Recognition of Prior Learning Under the Standards for Registered Training Organisations 2025: Why Clear Guidance for RTOs Is Now Critical

After attending yesterday's webinar, I’m feeling more confused than ever about the information provided versus what the legislation actually requires. The inconsistencies between ASQA's spoken guidance and the legislative standards are creating unnecessary uncertainty for RTOs. This lack of clarity isn’t just frustrating; it’s harmful for the sector and risks compliance issues for providers. Clear, consistent guidance is urgently needed to ensure everyone is on the same page.

Recognition of Prior Learning (RPL) has always been one of the most misunderstood, inconsistently applied, and heavily scrutinised components of the Australian Vocational Education and Training (VET) system. At the same time, it remains one of the most critical mechanisms for supporting workforce mobility, enabling lifelong learning, and ensuring that the VET system can genuinely recognise the diverse ways Australians gain skills.

To know more about RPL, click on these links:

Credit Pathways in VET and Higher Education Research Project https://www.education.gov.au/download/4388/credit-pathways-vet-and-higher-education/6542/document/pdf Broader credit‑transfer and pathways work (e.g. the “Credit Pathways in VET and Higher Education” report) that positions RPL as one of several mechanisms for recognising prior learning and supporting mobility between VET and higher education.

ASQA's risk priorities - Recognition of prior learning https://www.asqa.gov.au/how-we-regulate/risk-priorities/recognition-prior-learning

NCVER report “Exploring the recognition of prior learning in Australian VET” (Osborne & Serich, 2020), which analyses how RPL is actually used, the costs and practical challenges for providers, and the tension between policy ideals and implementation. https://www.voced.edu.au/content/ngv:86941

The Qualification Reform Design Group Initial Advice to Skills Ministers (containing 2018 RPL data) https://www.dewr.gov.au/download/16154/qualification-reform-design-group-initial-advice-skills-ministers/36487/qualification-reform-design-group-initial-advice-skills-ministers/pdf

Yesterday, the Australian Skills Quality Authority (ASQA) flagged a rising risk profile for the Recognition of Prior Learning (RPL), highlighting that poor-quality RPL practices continue to pose a systemic issue. You can read more about it here https://www.linkedin.com/posts/sukhsandhu_asqa-education-2025standards-activity-7400007027751825408-pAMy?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAKdwL0BTVkvHUJEwBGgyHW8TEHUgtX-69A

Image credit: ASQA

According to ASQA representatives, RPL is not being done well across a segment of the sector, with risks emerging in:

• How RPL is offered

• How RPL decisions are made

• The quality and sufficiency of evidence

• Assessment judgments that fail to maintain the integrity of training products

• RTOs' misunderstanding or oversimplifying their obligations

What makes the conversation even more interesting and controversial is that during the ASQA Webinar on the 2025 Standards for RTOs (held 28 November 2025), presenters appeared to suggest that under the new Standards, RTOs may “provide advice about what RPL is about” and that some providers might identify that they are “not suited” to delivering RPL. If that were the case, ASQA indicated that such providers might be “not required to undertake or enter into the RPL process with the student.”

This interpretation raised immediate alarm across the VET sector. Many RTO leaders, practitioners and compliance specialists have questioned:

• How does this align with the actual wording of the Standards?

• Does the legislation genuinely permit an RTO to avoid conducting RPL?

• How does this interact with the principle that all students must be able to access RPL?

• Does referring a student elsewhere constitute “offering an opportunity to seek RPL”?

• Is the regulator’s commentary consistent across its written guidance, spoken advice and webinars?

To answer these questions, this article provides a comprehensive, legislation-anchored analysis of the RPL requirements under the Standards for Registered Training Organisations (Outcome Standards) 2025, with a specific and detailed focus on Standard 1.6. It also examines the broader risk environment, draws out practical implications for RTOs, and highlights why the sector urgently needs clearer, more consistent guidance from ASQA.

Understanding RPL in the Australian VET Context

Why RPL Matters

RPL is a cornerstone of the VET system because it recognises that Australians gain skills not only through formal education but also through:

• Employment

• Volunteering

• Informal learning

• Life experience

• Community involvement

• Overseas qualifications

• Non-accredited training

RPL supports:

• Workforce mobility

• Career advancement

• Reduction of duplication in training

• Cost-effective upskilling

• Faster pathways into industry

• Greater fairness for experienced workers

The policy intent is clear: RPL must be accessible, fair, consistent and efficient, and it must maintain the integrity of national qualifications.

RPL is most commonly used in:

• Training package qualifications rather than accredited courses

• Sectors with mandatory qualifications for government-funded job roles

• Areas experiencing skills shortages and migration pathways

Historical Challenges With RPL

Despite its importance, RPL has remained problematic. Sector reviews, regulatory reports and ASQA audits over the last decade consistently highlight:

• Incomplete or insufficient evidence

• Overly onerous evidence requirements

• Poor assessor capability

• Inadequate assessment tools

• RPL processes are treated as “shortcuts”

• RPL is given to students who have not demonstrated competency

• Insufficient documentation to justify judgments

• Inconsistent interpretation of RPL rules across RTOs

Since late 2024, ASQA has taken unprecedented enforcement action:

• 15+ RTOs deregistered for fraudulent practices

• Over 29,000 qualifications and/or statements of attainment were cancelled

• More than 26,000 individuals are affected

• As of September 2025, 25,500+ fraudulently issued qualifications have been cancelled

ASQA’s RPL risk priority highlights the highest concern around the quality and sufficiency of evidence and the integrity of assessment judgments, with elevated risk also attached to how decisions are made and how well RTOs understand their RPL obligations.

