Enrolling and supporting students under 18 in Australia’s VET sector is both a privilege and a significant legal responsibility. These learners deserve training that is engaging, practical, and career-aligned, but they also require age-appropriate safeguards, clear consent processes, active well-being monitoring, and strong family communication. The expectations are not optional. They are based on national child safety principles, state and territory child-safe standards, and the Standards for Registered Training Organisations, with additional welfare duties for CRICOS providers that enrol younger overseas students. The result is a comprehensive compliance landscape that encompasses enrolment, orientation, delivery, assessment, practical placement, complaints handling, and record-keeping. Done well, it creates safe, inclusive pathways into work and further study. Done poorly, it exposes students to avoidable risk and organisations to serious regulatory consequences.
The compliance foundation: child-safe culture first
All organisations that work with children and young people are expected to implement the National Principles for Child Safe Organisations. These principles establish a national benchmark for leadership, culture, participation, physical and online safety, staff screening, complaint processes, and continuous improvement. They are reflected in state and territory child safe standards and are now a visible expectation in RTO regulation and guidance. For example, ASQA’s updated materials require providers who deliver to under-18s to demonstrate how the National Principles are embedded in their daily practice and risk management. In short, a child-safe culture is not an add-on. It is the baseline against which your systems, training and placements will be judged.
Victoria provides a clear example of local implementation. The Commission for Children and Young People administers eleven Child Safe Standards, providing practical self-assessment tools, compliance indicators, and templates. These standards align with the national principles and set tangible expectations for policies, codes of conduct, risk assessments, training and reporting. RTOs operating in Victoria must understand and apply these standards in conjunction with the National Principles, while providers in other jurisdictions should refer to their respective schemes.
Enrolment essentials for students under 18
Informed consent and identity
Every RTO must obtain the consent of a parent or legal guardian for a minor’s enrolment and maintain clear records of that consent. Identification sufficient to create or verify a Unique Student Identifier is also required. The USI is mandatory for nationally recognised training, and there is no minimum age to create one, but verifiable ID is essential, and details must match exactly to avoid transcript issues. Many RTOs use a consent form where the parent or guardian authorises the provider to create a USI on the student’s behalf.
In Victoria, most learners will already have a Victorian Student Number, a unique identifier assigned when the student first appears in the Victorian education system. RTOs delivering in Victoria must be able to capture and report VSN details to the Victorian Student Register in line with data reporting rules. Your student management system should support VSN workflows to ensure accurate and up-to-date reporting.
Minimum age, school leaving rules and early school leavers
Minimum ages vary based on program type. School-delivered VET and school-based apprenticeships have different age profiles from adult programs. A critical issue is compulsory schooling. In Victoria, school is compulsory from 6 until 17, with specific processes for exemptions from attendance and enrolment. If you are enrolling a student under 17 directly into Skills First training, you must follow the Department’s fact sheet and ensure the relevant exemption and notification requirements are satisfied. New South Wales has similar participation requirements after Year 10 until age 17, with approved alternatives such as VET, full-time work or a combination. RTOs should map their processes to the local jurisdiction of delivery and document how they handle under-17 enrolments, evidence of exemptions and liaison with schools.
Child safety and welfare in practice
Screening, supervision and staff capability
A child-safe RTO ensures that people who work with under-18s are suitable and trained. In Victoria, the Working with Children Check scheme is established under the Worker Screening Act 2020. Many staff who interact with minors will require a Check unless an exemption applies, and organisations must still assess suitability, supervise appropriately, and train staff in their child safety obligations. Teachers registered with VIT have specific arrangements, but they must notify WWCC Victoria if they engage in other child-related work outside their school role. RTO leaders should document the screening category each role falls into, verify currency and ensure role descriptions reflect supervision duties for training rooms, workshops and online spaces.
Training is equally important. State regulators provide practical resources for policy writing, codes of conduct, risk assessment, online safety and cultural safety. Build these into induction and refresher training, including for contractors and third-party providers. Make it explicit how staff raise and manage child-safety concerns, and how students and families can make a complaint.
