What 2026 child safety changes mean for incident evidence in childcare

Australian childcare operators are entering a period where child safety, governance and evidence quality are becoming more tightly connected.

That shift is not only about whether a serious event occurs. It is also about whether a provider can show what happened, when it was identified, how the room responded, what was recorded, and what leadership could see in time.

The policy direction is already clear. From 1 September 2025, new regulatory requirements took effect in response to the child safety review under the National Quality Framework, including policies and procedures for the safe use of digital technologies and online environments, including CCTV, and a 24-hour notification timeframe for incidents or allegations of physical or sexual abuse. From 1 January 2026, refinements to the National Quality Standard sharpened the focus on child safety in Quality Area 2 and Quality Area 7. ACECQA’s overview of the 2025 and 2026 child safety changes points to a stronger emphasis on child-safe systems, clearer risk management and better governance.

The national early childhood worker register adds to that broader picture. Taken together, these changes suggest that transparency, traceability and operational discipline are becoming more important to how the sector is assessed and governed.

For providers, that raises a practical question: what counts as strong incident evidence now?

In many services, incident handling still depends heavily on later recollection, manual follow-up and reconstruction after the fact. That is not necessarily because teams are inattentive. It is often because the operational reality of a busy room works against clean and consistent record-keeping. Directors and approved providers may only see a partial picture once the immediate moment has passed.

That becomes harder to rely on when expectations around child safety and governance are rising.

Stronger incident evidence means more than an incident form completed later in the day. It means being able to establish a clear sequence of events: what happened before and during, where it happened, who became aware of it, what action was taken, whether escalation occurred, and how the record was maintained. It also means being able to show that access to sensitive information is controlled, that any images or video are handled appropriately, and that retention and deletion practices are governed rather than improvised.

This is why the refinements to Quality Areas 2 and 7 matter. Child safety is being reinforced not only at the level of immediate wellbeing, but also at the level of leadership, systems and accountability. In that environment, a policy on paper is unlikely to be enough if the underlying workflow is weak.

CCTV is one part of this discussion, but it should not be treated as a simple binary. The Australian Government’s national CCTV assessment is not a blanket endorsement of CCTV rollout. It is intended to examine the costs, benefits and risks, and to build a more informed evidence base around practice, privacy and operations. That distinction matters. The question is not whether CCTV is automatically good or bad. The better question is whether providers have child-safe, privacy-conscious and operationally mature ways of managing images, footage, access and review.

The same principle applies to digital technology more broadly. ACECQA’s guidance on the safe use of devices in education and care services and the National Model Code for Taking Images in Early Childhood Education and Care both point to the same underlying issue: services need clearer rules, stronger controls and better judgement around how images of children are captured, stored, accessed and shared.

For operator groups and approved providers, there are a few useful questions to ask now.

• Can we reconstruct a serious incident clearly within hours, not days?
• Do our services have practical and explicit rules for taking, storing, accessing and deleting images and video?
• Do room leaders, directors and central teams know what gets escalated, by whom, and how it is recorded?
• Can leadership identify patterns across rooms or services early enough to support action and follow-up?

These are not technology questions first. They are governance questions.

Technology may help, but it should be judged against clear operational standards. Does it support earlier awareness of risk? Does it improve the quality and consistency of documentation? Does it reduce ambiguity when leaders need to review an event? Does it keep sensitive information under appropriate control? If not, it may be adding complexity rather than strengthening child-safe practice.

For that reason, the sector conversation should probably move beyond whether a particular tool sounds advanced, and towards whether it strengthens the quality of response, evidence and oversight in real settings. That is a more useful test for providers, regulators and families alike.

The sector is moving into a period where child safety expectations are becoming more explicit, and where governance is likely to be judged increasingly on system quality, not just good intent. Services that treat incident evidence as part of child safety infrastructure, rather than as an administrative task at the end of an event, are likely to be better placed for what comes next.

Author:

Tanya Wenczel is Chief Executive Officer of Lunero. She works on child safety, governance and the practical use of technology in Australian early childhood settings. www.lunero.com.au