The EFQC Enquirer: 15 July 2025

In this edition

Important Information

• NDIS Commission Regulatory Compliance Priorities for 2025/26
• Beware the Risks: Using Generic Consultants and Policies in NDIS Registration
• Latest Update: NDIS Commission SIL Practice Standards Review

Ask the Experts

• Understanding the NDIS Registration Process Sharon Floyd, Director at Engels Floyd Quality Consulting

Important Information

1. NDIS Commission Regulatory Compliance Priorities for 2025/26

The NDIS Quality and Safeguards Commission has announced its regulatory priorities for 2025/26, focusing on strengthening the quality and safety of disability supports and ensuring the rights and well-being of NDIS participants remain central to provider practices. Key priorities include:

• 1. Reduction and Elimination of Restrictive Practices
  • The Commission is prioritising the reduction and elimination of regulated restrictive practices, recognising that such practices can infringe on a person’s rights, cause trauma, and breach basic human rights.
  • Providers are expected to ensure human rights are embedded in all disability supports and services, actively working to remove barriers to full inclusion for people with disability.

• 2. Strengthened Oversight of Unregistered Providers and Sole Traders
  • There will be increased oversight and regulation of unregistered NDIS providers and sole traders.
  • The Commission will take decisive action against unregistered providers who breach the NDIS Code of Conduct, especially where such breaches undermine participant rights or the integrity of the NDIS.

• 3. Managing High-Risk Health Concerns
  • Providers are required to proactively identify and manage high-risk health concerns among participants, such as mealtime management, wound care, and timely access to health services.
  • The Commission will monitor and take strong action against providers failing to meet these obligations, aiming to prevent poor health outcomes and avoidable deaths in the sector.

• 4. Supporting, Training, and Monitoring a Skilled Workforce
  • Ensuring workers are appropriately skilled and supported remains a top priority.
  • Providers must have robust systems and processes to support, train, and monitor their workforce, ensuring safe and high-quality service delivery.

What This Means for Providers

• Compliance: Both registered and unregistered providers are expected to comply with the NDIS Code of Conduct and certain regulatory requirements.
• Human Rights Focus: All supports and services must prioritise the dignity, safety, and inclusion of people with disability.
• Workforce Development: Ongoing training and capability-building for staff is essential.
• Health and Safety: Implementing robust systems to monitor and manage high-risk health concerns is critical for participant safety and compliance.
• Behaviour Support: Providers should review and, where necessary, revise their behaviour support strategies to align with the goal of reducing restrictive practices.

Engels Floyd Quality Consulting is committed to assisting NDIS providers in meeting these compliance priorities. Our team offers tailored support to ensure your organisation remains compliant and continues to deliver high-quality services to participants.
For more information or assistance, please contact us at info@engelsfloyd.com or call 1300 790 194.

2. Beware the Risks: Using Generic Consultants and Policies in NDIS Registration

NDIS providers are being strongly cautioned against using generic consultants and off-the-shelf policies and procedures when applying for registration or maintaining compliance. The NDIS Commission has seen a surge in applications being rejected or delayed due to “cut and paste” self-assessments and documentation that do not reflect the unique operations of each provider, as highlighted here.

Why Are Applications Being Rejected?

• Duplicate Responses: Thousands of applications have reportedly been refused because providers submitted identical or near-identical self-assessment answers, often supplied by consultants using the same templates for multiple clients.
• Lack of Customisation: Applications that rely on generic policies fail to demonstrate how the provider’s actual services, governance, and risk management meet NDIS Practice Standards.
• False Promises: Some consultants claim they can “do it all” or guarantee registration, but these assurances are not true as no consultant can guarantee registration, a decision made by the NDIS Commission and may indicate a lack of integrity.
• No Real Expertise: A red flag is when a consultant’s website lacks credible information about their team’s experience or qualifications.

Best Practice Advice for Providers

• Vet Consultants Carefully: Choose consultants who offer tailored support and have proven experience in the NDIS sector.
• Customise Everything: Ensure all documentation is unique to your business and addresses your actual services and risks.
• Stay Involved: Consultants should guide and support you, not take over the process. You must understand and own your compliance obligations.
• Regularly Review Policies: Keep your documentation up to date as NDIS standards evolve.

