Few concepts in vocational education and training (VET) generate as much confusion, anxiety, and inconsistent practice as reasonable adjustment. Some registered training organisations (RTOs) treat it as a loophole that threatens the integrity of qualifications. Others treat it as a blank cheque that requires them to do whatever a student requests, regardless of cost or consequence. Neither interpretation is correct, and both lead to outcomes that fail students and expose RTOs to regulatory and legal risk.
The Department of Employment and Workplace Relations (DEWR) guidance materials, released through the Supporting Students with Disability in VET project, include a dedicated practice guide on reasonable adjustments, supported by three detailed practice illustrations covering oral communication, reading and writing, and workplace supports. Together with the templates for exploring inherent requirements and documenting adjustment decisions, these resources provide the most comprehensive and practical guidance the sector has received on this topic.
This article explains what reasonable adjustments are, how they should be implemented, where the boundaries lie, and why getting this right is essential for both equity and qualification integrity.
What Are Reasonable Adjustments?
Under the Disability Discrimination Act 1992 (DDA) and the Disability Standards for Education 2005 (DSE), reasonable adjustments are measures or actions taken to help a student with disability participate in education and training on the same basis as students without disabilities. The DEWR practice guide positions adjustments as part of a broader inclusive approach that spans course information, enrolment, teaching, assessment, and support services, not merely as assessment tweaks applied at the point of submission.
The defining principle is straightforward: adjustments change the pathway, not the destination. They modify how a student accesses training and demonstrates competence while preserving what the qualification requires. An adjustment is reasonable if it balances the interests of all parties affected, including the student, the RTO, staff, and other students. The factors that inform this balance include the student's learning needs, the impact of the adjustment on the student's participation and independence, the impact on others, including safety considerations, and the cost and benefits of making the adjustment.
Given the highly individualised nature of disability and the vast range of competencies required across different courses, the DEWR guidance makes clear that there is no single formula or set of rules for determining reasonableness. Each person's experience and impact of their disability is unique, varies throughout their life and in different contexts, and therefore, reasonable adjustments should always be negotiated with the student, consider the individual student's needs and capabilities, and maintain the integrity of the course or unit of competency.
Scope and Core Principles
ASQA's Training Support practice guide, aligned with Outcome Standard 2.4 under the Standards for RTOs 2025, expects RTOs to provide support to VET students with disabilities, including reasonable adjustments to allow access and participation in training and assessment, while maintaining training product integrity. This expectation is not limited to formal assessment events. Reasonable adjustments can encompass changes to premises, equipment, delivery methods, teaching tools, tasks, methodologies, and the assessment environment.
Three core principles should guide every adjustment decision. First, adjust access and method, not the competency standard. The student must still demonstrate the skills, knowledge, and capabilities required by the unit of competency; the adjustment changes the conditions under which they do so. Second, individualise. Adjustments are made for each student after consultation, not by applying generic labels or blanket policies. Third, document and review. Every adjustment should be recorded in the Student Support/Learning Plan, including the rationale, the agreed implementation approach, and scheduled review points. Adjustments are not set-and-forget decisions; they must be monitored and refined as the student progresses and as circumstances change.
In Practice: Oral Communication Adjustments
The DEWR practice illustration on oral communication presents a scenario that many RTOs will recognise. A student with autism who is non-verbal emails to ask about the core oral communication requirements in their course and to explore possible reasonable adjustments. The first unit requires the student to interact and communicate with a diverse range of customers, greet customers in a polite and friendly manner, clearly communicate using appropriate verbal and non-verbal communication, and adapt communication style for customers from diverse backgrounds. The foundation skills explicitly map oral communication.
RTO staff initially have concerns about whether reasonable adjustments are possible when the unit so clearly specifies verbal and non-verbal communication. The practice illustration shows the better practice response: staff consult with the student and their associate, explore the unit requirements with the compliance officer, and contact industry partners to check whether the use of assistive technology is acceptable in the workplace. Industry representatives confirm that chat-based and online communication features are becoming increasingly common in some settings. The student, their associate, the trainer, assessor, and quality manager agree that the student will use text-to-speech assistive technology to complete the assessment task.
