How Forged Licence Agreements and Stolen Intellectual Property Are Being Used to Build Fraudulent RTO Applications, and Why the Sector Must Confront It
The Market We Operate In
This is the market we operate in. Consultants are forging licence agreements for resources they never purchased. Fake End User Licence Agreements (EULAs) are created to disguise stolen intellectual property. Entire RTO registration applications assembled from fabricated evidence, submitted across multiple applicants, word for word. Student handbooks copied wholesale. Policies and procedures duplicated without alteration. Training and assessment strategies, business plans, and organisational charts are reproduced identically across separate organisations that have no connection to one another.
CAQA Resources, a division of Career Calling International, is one of the intellectual property holders directly affected. The Australian Skills Quality Authority (ASQA) contacted CAQA to verify ownership of learning and assessment materials that had appeared in multiple initial registration applications. CAQA confirmed that no licensing arrangements existed between CAQA Resources and the consultant distributing the materials. No permission had been granted. No fees had been paid. The materials were CAQA's. The agreements were forged.
Every application linked to this pattern received an overall risk rating of Severe. Everyone was rejected. None were given an opportunity to rectify.
What ASQA Found
ASQA is now requiring RTOs and initial registration applicants to produce paid invoices and signed licence agreements to verify who actually owns the training and assessment resources being presented in applications. What the regulator has found is alarming.
Multiple initial registration applications were rejected in recent months, all linked to the same pattern: a consultant submitting nearly identical documentation across different applicants. The same student handbooks. The same policies and procedures. The same training and assessment strategies. The same business plans. The same organisational charts. Word for word, across organisations that should have had entirely distinct operational documentation.
The findings extended well beyond intellectual property theft. False Memorandums of Understanding (MOUs) with aged care providers were submitted, where the aged care providers themselves confirmed no such agreement existed. Photographs of training equipment were sourced from overseas websites and presented as the applicant's own facilities. CEOs of the applicant organisations could not answer basic questions about their own operations during ASQA interviews because the entire submission had been constructed by the consultant. Financial documents contained identical figures across completely different organisations. Interview responses from different applicant CEOs were so similar in wording and structure that ASQA concluded the applicants had been coached.
What the consultant did, instead of securing legitimate access to resources, was create fabricated EULAs and service agreements to make it appear as though proper licensing had been arranged. Invoices were issued by the consultant's own entities for resources that belonged to CAQA and other organisations. This is not a case of carelessness or administrative oversight. This is deliberate, calculated, and unethical conduct by individuals who have turned the registration process into a money-making factory at the expense of every legitimate provider, every genuine student, and every resource developer who has invested years of expertise into building quality materials.
The Applicants Did Not Know
One of the most damaging aspects of this pattern is that the applicants themselves were often unaware of what had been done in their name. During closing meetings with ASQA, several CEOs confirmed they did not know the intellectual property of another organisation had been used without authority in their applications. They paid a consultant. They trusted that consultant. And that consultant used stolen materials and forged documents to assemble their entire submission.
The financial and reputational consequences for these applicants are severe. Application fees are lost. Months of preparation are wasted. The applicant's credibility with the regulator is damaged, potentially permanently. For some, the dream of establishing a registered training organisation has been destroyed by a person they paid to help them achieve it.
The Sector's Response: This Is Not Isolated
When CAQA's Director, Sukh Sandhu, published a public account of this situation, the response from the VET sector was immediate and unequivocal. The volume and nature of the responses confirmed that this is not an isolated incident affecting a single IP holder. It is a systemic problem that has been operating across the sector for some time.
A resource development company confirmed experiencing the same pattern: consultants purchasing their resources and passing them off as their own work product, and RTOs sharing licensed tools across their networks without payment or permission. That company stated it had changed the services it offers in response to these behaviours.
A VET compliance consultant disclosed that she had supported an applicant who had been previously deceived by a consultant in exactly the same manner described above. In that case, the applicant did not even know their registration application had been submitted. The consultant called for public identification of the individuals responsible so the sector could protect itself.
An education strategist and board member confirmed she had been working with two separate new registration applications that were caught up in the same fraudulent pattern, and noted that the consultant involved is well known and has been operating in the industry for a considerable period.
A director and general manager in the VET compliance space stated publicly that the identity of the person responsible is now known within the sector. Another resource developer confirmed they had also been contacted by ASQA in relation to the same matter.
A managing director of a VET consultancy called for a licensing or standards framework for VET consultants, expressing frustration that no regulatory threshold currently exists for individuals who prepare and submit RTO registration applications on behalf of others.