By investing in quality, customised compliance processes and working with reputable consultants, NDIS providers can protect their business and ensure participant safety

At Engels Floyd Quality Consulting, our key strengths are our decades of experience in the disability sector and our commitment to offering individualised support to every client. We only provide customised policies and procedures that are designed to reflect your organisation’s unique structure, services, and systems. Our team works closely with you to ensure all documentation aligns with your actual operations and meets NDIS Practice Standards, empowering you to understand and own your compliance obligations.

3.   Latest Update: NDIS Commission SIL Practice Standards Review 

The NDIS Commission is currently reviewing and redeveloping the Supported Independent Living (SIL) Practice Standards to improve quality, safety, and participant rights in SIL services.

What’s New?

• Co-Design Approach: The new standards are being developed with input from people with disability, providers, and advocates.
• Key Focus: Enhanced safety, clearer staff training requirements, improved auditing processes, and stronger participant privacy and choice.
• Mandatory Registration: All SIL providers will soon be required to register with the Commission, increasing oversight and accountability.

Next Steps
An exposure draft of the new standards will be released later in 2025 for sector feedback.
Providers should stay informed and start preparing for changes to compliance and workforce training.

Coming Soon: SIL Essentials Workshop + Free Audit Readiness Checklist

At EFQC, we’re excited to be developing our new SIL Essentials Workshop—a practical, compliance-focused session designed to help Supported Independent Living (SIL) providers confidently understand and implement their responsibilities under the NDIS Practice Standards.

To support you further, we will also be launching a FREE Pre-Audit Checklist for SIL providers on our website —helping you get certification-ready with clarity and confidence.

Stay tuned for more details – coming soon!

Ask the Experts

Understanding the NDIS Registration Process with Sharon Floyd, Director at Engels Floyd Quality Consulting

What is NDIS Registration? NDIS registration requires providers to demonstrate that they meet quality and safety standards through an application and independent audit. The NDIS Commission assesses suitability and makes a final decision. Registered providers are subject to ongoing compliance audits every 18 months and three years.

Do I need to register to provide NDIS supports?
Registration depends on the types of support offered and how the participant’s plan is managed. It is legally required for providers serving NDIA-managed participants or high-risk supports (e.g., specialist behaviour support, restrictive practices). The NDIS Commission have announced that registration will become mandatory for platform providers, SIL services, and support coordinators.

What are the benefits of NDIS registration?
Increased Access to Clients: Registration allows services to participants managed by the NDIA, giving assurance of compliance with standards and boosting credibility.
Payment Security: Registered providers have assured payments from the NDIS, minimising financial risks.
Enhanced Visibility and Collaboration: Registered providers are listed in the NDIS Provider Register, gaining visibility and access to networking opportunities within the NDIS community.
Compliance Benefits: Registration assures quality and safety, increasing participant trust.

How long does NDIS registration take, and what does it cost? Registration varies based on application complexity and audit findings; it typically takes several months. Application submission is free, but an independent audit is required, and providers are responsible for audit fees, which vary by audit type and compliance needs.

What are the mandatory compliance requirements for registered providers? Registered NDIS providers must meet specific compliance requirements to ensure safe, ethical, and high-quality support for participants. These include:

• NDIS Practice Standards: Providers must meet the relevant NDIS Practice Standards, which vary based on the services provided.
• Code of Conduct: Providers and staff are expected to act ethically, respect participant rights, and uphold professional boundaries. Staff must be trained in the NDIS Code of Conduct.
• Complaints, Feedback and Incident Management: Providers need a documented complaints, feedback and incident management system.
• Worker Screening: Staff in risk-assessed roles must have a current NDIS Worker Screening Check.
• Governance: Clear governance structures are required to ensure accountability, transparency, and ethical management practices.
• Personnel Suitability: Key personnel must be qualified and suitable for their roles.

What are the key steps for registering an NDIS business?

 
By planning ahead and thoroughly addressing all registration requirements, you can streamline the registration process and set your organisation up for success.
 
We have a free resource on our website that will provide you with all the essential information in preparing for NDIS registration here.