Risk management for learning and assessment
Risk controls must reflect the real hazards under-18 learners face in workshops, simulated environments and placements. Review equipment access rules, supervision ratios, emergency procedures and first-aid coverage with a specific focus on minors. ASQA’s risk practice guides ask directly how RTOs embed the National Principles when delivering to students under 18, which means you should be able to point to your risk register, documented controls and evidence of review. In Western Australia, public guidance explicitly highlights risks to the safety and well-being of VET students under 18 and links these risks to child-safe organisational principles. The message is the same nationally. Know your risks, implement controls and review them regularly.
Practical placements and licensing limits
Some industries place age-based limits on duties or licensing that affect under-18 learners. Before approving a placement, the RTO should confirm supervision, task suitability, equipment access, hours and travel arrangements, and obtain guardian consent where required. Document the induction and who is responsible for the day-to-day welfare checks. Where a student cannot legally perform a task, design alternative assessment strategies to demonstrate competence without breaching safety or licensing rules. Align your placement agreement template with the National Principles and your state’s child-safe framework so expectations are clear for hosts, students, and families.
CRICOS: additional duties for younger overseas students
If you enrol international students under 18, the National Code of Practice for Providers of Education and Training to Overseas Students imposes additional obligations. Standard 5 requires suitable welfare and accommodation arrangements, ongoing monitoring and clear records. Providers may accept responsibility for welfare by issuing a CAAW letter, or they may only enrol a student if another approved arrangement is in place. These settings must be monitored until the student turns 18, regardless of academic progress. Your internal procedures should define who checks homestays or other arrangements, how issues are escalated and how communication with parents or legal custodians overseas is maintained.
Building the right supports for under-18 learners
Orientation, well-being and case management
Under-18s benefit from tailored orientation that explains safety, support services, placement rules, digital conduct and complaint avenues in plain language. Schedule early check-ins and regular well-being touchpoints, and identify students who may need case management due to distance from home, caring responsibilities, disability, financial stress or cultural barriers. A simple escalation pathway helps staff act early when attendance, engagement or behaviour flags a risk, and a documented referral map makes it easy to connect students to external services when needed. These practices align directly with national and state child-safe expectations for participation, empowerment and accessible complaints processes.
Family engagement and consent
Parents and guardians must receive timely information about the course, delivery mode, placement expectations, supervision, travel and costs. Set a communication rhythm that respects family preferences, explain what you can share under privacy law and where consent is required for changes such as course transfers, placement shifts or approved leave. For minors, consent management is not a formality. It is a safety control. Publish straightforward guides for families and maintain a single point of contact who can coordinate responses quickly if issues arise. The CRICOS framework reinforces these duties for younger overseas students, but the same good practice applies to domestic learners.
Online safety and respectful conduct
Many under-18s undertake blended or online training. Your LMS and collaboration tools need clear usage rules, moderated spaces, content filters where appropriate and reporting pathways for cyberbullying or grooming concerns. Staff should be trained to maintain professional boundaries in digital channels and to escalate concerns immediately. State child-safe regulators provide practical online safety guidance that can be adapted for RTO settings.
Process detail that prevents problems
Clear, multi-step enrolment workflow
Document a specific workflow for minors that covers guardian consent, identity verification and USI creation or verification, capture of VSN in Victoria, schooling status check and, where applicable, evidence of exemption for under-17 direct enrolments. Automate reminders in your student management system so expiring documents and missing approvals are chased before training commences. This reduces audit risk and avoids interruptions for the learner.
Placement readiness and host briefing
Before any placement, complete a minor-specific risk assessment that confirms supervision, tasks, PPE, insurance and incident reporting expectations. Provide hosts with a short briefing sheet about their duty of care to minors and how to contact the RTO if concerns or incidents arise. Reconfirm guardian consent if placement details change, then record all approvals centrally. These steps satisfy the spirit of the National Principles and state standards and make audits far simpler.
Reporting concerns and mandatory obligations
Staff must know their mandatory reporting obligations and how these interact with your internal child safety policy. Give simple, scenario-based guidance that explains when to contact police or a child protection authority, how to make a record, and who informs the family. Provide the same clarity for students and parents about how to raise a concern and what they can expect next. State child-safe regulators set out complaint and reporting expectations and provide templates you can draw on.
