The EFQC Enquirer: 14 January 2026

In this edition

EFQC Update

• Engels Floyd Quality Consulting – Our priorities in 2026
• Industry collaboration – Championing Women in Care: Supporting Cassie Day’s International Women’s Day Luncheon 27 February 2026.

Important Sector & Regulatory Updates

• Mandatory Registration Confirmed for SIL & Platform Providers
• Have Your Say: Consultation on the Definition of an NDIS Provider
• Changes to Plan Management Registration Requirements
• NDIS Commission Evidence Review Highlights Preventable Health Risks for NDIS Participants

Ask the Experts

• NDIS Registration Q and As — What Providers Need to Do Now (Sharon Floyd, Director Engels Floyd Quality Consulting)

EFQC Update

Our priorities for 2026

Supporting Supported Independent Living (SIL) and Platform providers to prepare for mandatory registration

• Following the announcement regarding mandatory registration, we are continuing to support providers to understand what this decision means for their organisation and how to prepare in a practical, informed way. Our focus is on helping providers assess readiness, strengthen systems, and approach registration and audit requirements with confidence.
• Read more about the mandatory registration decision and our ask the experts article below on how to prepare for registration.

Re-entering the Home Care consultancy space

• In response to demand and growing overlap between NDIS, home care and quality system requirements, EFQC is re-entering the home care consultancy space. This includes support with registration, governance, quality systems, audits, training, and integrated approaches across NDIS and home care services. We have the benefit of hand-picked Associates with extensive NDIS and aged care experience.
• View our upcoming NDIS & Home Care workshop

Specialised compliance and regulatory support

• We continue to provide targeted, individualised consultancy support for providers experiencing regulatory action or increased compliance pressure, drawing on our deep understanding of audit processes and regulatory expectations.

Quality management reviews and ongoing support

• Beyond audit preparation, we are increasingly being asked by providers to undertake quality management reviews and to provide ongoing support to help providers embed quality into everyday operations, not just at audit time.

Industry collaboration – Championing Women in Care: Supporting Cassie Day’s International Women’s Day Luncheon in Adelaide on 27 February 2026.

We are proud to support Cassie Day’s International Women’s Day Luncheon, an event that celebrates, elevates, and champions women working across the disability, health, and human services sectors.
This inspiring luncheon brings together leaders, practitioners, and change-makers who are shaping the future of care. It provides a valuable opportunity to connect, reflect, and recognise the critical role women play in driving quality, compassion, and innovation across our sector.

At EFQC, collaboration and sector leadership are central to how we work. Supporting events like this aligns with our commitment to professional development, shared learning, and strengthening the systems that underpin safe, ethical, and high-quality services for the people we support.

We encourage colleagues and providers to attend and be part of this important conversation—celebrating women’s leadership, amplifying lived and professional experience, and continuing to build a stronger, more connected care sector.

Find out more and secure your ticket:
https://www.stickytickets.com.au/oil3m0/international_womens_day_2026_championing_women_in_care.aspx

Important Information

1. Mandatory Registration Confirmed for SIL & Platform Providers

The NDIS Quality and Safeguards Commission has confirmed a significant regulatory change for the sector: from 1 July 2026, Supported Independent Living (SIL) providers and platform providers will be required to be registered with the NDIS Commission.

This decision means that providers currently operating unregistered in these higher-risk service areas will need to meet the NDIS Practice Standards, undergo independent audits, and comply with the full range of governance, workforce, incident management, and reporting requirements that apply to registered providers.

Why this matters?

The move to mandatory registration responds to findings from the NDIS Review, the Disability Royal Commission, and the Provider and Worker Registration Taskforce, all of which highlighted the need for stronger safeguards, oversight, and accountability—particularly where participants have complex needs or services are delivered through digital platforms.

What should providers do now?

While the requirement does not take effect until 1 July 2026 the message from the regulator is clear: providers should start preparing now. Registration is not just an application—it requires evidence that policies, procedures, systems, and practice are implemented and operating effectively.

Early preparation gives providers time to:

• review service models against the NDIS Practice Standards
• identify gaps in governance, risk, and quality systems
• plan realistically for audit readiness and workforce capability.

Want practical answers?

We’ve unpacked the most common questions providers are asking about NDIS registration, audits, timelines, and preparation in our Ask the Experts article below.

