Reasonable Adjustments Demystified: What They Are, How to Implement Them, and Where the Boundaries Lie

Few obligations in vocational education and training generate as much confusion as reasonable adjustment, treated by some RTOs as a loophole that threatens qualification integrity and by others as a blank cheque that must accommodate any request. Neither reading is correct, and both create risk. The DEWR Supporting Students with Disability in VET toolkit now offers the sector's most practical guidance on the topic, and what it means for RTOs, trainers, assessors, students and the industries that rely on a qualification as a guarantee of competence is the subject of this article.

Neither Loophole Nor Blank Cheque

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 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.

1. What Reasonable Adjustments Are: Changing the Pathway, Not the Destination

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 disability. 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 across different courses, the DEWR guidance makes clear that there is no single formula for determining reasonableness. Each person's experience of their disability is unique, varies throughout their life and across different contexts, and so 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.

2. 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 disability, 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, and the adjustment changes only 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 or 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.

3. The Three Illustrations: How Adjustment Decisions Are Made in Practice

The DEWR practice illustrations show how the needs-based approach works in real VET settings, and how an RTO reasons its way from an apparent barrier to a defensible adjustment. The following table summarises the three scenarios before each is examined in turn.

3.1 Oral Communication

In the first illustration, a student with autism who is non-verbal emails to ask about the core oral communication requirements in their course and to explore possible adjustments. The unit requires the student to interact and communicate with a diverse range of customers, greet them politely, communicate clearly using appropriate verbal and non-verbal communication, and adapt their style for customers from diverse backgrounds. The foundation skills explicitly map to oral communication. Staff initially have concerns about whether adjustment is possible when the unit so clearly specifies verbal communication.

The better-practice response is consultative. Staff consult the student and their associate, explore the unit requirements with the compliance officer, and contact industry partners to check whether 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, the assessor and the 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 standard, since oral communication can be achieved using assistive technology; it is reasonable to expect in a workplace; it does not create unjustifiable hardship; and it does not harm others. Even when a unit appears to require a specific mode of communication, consultative problem-solving can identify adjustments that preserve the competency while removing the barrier.

3.2 Reading and Writing

In the second illustration, a learner enrolled in an Individual Support (Home and Community) qualification discloses severe dyslexia and writing difficulties after enrolment. The trainer and assessor make time to meet with the student, and in preparation they consult the RTO compliance officer to explore the unit requirements, review the training and assessment strategy, and identify potential barriers and strategies.

The response is collaborative and evidence-informed. 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 format or support. Strategies might include text-to-speech and voice-recognition technologies, large print or accessible digital formats, additional time, a computer with spelling and grammar tools, oral assessment where the unit allows, plain-language step-by-step instructions, 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 aged care, 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, which is reasonable, and having someone else write it for them, which is not.

3.3 Workplace and Practical Supports

In the third illustration, a trade student with a physical disability who uses a wheelchair 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 workshop. He identifies that he will need adjustments to access equipment and tools and to have enough space to move around the workshop. Staff initially express concerns about work health and safety and whether the student can safely perform all required tasks.

The better-practice response is to engage 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 for 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, the employer's workplace knowledge and the RTO's training requirements together form the basis for a co-designed adjustment plan. The boundary for practical supports is drawn where a qualification outcome is directly tied to an occupational task 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. That determination must be made through careful analysis, not through blanket assumptions about disability.

4. 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 its 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 unit HLTAID011 Provide First Aid, the performance evidence requires the candidate to perform at least two minutes of uninterrupted single rescuer cardiopulmonary resuscitation, across five cycles of compressions and ventilations, 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, 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 where 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 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.

5. 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. First, invite and support disclosure by providing clear information about rights and supports through course information, enrolment and orientation, and by normalising discussions about adjustments so that students feel safe to raise their needs. Second, gather relevant information by asking about functional impacts and support needs rather than solely requesting diagnoses, while seeking supporting documentation where it is necessary to design appropriate adjustments.

Third, consult and co-design by 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 where needed. Fourth, assess reasonableness by checking each proposed adjustment against the course and unit requirements, the occupational outcomes and inherent requirements, the impact on others and on safety, and the availability of less intrusive alternatives that could achieve a similar benefit.

Fifth, decide, document and implement. Agreed adjustments should be recorded in the student support or learning plan, including the rationale, who is responsible for implementation, where the adjustments apply across training, assessment and placement, and scheduled review points. The DEWR toolkit includes dedicated templates for this purpose, including a template for exploring inherent requirements and reasonable adjustments at the unit level, and a template for documenting reasonable adjustments on individual assessments. Sixth, 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 an adjustment if circumstances change or if it is no longer reasonable.

6. 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.

Conclusion: A Structured Dialogue, Not a Favour

Reasonable adjustment is not a favour granted to students with disability. It is not a loophole that undermines qualifications. And it is not an open-ended obligation 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 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 everything they need to approach this dialogue with confidence: a clear conceptual framework, detailed practice illustrations showing how adjustment decisions are made in real scenarios, templates for documenting every step, and a principled approach to identifying where the boundaries lie. The sector's experience is consistent on one point: the RTOs that handle reasonable adjustments well are those that treat the process as a professional responsibility rather than a bureaucratic burden. The resources are freely available. The framework is clear. The boundaries are knowable. What remains is the decision to use them.

References and Further Reading

Department of Employment and Workplace Relations (2025). Supporting Students with Disability in VET: Practice Guide on Reasonable Adjustments, with practice illustrations and templates. https://www.dewr.gov.au

Australian Skills Quality Authority (2025). Practice Guide: Training Support (Outcome Standard 2.4). https://www.asqa.gov.au

Federal Register of Legislation (2025). National Vocational Education and Training Regulator (Outcome Standards for NVR Registered Training Organisations) Instrument 2025. https://www.legislation.gov.au

Federal Register of Legislation. Disability Discrimination Act 1992. https://www.legislation.gov.au

Federal Register of Legislation. Disability Standards for Education 2005. https://www.legislation.gov.au

Department of Employment and Workplace Relations. National Register of VET (training.gov.au): HLTAID011 Provide First Aid. https://training.gov.au