Governance and assurance that actually works
Embed child safety in risk and quality systems.
ASQA’s current approach expects providers to show a mature understanding of risk, including the risks specific to delivering to minors. Build child-safety controls into your quality cycle and internal audit program. Test screening records, training completion, supervision plans, placement agreements, and incident logs each term. Where you use third parties, verify their screening and training too. Treat findings as opportunities for improvement, not faults to hide. This mindset aligns with regulator expectations under the revised Standards for RTOs.
Train managers and boards
Leaders should be able to explain how the National Principles and local child-safe standards are applied in the RTO’s context, how the organisation measures effectiveness and what has improved in the last year. Provide board or governing body briefings on trends, incidents and audit outcomes. Keep a child-safety action plan with timeframes and responsible owners and track it like any other business-critical program.
Special settings and edge cases
VET Delivered to School Students and School-based Pathways
Where delivery occurs through a school partnership, clearly allocate roles for attendance monitoring, behaviour management, placement coordination and incident reporting. School leaving and participation obligations still apply, and the Department’s VET-in-schools policy settings guide collaboration across clusters and regions. Joint planning with schools reduces duplication and ensures families receive consistent information.
Cross-border and multi-jurisdiction delivery
If your RTO delivers across multiple states or territories, you must map the child-safe standards, WWCC or equivalent screening schemes and reporting pathways for each jurisdiction. The ACT, for example, has implemented its Child Safe Standards scheme through the Human Rights Commission Act, mirroring the National Principles while setting local compliance requirements. Maintain jurisdiction-specific quick reference guides for staff.
International students who turn 18 mid-course
When a CRICOS student turns 18, review their welfare settings, confirm any changes with the student and family, and update your records. If you issued a CAAW, ensure the transition is orderly and that any residual risks are considered in supervision or accommodation arrangements. Keep communication respectful and clear so the student understands their rights and responsibilities as an adult learner.
Practical checklist to lift your practice this term
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Update your child-safety policy so it explicitly references the National Principles and your state’s standards, and attach role-specific responsibilities and reporting steps.
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Audit your screening register against the Worker Screening or WWCC laws in your jurisdiction. Close any gaps and add expiry alerts.
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Build a minor-specific enrolment workflow that captures guardian consent, USI and, in Victoria, VSN details, and checks school participation or exemption.
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Reissue placement agreements with a one-page host briefing about duties to minors, supervision, tasks and incident reporting.
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For CRICOS providers, review Standard five procedures, including CAAW processes, monitoring and communication templates for families.
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Schedule staff refresher training on child safety, online conduct and complaint handling using regulator resources and templates.
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Add child-safety controls to your internal audit program and table a quarterly report to governance.
Conclusion: Safe, supported and ready to thrive
Under-18 learners can flourish in VET when providers build systems that combine rigorous compliance with genuine care. The pathway is clear. Anchor your culture in the National Principles and local child-safe standards. Get consent and identity right from the start. Understand school leaving requirements and exemptions. Train and screen your people. Plan placements with a minor’s safety at the forefront. Communicate consistently with families. Meet CRICOS welfare duties where relevant. Audit your own practice and keep improving. This is how we honour the trust families place in us and how we deliver on our promise to prepare the next generation for meaningful work and lifelong learning in a safe, respectful environment.
Reference to key frameworks and guidance
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National Principles for Child Safe Organisations, Australian Human Rights Commission and Commonwealth resources.
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ASQA guidance and practice questions linking child-safe expectations to RTO risk and quality systems.
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USI creation and evidence requirements for all nationally recognised training.
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Victorian Student Number obligations for delivery in Victoria.
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School participation and exemption requirements for under-17 enrolments in Victoria and NSW.
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CRICOS National Code Standard 5 welfare requirements for younger overseas students.
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Victorian Working with Children Check framework and related guidance for staff suitability.
Note: Child safety and schooling rules are jurisdiction-specific. Always check the latest requirements for the state or territory where delivery occurs and align your RTO policies and procedures accordingly.