The agreement is documented and considered reasonable because it was discussed with and agreed to by the learner, it benefits the learner, it maintains the competency standards (oral communication can be achieved using assistive technology), it is reasonable to expect in a workplace, it does not create an unjustifiable hardship, and it does not impact upon or harm others. This illustration demonstrates that even when a unit appears to require a specific mode of communication, creative and consultative problem-solving can identify adjustments that preserve the competency while removing the barrier.
In Practice: Reading and Writing Adjustments
The DEWR practice illustration on reading and writing presents a learner enrolled in an Individual Support (Home and Community) qualification who discloses severe dyslexia and writing difficulties after enrolment. The trainer and assessor make time to meet with the student, and in preparation, they consult with the RTO compliance officer to explore the unit requirements, review the training and assessment strategy, and identify potential barriers and strategies.
The better practice response involves a collaborative, evidence-informed process. The trainer and assessor identify the reading and writing demands of each unit, determine which aspects are inherent requirements (such as completing workplace documentation in aged care or community services) and which can be adjusted in terms of format or support. Strategies might include text-to-speech and voice-recognition assistive technologies, large print or accessible digital formats, additional time for reading and writing tasks, use of a computer with spelling and grammar tools, oral assessments where the unit allows, step-by-step instructions in plain language, and checking understanding through paraphrasing when reading loads are high.
The critical boundary is this: if a unit inherently requires independent reading and writing to a workplace standard, for example, preparing care plans, incident reports, or client documentation in the aged care sector, an adjustment that removes the need to read or write altogether would not be reasonable because it would change the competency itself. The adjustment should support the student's ability to perform the required task, not eliminate the task. The distinction is between providing tools and support that enable the student to write a care plan (reasonable) and having someone else write it for them (not reasonable).
In Practice: Workplace and Practical Supports
The DEWR practice illustration on workplace supports presents a trade student with a physical disability who uses a wheelchair and has enrolled in a Light Vehicle Mechanical Technology course. The student is under a contract of training with a supportive employer, comes from a family with a background in motor mechanics, and has developed many strategies for managing in a mechanical workshop. He identifies that he will need reasonable adjustments to ensure he can access equipment and tools and have enough space to move around the workshop.
RTO staff initially express concerns about work health and safety and whether the student can safely perform all required tasks. The better practice response involves the RTO engaging directly with the student, the employer, and relevant work health and safety expertise to conduct a thorough assessment rather than making assumptions. Adjustments might include modifying the workshop layout to ensure wheelchair accessibility, providing adapted tools or equipment, adjusting the sequencing of practical tasks, and ensuring that work health and safety plans specifically address the student's needs. The key principle is that the student is not excluded on the basis of assumptions about what a wheelchair user can or cannot do. The student's own expertise about their capabilities, combined with the employer's workplace knowledge and the RTO's training requirements, forms the basis for a co-designed adjustment plan.
The boundary for workplace and practical supports is drawn where a qualification outcome is directly tied to a specific occupational outcome involving tasks that cannot be adjusted in the real workplace. If an essential task cannot reasonably be adjusted on the job, adjusting it in the training assessment may misrepresent the student's competence. However, this determination must be made through careful analysis, not through blanket assumptions about disability.
Inherent Requirements: Where the Boundaries Lie
The concept of inherent requirements is central to understanding the limits of reasonable adjustment. The DEWR practice guide explains that a reasonable adjustment must not compromise the integrity or core inherent requirements of the unit of competency and the associated assessment requirements. Inherent requirements are the essential elements of a unit that cannot be removed or fundamentally altered without changing what the qualification certifies a person can do.