A data intelligence platform founder noted that this type of conduct is precisely why signal-layer analytics and digital fingerprinting technologies are being developed for the VET sector, to detect patterns that human review alone cannot identify across the volume of provider data held by regulators.
An industry engagement specialist raised the additional dimension of non-accredited course providers whose free online content is being used by RTO trainers without referral, attribution, or payment, constituting a further layer of IP breach that ASQA has the power to enforce.
Why This Matters for the Entire VET System
The VET sector's credibility depends on the integrity of its registration process. When fraudulent applications are submitted, the damage radiates outward. Genuine applicants who invest properly in resources, develop their own documentation, and engage honestly with the regulator are disadvantaged by competitors who cut every corner. Students who enrol with an RTO that was registered on the basis of fabricated evidence receive training from an organisation that may lack the operational substance to deliver quality outcomes. Resource developers who invest years and significant capital in creating compliant, high-quality learning and assessment materials see their work stolen and resold by individuals who contributed nothing to its creation.
The regulatory burden also increases for everyone. When ASQA identifies a systematic pattern of fraud, the natural and appropriate response is to tighten verification processes across all applications. The regulator is now cross-referencing submissions, contacting original IP holders directly, and verifying the authenticity of every agreement and invoice. While CAQA welcomes and supports this approach, the reality is that honest applicants and legitimate consultants bear the cost of additional scrutiny that was made necessary by the actions of a few.
The Case for Consultant Standards
There is currently no licensing requirement, no regulatory threshold, and no enforceable standard of practice for individuals who offer consultancy services to RTOs or RTO applicants in Australia. Anyone can present themselves as a VET consultant. Anyone can charge fees to prepare a registration application. And as this case demonstrates, anyone can forge documents, steal intellectual property, and coach applicants through interviews without facing any professional consequence beyond the eventual rejection of the applications they assembled.
The absence of consultant regulation is a gap that the sector has discussed for years without resolution. The introduction of the Standards for RTOs 2025 raised the bar for registered providers. ASQA's enhanced verification processes are strengthening the scrutiny applied to applications. But neither of these measures directly addresses the conduct of the individuals who sit between the applicant and the regulator, preparing submissions, sourcing resources, and, in some cases, fabricating the entire evidentiary base.
Until a framework exists that holds VET consultants to a defined standard of conduct, with enforceable consequences for fraud, the sector will continue to be vulnerable to the type of criminal operation described in this article. The legitimate consultants who do the right thing every day deserve better than being grouped with individuals who operate as described here. The applicants who pay for professional assistance deserve a guarantee that the person they are trusting is not building their submission from stolen materials and forged documents.
Three Questions Every RTO and Applicant Must Ask
For any registered training organisation or prospective applicant currently working with a consultant, three questions should be asked immediately and answered with documentary evidence.
First: where did these resources come from? Every training and assessment resource, every student handbook, every policy and procedure document should have a clear and traceable origin. If the consultant cannot identify the original developer or publisher, that is a warning sign.
Second: Is there a genuine, signed, and dated licence agreement with the actual copyright holder? Not a document created by the consultant. Not a template with a generic company name inserted. A real agreement, executed by both parties, with the original IP owner's details clearly stated.
Third: Can you produce a legitimate invoice showing payment to the original author or publisher? If the invoice was issued by the consultant's own entity for resources developed by someone else, that is not evidence of legitimate access. That is evidence of a problem.
If these three questions cannot be answered with confidence and supporting documentation, the materials should not be used in any application or audit. The risk is not hypothetical. ASQA is actively verifying this information, and the consequences of presenting fabricated evidence are severe.
CAQA's Position
CAQA Resources has invested years of expertise in developing training and assessment materials that support quality outcomes for RTOs and their students. CAQA will not stand by while unethical operators profit from that work without permission, and CAQA will not tolerate fabricated agreements being used to misrepresent access to its intellectual property.
CAQA has cooperated fully with ASQA throughout this process and will continue to do so. CAQA will continue to protect its intellectual property through every available legal mechanism. CAQA will continue to support the regulator in identifying and verifying the authenticity of materials presented in applications and audits.
For any RTO or applicant who has purchased resources through a consultant and is uncertain whether what they received is legitimately licensed, the advice is straightforward: contact the IP owner directly. Do not rely on what a consultant has represented. Verify it independently. It could save the application, the investment, and the reputation of the organisation.
The VET sector deserves better than this. Students who enrol in good faith deserve better than this. And the professionals across the industry who build, develop, and maintain quality every day deserve a system that holds fraudulent operators to account.
