A detailed overview of the key compliance dates and regulatory obligations published by the national regulator for registered training organisations and ESOS providers in the 2026 calendar year
The National Regulator Publishes 2026 Obligations Planners
The national regulator has published its 2026 obligations annual planners for both registered training organisations and providers registered under the Education Services for Overseas Students framework. The two planners set out the key compliance dates, reporting deadlines, and regulatory obligations that apply across the 2026 calendar year. Both documents are described by the regulator as reminders, with an express note that registered providers need to meet other obligations and deadlines beyond those listed in order to comply with the requirements of ongoing registration in 2026.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au); ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au).
The publication of these planners at the commencement of the calendar year provides registered providers with a consolidated reference point for the principal compliance milestones ahead. For providers managing multiple regulatory obligations — including those holding both RTO registration and CRICOS registration — the planners serve as a practical tool for mapping the year’s compliance calendar. The following overview examines each obligation identified in the planners, presented in chronological sequence.
2026 RTO Obligations Annual Planner: Key Dates and Requirements
The 2026 RTO Obligations Annual Planner identifies a series of compliance milestones that apply to all registered training organisations regulated by the national regulator. The planner is structured chronologically, commencing with obligations that should be attended to as soon as practicable and progressing through to deadlines in the second half of the calendar year.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au).
Immediate: Confirming Contact Details and ASQAnet Access
The first obligation identified in the planner is the confirmation of contact details and ASQAnet portal access. The planner directs registered training organisations to verify that their ASQAnet login details are current and functional, and that the Chief Executive Officer’s email address and mobile number are up to date in the ASQAnet portal. The stated purpose of this requirement is to ensure that the Chief Executive Officer can receive important notices and information from the national regulator. This obligation is designated as requiring immediate attention, with no fixed deadline, reflecting its foundational importance to all subsequent regulatory communications throughout the year.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au).
The significance of this obligation extends beyond administrative housekeeping. Regulatory correspondence, including notices of investigation, production requests, compliance directions, and audit notifications, is typically directed to the registered contact details held by the regulator. Where those details are incorrect or out of date, there is a risk that critical correspondence may not reach the intended recipient within the timeframes specified. Given the compressed compliance periods that may accompany production requests under section 62 of the National Vocational Education and Training Regulator Act 2011 — which, as discussed elsewhere in this edition, can be as short as 24 hours — the failure to maintain current contact details can have material consequences for a provider’s ability to respond in a timely manner.
28th February 2026: Total VET Activity AVETMISS Data Reporting
The planner states that every registered training organisation must report its Total VET Activity AVETMISS data for the 2025 calendar year to the National Centre for Vocational Education Research by 28th February 2026. The reporting is conducted through the AVETMISS Validation Software system. The planner further notes that where a registered training organisation did not deliver any nationally accredited training during 2025, a nil return must be provided directly to the National Centre for Vocational Education Research. The planner expressly states that failure to report on time can lead to penalties.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au); NCVER, AVETMISS Validation Software (avs.ncver.edu.au).
The AVETMISS reporting obligation is one of the most operationally significant compliance deadlines in the annual cycle. The data submitted forms part of the national VET data collection and underpins sector-wide reporting, funding allocations, and regulatory intelligence activities. From a provider perspective, the accuracy and completeness of the submitted data are important not only for compliance with the reporting obligation itself, but also because the data may be referenced in subsequent regulatory activities, including audits and compliance inquiries. Discrepancies between reported data and the provider’s internal records can become a point of regulatory interest if the data is later examined in the context of a compliance matter.
The requirement to submit a nil return where no nationally accredited training was delivered is also notable. Providers that have maintained their registration but have not been actively delivering training are not exempt from the reporting obligation. The nil return confirms to the national data collection that the absence of delivery data is a function of nil activity rather than a failure to report. For providers in this position, the nil return also intersects with other regulatory considerations, including the potential for the regulator to examine the reasons for extended periods of non-delivery.
31st March 2026: Annual Declaration on Compliance
The planner identifies the Annual Declaration on Compliance as due for submission in March 2026. The Chief Executive Officer is expected to receive an email with a unique Annual Declaration on Compliance link on 3rd March 2026, and submissions close on 31st March 2026. The Annual Declaration on Compliance is described elsewhere in the regulator’s published guidance as a statement confirming compliance with obligations under the National Vocational Education and Training Regulator Act 2011, linked to record accuracy, ongoing monitoring of regulatory requirements, and the ability to identify and address risks.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au); ASQA, Annual Declaration on Compliance guidance (asqa.gov.au).
As discussed in detail in a separate article in this edition, the Annual Declaration on Compliance is a one-time, non-editable submission that creates an enduring documentary record. The window between 3rd March and 31st March 2026 provides approximately four weeks within which the legally responsible person must prepare, review, and submit the declaration. Given the evidentiary significance of the declaration in enforcement contexts and the inability to amend it after submission, this four-week window should be treated as the execution phase of a preparation process that commences well in advance. Providers that begin their internal evidence review and governance sign-off process only upon receipt of the declaration link on 3rd March 2026 may find the available time insufficient for the level of diligence the declaration warrants.
