ASQA puts RTO ownership and governance disclosures under closer scrutiny

The VET regulator says training providers must disclose material changes promptly and keep fit and proper person assessments current. Its September reminder is relevant to RTOs delivering early childhood qualifications.

Registered training organisations (RTOs) that delay telling the Australian Skills Quality Authority (ASQA) about ownership or other material changes can expect closer attention from the regulator.

ASQA confirms it will increasingly follow up with providers that do not make notifications at the required time, particularly when ownership changes. The reminder draws on ASQA’s Statement of Regulatory Expectations, issued in May 2026, concerning material change notifications and Fit and Proper Person Requirements (FPPRs). It is a renewed enforcement message, rather than a new set of notification rules. 

The statement applies to RTOs, including those delivering early childhood education and care (ECEC) qualifications. It does not change the separate notification obligations of approved early childhood services under the National Quality Framework.

ASQA’s statement identifies changes involving ownership, control and governing persons, as well as financial viability or compliance risks, among matters that may require disclosure. Significant events arising through a third-party arrangement can also be relevant if they affect an RTO’s capacity to meet its obligations. 

The deadlines are specific. Prospective ownership changes must be notified as soon as practicable before they take effect. Changes concerning governing persons must generally also be notified beforehand; where a change cannot be determined until it occurs, the RTO has 10 business days to notify ASQA. An event that significantly affects the organisation’s ability to comply with its obligations must be reported within 10 business days after the event occurs. 

Those distinctions matter for boards and executives considering a sale, restructure or leadership appointment. Waiting until a transaction has closed may be inconsistent with the requirement to notify ASQA of a prospective ownership change beforehand.

ASQA’s ownership guidance also warns that registration cannot simply be transferred to a different legal entity. Where a transaction creates a new entity, its registration position needs to be resolved before it delivers training. 

FPPRs are not confined to an RTO’s initial registration. ASQA describes them as a continuing obligation and expects providers to assess whether they and their governing persons meet the requirements as circumstances change.

Declarations are submitted at initial registration, at renewal and when relevant changes occur, including a change of governing person or a matter arising during that person’s appointment that may affect their fitness and propriety. ASQA may also request a declaration at any time. 

The regulator expects RTOs to have due diligence arrangements and records that show how they considered relevant matters. These may include legal, regulatory, financial, governance or compliance issues, including matters arising overseas. Disclosure does not itself mean a person is unsuitable; it gives ASQA the information needed to assess the circumstances. 

What concerns ASQA is incomplete, delayed or selective disclosure. Its statement says providers that do not comply with FPPRs or material change notification requirements will be found non-compliant with the 2025 Standards for RTOs, and further regulatory action may follow. It does not say that every late notification will produce the same outcome. 

For an RTO training future early childhood educators, ownership and governance decisions sit alongside its responsibility for the quality of training and assessment. The ASQA Accountability Practice Guide points providers to systems for identifying significant events, meeting notification deadlines and supplying further information when requested. 

A practical review would establish who within the RTO identifies a potential notification, who decides whether it must be reported and how a proposed transaction reaches that person before it takes effect. Providers with third-party training arrangements also need visibility of events that could affect their own compliance. These are governance implications of ASQA’s guidance, not additional steps newly mandated by the September update. 

ASQA’s message is that it places weight on timely, voluntary and complete disclosure. For RTO leaders, the September reminder makes the timing of those conversations as significant as the paperwork that follows.