2. Have Your Say: Consultation on the Definition of an NDIS Provider

The Australian Government has opened a public consultation on how the term “NDIS provider” is defined in the National Disability Insurance Scheme Act 2013. This is an important step in broader reforms aimed at improving quality, safety, accountability, and transparency across the NDIS market.

What’s this consultation about?
The Department of Health, Disability and Ageing is inviting views from NDIS providers, participants, families, carers, workers and the broader disability community on a proposed definition of an NDIS provider. The goal is to ensure that regulation is fit-for-purpose and proportionate to the level of risk and complexity of supports delivered.

A clear legislative definition helps determine:

• Who counts as a provider under the NDIS Act
• Which services and supports trigger formal regulation
• How registered vs unregistered arrangements are understood
• How oversight and compliance apply across different service types

This work builds on advice from the NDIS Provider and Worker Registration Taskforce, the NDIS Review, and the Disability Royal Commission — all of which recommended a more transparent and risk-proportionate regulatory framework.

Why it matters for NDIS providers
For providers, how the term “NDIS provider” is defined could shape future regulatory expectations, including:

• Registration requirements
• Audit and reporting obligations
• Scope of services covered by the NDIS Commission’s oversight

How to get involved
The consultation paper and supporting materials are publicly available here. Submissions are open now and accessible via the consultation portal.

This is a key chance for providers to have input on a consultation that could influence regulatory clarity, sector expectations, and how quality and safeguards apply across the NDIS market.

3. Changes to Plan Management Registration Requirements

The NDIS Quality and Safeguards Commission has introduced stronger assessment requirements for providers delivering plan management services.

Plan management providers must now provide evidence of relevant qualifications, professional memberships, and NDIS Worker Screening Checks, along with a signed declaration confirming they understand their obligations. This evidence will be reviewed as part of the audit process.

New applicants for plan management registration must include this information with their application. Existing plan managers may already have been asked to provide it, and all other registered providers will be required to submit the evidence at their next audit.

These changes aim to ensure plan management services are delivered by appropriately qualified and skilled providers.

Qualifications and acceptable professional memberships are outlined in the NDIS Practice Standards Qualification and Professional Associations Required Documentation Guide Plan Nov 2025 .pdf

4. Mandatory registration for Support coordination

The NDIS Commission has paused mandatory registration for Support Coordination while further regulatory reforms are considered, following sector consultation between November 2024 and July 2025.

5. NDIS Commission Evidence Review Highlights Preventable Health Risks for NDIS Participants

The NDIS Quality and Safeguards Commission has released an evidence review exploring the underlying causes of poor health outcomes and preventable deaths among people with traumatic brain injury (TBI), autism spectrum disorder (ASD), and intellectual disability (ID). The findings highlight significant areas where early intervention and targeted provider action can improve participant wellbeing and reduce avoidable harm.

Key Findings by Disability Type

Traumatic brain injury (TBI)
Participants with TBI often live with multiple health conditions affecting the heart, hormone balance, digestion, and mental health. They also face a higher likelihood of death by self-harm compared with the general population.

Autism spectrum disorder (ASD)
People with ASD experience elevated rates of obesity, diabetes, and poor mental health. They are more likely to require emergency or hospital care and have higher mortality rates linked to accidents, injury, and suicide.

Intellectual disability (ID)
Participants with ID are at increased risk of obesity, diabetes, and chronic respiratory or urinary problems. Deaths are more commonly related to infections and health issues affecting the digestive, endocrine, and nervous systems.

What Providers Can Do
The review reinforces the importance of routine health monitoring and individualised care strategies. Providers play a crucial role in identifying, addressing, and preventing emerging health concerns. Consider the following approaches:

• Conduct regular health assessments and monitoring tailored to each participant’s needs.
• Implement proactive screening and early intervention practices.
• Keep accurate health records and track changes over time.
• Act swiftly when health concerns arise.
• Build staff capability through targeted training on disability-specific health risks.
• Strengthen coordination between support teams, families, and healthcare professionals.

By embedding these practices into everyday service delivery, providers can help reduce risks from preventable health factors and support safer, healthier outcomes for participants.