15th June and 30th June 2026: Scope Review and Quality Indicator Data
The planner identifies two obligations with deadlines in June 2026. The first relates to preparation for the Annual Registration Charge. The planner states that the Annual Registration Charge is calculated at the start of the financial year and that scope items determine the charge amount. Providers are directed to review their scope of registration and submit any scope removal applications by 15th June 2026, to ensure that applications are processed in time for accurate invoicing on 1st July 2026.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au).
The second June obligation relates to the submission of 2025 quality indicator data. The planner states that quality indicator data is to be submitted using the Quality Indicator webform, which will be open from January and close on 30th June 2026. The quality indicator submission is part of the national quality assurance framework and provides data that contributes to the regulator’s understanding of provider performance. As with AVETMISS reporting, the accuracy and completeness of quality indicator data are relevant not only to the reporting obligation itself but also to the broader compliance profile that the regulator may examine in subsequent regulatory activity.
The scope review obligation is particularly relevant for providers seeking to manage the cost of their Annual Registration Charge. Scope items that are no longer being delivered, or that the provider does not intend to deliver in the forthcoming period, should be reviewed and, where appropriate, removed prior to the 15th June 2026 deadline. Failure to complete scope removal applications by this date may result in the provider being invoiced for scope items that are no longer operationally relevant, with limited ability to adjust the charge after the invoice is issued on 1st July 2026.
31st July 2026: Payment of the Annual Registration Charge
The planner states that the Annual Registration Charge invoice must be paid by 31st July 2026. The Annual Registration Charge is a statutory fee associated with ongoing registration, and its payment is a condition of maintaining registration status. The planner does not elaborate on the consequences of late payment, but it is well established within the regulatory framework that failure to pay registration charges can trigger compliance action, including potential consequences for the provider’s registration status.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au).
Ongoing: Registration Renewal
The planner directs providers to keep their registration up to date by checking the expiry date through the ASQAnet portal or the national training register. The planner notes that renewal applications open 12 months prior to registration expiry and close 90 days before expiry, and that late applications may not be accepted. This timeline means that providers whose registration expires in 2026 or early 2027 should already be monitoring their renewal window and preparing renewal applications well in advance of the 90-day closure point.
Source: ASQA, 2026 RTO Obligations Annual Planner (asqa.gov.au).
The consequence of failing to submit a renewal application within the required window is potentially severe. Where an application is not accepted due to late submission, the provider’s registration may lapse at the expiry date, requiring a fresh initial registration application rather than a renewal. The distinction between renewal and initial registration carries significant implications for cost, processing time, and the scope of assessment involved.
2026 ESOS Obligations Annual Planner: Key Dates and Requirements
The 2026 ESOS Obligations Annual Planner identifies the compliance milestones that apply specifically to providers registered under the Education Services for Overseas Students framework. The obligations set out in this planner are in addition to those in the RTO planner for providers that hold both registrations. The planner is similarly structured chronologically, with obligations ranging from immediate to mid-year deadlines.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au).
Immediate: Verification of CRICOS Information
The ESOS planner directs providers to review the information about their organisation published on the Commonwealth Register of Institutions and Courses for Overseas Students website. Where the published information is not accurate, providers are directed to make changes through the ASQAnet portal. The accuracy of CRICOS information is relevant to the provider’s regulatory standing, to the information available to prospective overseas students, and to the integrity of the national register. Inaccurate or out-of-date CRICOS information may also become a point of regulatory interest in the event of an audit or compliance inquiry.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au); CRICOS (cricos.education.gov.au).
Ongoing: Fit and Proper Provider Notification Requirements
The ESOS planner identifies an ongoing obligation to notify the national regulator within 10 business days of any new or changed ownership or control arrangements between the provider and education agents. The planner references an amended requirement and directs providers to a fact sheet published by the Department of Education for further details. This notification obligation is linked to the fit and proper provider requirements under the ESOS framework and reflects the regulatory concern with transparency and accountability in the relationships between registered providers and the agents through which overseas students may be recruited.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au); Department of Education fact sheet on amended fit and proper provider requirements.
The 10-business-day notification window is a strict compliance requirement. Failure to notify within the specified period may itself constitute a breach of the provider’s obligations under the ESOS framework. Providers that engage education agents, or that have existing arrangements with education agents, should ensure that internal processes are in place to identify any changes in ownership or control arrangements as they occur and to generate the required notification within the mandated timeframe.
From 1st January 2026: Cancellation of Registration Due to Nil Delivery
The ESOS planner identifies a significant registration consequence that takes effect from 1st January 2026. The planner states that a provider that does not deliver a CRICOS-registered course at a registered onshore location to an overseas student within a 12-month period from 1st January 2026 will have its CRICOS registration cancelled for all courses in all locations. The planner directs providers to a fact sheet published by the Department of Education on this change to registration requirements.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au); Department of Education, ESOS Framework resources (education.gov.au).