The DEWR guidance provides a clear example. In the competency HLTAID011 Provide First Aid, the performance evidence states that the candidate must perform at least two minutes of uninterrupted single rescuer cardiopulmonary resuscitation on an adult resuscitation manikin placed on the floor. This is an inherent requirement: it is a physical task that must be demonstrated as specified because it reflects a real-world safety-critical competency. The guidance notes that it is critical to inform students of such requirements before enrolment, so they can make an informed decision. When determining inherent requirements, RTOs should consider all aspects of the unit of competency, including its intent, performance requirements, and assessment conditions, as well as any advice in Companion Volume Implementation Guides.
To be clear about what does not constitute a reasonable adjustment: changing or reducing the performance criteria or evidence requirements of a unit, guaranteeing a pass or creating a different qualification outcome for a student with disability, removing essential safety-critical competencies when these cannot realistically be adjusted in the workplace, and providing a level of support that undermines the student's own demonstration of competence, such as allowing a support person to actually perform the task being assessed rather than enabling the student to do so. These are not adjustments. They are compromises of qualification integrity, and they serve neither the student nor the industry that relies on the qualification as a guarantee of competence.
Implementing Reasonable Adjustments: A Six-Step Process
Drawing on the DEWR practice guide and the broader toolkit, RTOs can follow a structured six-step process for implementing reasonable adjustments. The first step is to invite and support disclosure by providing clear information about rights and supports through course information, enrolment, and orientation, and normalising discussions about adjustments so that students feel safe to raise their needs. The second step is to gather relevant information by asking about functional impacts and support needs rather than solely requesting diagnoses, while seeking supporting documentation where necessary to design appropriate adjustments.
The third step is to consult and co-design. This means discussing options with the student and, where relevant, their associate, exploring the benefits and potential impacts of different approaches, and consulting specialist services or external agencies such as industry partners if needed. The fourth step is to assess reasonableness by checking each proposed adjustment against the course and unit requirements, occupational outcomes and inherent requirements, impact on others and on safety, and the availability of less intrusive alternatives that could achieve a similar benefit.
The fifth step is to decide, document, and implement. Agreed adjustments should be recorded in the Student Support/Learning Plan, including the rationale, who is responsible for implementation, where the adjustments apply (training, assessment, placement), and scheduled review points. The DEWR toolkit includes dedicated templates for this purpose, including Template 4 for exploring inherent requirements and reasonable adjustments at the unit level, and Template 8 for documenting reasonable adjustments on individual assessments. The sixth step is to monitor and review. RTOs should regularly check whether adjustments are effective for the student and sustainable for the organisation, and should be prepared to change or withdraw adjustments if circumstances change or if they are no longer reasonable.
The Broader Picture: Adjustments Within an Inclusive System
Reasonable adjustments are essential, but they are most effective when they operate within a broader system of inclusive design. The DEWR materials consistently position adjustments as part of a continuum. At one end is Universal Design for Learning, which removes barriers for the broadest possible range of students before any individual adjustment is needed. In the middle are targeted supports, such as additional tutoring, language and literacy assistance, or mentoring. At the other end are individualised reasonable adjustments negotiated for specific students with specific needs. An RTO that invests in inclusive curriculum design and accessible resources will find that its students need fewer individual adjustments, and that the adjustments it does make are more targeted, more manageable, and more sustainable.
Reasonable adjustment is not a favour granted to students with disabilities. It is not a loophole that undermines qualifications. And it is not an open-ended obligation that requires RTOs to do anything a student requests, regardless of cost or consequence. It is a structured, evidence-based dialogue between the student and the RTO, anchored in the Disability Standards for Education 2005, the Standards for RTOs 2025, and practical VET guidance, that seeks to find the most effective way for a student to demonstrate competence while preserving the integrity of what that competence means.
The DEWR guidance materials provide RTOs with a comprehensive toolkit to approach this dialogue with confidence. This includes a clear conceptual framework, detailed practice illustrations for real-world adjustment decisions, documentation templates, and a principled approach to identifying boundaries. Experience in VET compliance and quality assurance shows that RTOs handling reasonable adjustments effectively are those treating the process as a professional responsibility, not a bureaucratic burden. These resources are freely available, and the framework is clear. The only question is whether your RTO is ready to use them.