Read the full evidence review: NDIS Commission Evidence Review

Ask the Experts

Ask the Experts: NDIS Registration Q and As — What Providers Need to Do Now (Sharon Floyd, Director Engels Floyd Quality Consulting)

With mandatory NDIS registration for Supported Independent Living (SIL) and Platform providers commencing from 1 July 2026, many organisations are seeking clarity on what the NDIS Quality and Safeguards Commission — and auditors — actually expect.

Drawing on EFQC’s experience supporting NDIS providers since 2012 and training nearly 1,600 NDIS auditors on behalf of the Commission, Sharon Floyd is answering the questions we are most frequently asked.

Q: When should SIL and Platform providers start preparing for NDIS registration?
A: For most providers, preparation should start now — but preparation is not the same as submitting an application.

Early preparation allows time to build, embed, and test governance and service delivery systems. Submitting an application before systems are operating in practice is one of the most common causes of delayed or unsuccessful registration outcomes.

Starting early is a strategic advantage. Applying too early is a risk.

Q: What does “audit-ready” actually mean under the NDIS?
A: Being audit-ready means your systems are implemented, embedded, and working — not just documented.
NDIS auditors assess whether:

• Policies guide everyday practice
• Systems are actively used and monitored
• Staff understand and apply procedures
• Leadership oversight is visible and effective

Policies that exist only on paper significantly increase the risk of non-conformities.

Q: Can we submit our application first and address gaps during the audit?
A: This approach almost always creates problems.
Submitting an NDIS registration application triggers the certification audit process. Auditors expect systems to already be in place and operating. Identifying gaps during the audit typically leads to corrective actions, extended timeframes, and increased cost.
At EFQC, we consistently see stronger outcomes when gaps are addressed before an application is lodged.

Q: What are auditors really looking for during certification audits?
A: Auditors focus on implementation, consistency, and oversight.
They will:

• Interview workers, management, and participants
• Observe service delivery and environments
• Review records, registers, and governance evidence

Key areas of focus include incident and complaints management, risk management, governance and operational management, worker training and supervision, participant rights, and continuous improvement.

Q: How important are staff interviews in the audit process?
A: Staff interviews are critical.

Auditors expect staff to confidently explain how systems operate in practice, using real examples. This cannot be achieved through last-minute coaching or scripted responses. Strong audit outcomes occur when staff have been trained, supported, and working within embedded systems over time.

Q: What are the biggest risks for SIL and Platform providers rushing registration?
A: Common risks EFQC identifies in audits include:

• Generic or recently written policies
• Limited evidence of system use
• Staff uncertainty during interviews
• Weak governance oversight

These risks are manageable with early, structured preparation.

Q: If I use a consultant to help with my NDIS registration, who is responsible for the application?
A: The provider is always responsible.
The NDIS Commission expects providers to be actively involved, understand what has been submitted, and be able to explain how their systems operate in practice. Consultants can guide and support — but NDIS registration cannot be outsourced. This expectation applies to both initial registration and future audits. Further information on the Commissions expectation are available here on my recent Linked in post.

Q: What really drives successful NDIS registration outcomes?
A:Successful NDIS registration is not about speed or paperwork — it is about ownership, implementation, and readiness.
Providers achieve the strongest outcomes when they take genuine ownership of their systems and can demonstrate that those systems are operating in practice, not just described in documents.
This means providers who:

• Build systems early so they have time to operate and mature
• Embed systems into everyday practice, rather than relying on policies alone
• Prepare staff and participants so they understand their roles during audits
• Test readiness honestly through internal or preparatory audits.

Providers who undertake these actions are far better positioned for smooth certification outcomes, reduced audit risk, and ongoing compliance beyond initial registration.

At EFQC, we consistently see that providers who focus on implementation — not shortcuts — are the ones who navigate NDIS registration with confidence and resilience.

Need Support with NDIS Registration or Audit Readiness?
Engels Floyd Quality Consulting has supported NDIS providers since 2012 and trained nearly 1,600 NDIS auditors on behalf of the NDIS Commission.
We support providers with:

• NDIS registration planning and applications
• System development and implementation
• Preparatory and internal audits
• Audit support and preparation
• Ongoing quality management coaching
• Training and development

If you would like to know more about registration and how we may support you, contact EFQC for a complimentary, no-obligation consultation at 1300 790 194 or info@engelsfloyd.com.