This provision represents a material change in the consequences of non-delivery for CRICOS-registered providers. The cancellation applies across all courses and all locations, meaning that a provider’s entire CRICOS registration is at risk if delivery does not occur within the 12-month period. The provision is framed as commencing from 1st January 2026, which means that the 12-month assessment period runs from that date. Providers that are not currently delivering to overseas students at a registered onshore location should treat this provision as an immediate risk management priority, either by commencing delivery within the required period or by assessing the implications of registration cancellation for their overall operations and registration status.
The cancellation for nil delivery also has implications for providers that may be experiencing disruptions to their overseas student enrolments, whether due to market conditions, visa processing delays, agent-related issues, or operational challenges. The 12-month period does not, on the face of the planner, provide for exceptions based on the reasons for non-delivery. Providers in this position should seek specific advice on the application of this provision to their circumstances and on any mechanisms that may be available to address the risk of cancellation.
Tuition Protection Service Levy
The ESOS planner states that providers are required to pay the Tuition Protection Service levy. The planner indicates that the Tuition Protection Service Director will provide a written notice setting out the amount of the levy and the due date for payment. The planner directs providers to the Tuition Protection Service online portal and to the Department of Education’s published advice on the 2026 International Tuition Protection Service Levy settings. The Tuition Protection Service is a key element of the consumer protection framework for overseas students, and the levy funds the protections that apply when a provider is unable to deliver a course for which an overseas student has paid.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au); Tuition Protection Service (tps.gov.au); Department of Education, TPS resources (education.gov.au).
Late March 2026: CRICOS Annual Registration Charge
The planner states that the CRICOS Annual Registration Charge is payable to the Department of Education by late March 2026. The planner expressly notes that this charge is additional to the Annual Registration Charge payable to the national regulator. For providers holding both RTO and CRICOS registrations, this means that two separate registration charges are payable during the 2026 calendar year: the CRICOS Annual Registration Charge to the Department of Education by late March 2026, and the Annual Registration Charge to the national regulator by 31st July 2026.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au).
31st July 2026: Annual Registration Charge for ELICOS-Only Providers
The planner identifies a separate Annual Registration Charge obligation for ELICOS-only providers, with a payment deadline of 31st July 2026. The planner notes that this charge is payable to the national regulator and is additional to the CRICOS Annual Registration Charge payable to the Department of Education. This dual-charge structure means that ELICOS-only providers are subject to registration charges from two separate entities, each with its own invoicing process and payment deadline.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au).
Ongoing: ESOS Registration Renewal
The ESOS planner mirrors the RTO planner’s guidance on registration renewal, directing providers to check their registration expiry date through the ASQAnet portal or the Provider Registration and International Student Management System. The same 12-month opening window and 90-day closure rule apply, and the same warning about late applications potentially not being accepted is included. For providers holding CRICOS registration, the renewal process encompasses additional elements specific to the ESOS framework, including the maintenance of CRICOS registration for individual courses and locations.
Source: ASQA, 2026 ESOS Obligations Annual Planner (asqa.gov.au).
The Combined Compliance Calendar for Dual-Registered Providers
For providers holding both RTO registration and CRICOS registration, the combined effect of the two planners creates a compliance calendar with obligations distributed across the entire 2026 year. The earliest deadlines require immediate attention to contact details and CRICOS information verification. The AVETMISS reporting deadline of 28th February 2026 is followed closely by the Annual Declaration on Compliance window opening on 3rd March and closing on 31st March 2026. The CRICOS Annual Registration Charge is payable by late March 2026. Scope review and quality indicator data submissions are due by mid to late June 2026. The Annual Registration Charge for RTO registration and, for ELICOS-only providers, the separate Annual Registration Charge, are payable by 31st July 2026. Registration renewal monitoring is an ongoing obligation throughout the year.
The density of this compliance calendar underscores the importance of structured compliance planning and internal deadline management systems. Providers that rely on ad hoc or reactive approaches to compliance deadlines face an elevated risk of missing critical dates, with consequences that can range from financial penalties to registration cancellation. The publication of the annual planners by the national regulator provides a starting point for compliance calendar development, but the planners themselves note that they are provided as reminders only and that providers need to meet other obligations and deadlines beyond those listed.
The Planners as a Starting Point, Not the Complete Picture
The 2026 RTO and ESOS Obligations Annual Planners published by the national regulator provide a valuable consolidated reference for the principal compliance milestones of the calendar year. The planners identify specific dates, reporting obligations, payment deadlines, and ongoing requirements that apply to registered training organisations and ESOS providers. However, both planners include an express statement that they are provided as reminders only and that providers need to meet other obligations and deadlines to comply with the requirements of ongoing registration in 2026.
This qualification is important. The planners do not capture the full range of regulatory obligations that may apply to a registered provider, including obligations arising from specific conditions of registration, directions from the regulator, legislative amendments, or changes to standards and regulatory guidance that may occur during the year. Providers should treat the planners as the foundation of their compliance calendar, supplemented by systematic monitoring of regulatory communications, legislative developments, and the specific conditions that attach to their individual registration.
The planners are available on the national regulator’s website. Providers are encouraged to review both documents in full and to incorporate the identified dates and obligations into their internal compliance management systems at the earliest opportunity.