The fraud particularly affected qualifications in aged care, disability support, childcare, construction, and security sectors serving vulnerable Australians. At one Sydney institute investigated, 94% of students in aged care and disability support qualifications received RPL for at least 50% of course requirements, with "skills interviews" lasting less than 15 minutes.

Providers are also under-reporting RPL in Total VET Activity (TVA) data to avoid regulatory scrutiny and attract higher VET funding levels.

In 2025, with 6.7 million Australians working from home (Roy Morgan research published in August 2025 confirms that over 6.7 million Australians (46% of employed Australians) work from home at least some of the time. This figure is based on interviews with approximately 41,449 employed Australians conducted between July 2024 and June 2025, and hybrid models are standard for 69% of employers (Source:Optibpo: Hybrid Work Trends Australia 2025). Online RPL has become increasingly relevant. The National Skills Commission Care Workforce Labour Market Study estimated the total required care and support workforce will reach approximately 721,800 workers by 2049–50 (up from 364,100 in 2019–20), with a projected workforce gap of 285,800 workers.

Victoria's Skills Plan identifies RPL as critical to meeting workforce demands in construction and care sectors.

Given these challenges, the 2025 Standards aim to strengthen RPL decision-making and the consistency of assessment judgements, aligning RPL processes with the broader assessment system in each RTO.

The Legislative Foundation: Standard 1.6 of the 2025 Outcome Standards

The core requirement for RPL under the 2025 Standards is found in Standard 1.6, which states:

Outcome Standard

(1) VET students with prior skills, knowledge and competencies are supported to seek recognition of prior learning to progress through the relevant training product. Legislation-SRTOs

Performance Indicators

(2) An NVR registered training organisation demonstrates: (a) VET students are offered opportunities to seek recognition of prior learning and are made aware of the organisation’s policies for seeking recognition of prior learning; (b) decisions relating to recognition of prior learning are based on evidence of prior skills, learning and experience, and are undertaken in accordance with the organisation’s assessment system; and (c) decisions relating to recognition of prior learning are documented and decided in a way that is fair, transparent, consistent amongst VET students, and maintains the integrity of the training product.

This is extremely strong language. It says:

• RPL must be supported, not merely explained.

• RPL must be offered.

• Students must be made aware of how to access it.

• RPL decisions must be based on evidence.

• These decisions must align with the RTO’s assessment system.

• RPL must be fair, transparent, consistent and protect integrity.

None of this language suggests that an RTO can “opt out” of delivering RPL because it is inconvenient, complex or resource-intensive.

3. The Regulatory Interpretation Conflict: What ASQA Said

During the ASQA webinar, representatives reportedly made the following statements (paraphrased by sector attendees):

• RTOs must “provide advice about what RPL is about.”

• Some providers “might find they are not suited to delivering RPL well.”

• Such providers may therefore be “not required to undertake or enter into the RPL process with the student”, provided they offer advice.

These statements were interpreted by some participants as suggesting:

“If you can’t do RPL well, you can avoid it.”

This interpretation is incompatible with the plain meaning of Standard 1.6.

Industry professionals have raised concerns that:

• ASQA’s spoken guidance differs from the written legislative instrument

• The regulator is inadvertently creating confusion

• RTO decisions based on incorrect guidance could lead to compliance risk

• Sector confidence requires clarity and consistency

• ASQA should publish a clarification to prevent misapplication of the Standard

The advice we previously received (written advice) from ASQA was that:

“All RTOs are required to OFFER RPL.”

That written advice is consistent with the legislative instrument now in force.

So the question becomes: Does Standard 1.6 legally allow an RTO to avoid providing RPL themselves?

Let’s examine this.

Can an RTO Legally Decline to Conduct RPL? A Legislative Interpretation

The Obligation to Offer RPL

The Standard requires RTOs to:

• “offer opportunities” for RPL

• ensure students are “supported to seek RPL”

• provide clear RPL policies

• make students aware of these policies

This creates an obligation for each RTO to:

• make RPL available

• support students to access RPL

• carry out RPL in accordance with assessment requirements

There is no clause that allows an RTO to simply:

• decline RPL altogether,

• refuse to consider a request for RPL, or

• outsource responsibility to another RTO.

Does “offering an opportunity elsewhere” meet the requirement?

Some have interpreted ASQA’s comment as implying:

“If you don’t offer RPL, you can just tell students where to go.”

However, Standard 1.6 does not say:

• “Students are offered advice about RPL.”

• “Students are offered the opportunity to seek RPL somewhere else.”

• “RTOs may decide not to provide RPL.”

The phrase is explicit:

“VET students are offered opportunities to seek recognition of prior learning”

and

“decisions relating to recognition of prior learning are... undertaken in accordance with the organisation’s assessment system.” Legislation-SRTOs

This means:

• The RTO must have its own RPL decision-making capacity.

• It must have its own RPL policies and procedures.

• It must have its own assessment system for RPL.

• It must be able to conduct RPL assessment judgements.

Directing a student to another RTO does not satisfy the legislative requirement for the organisation’s decision-making.

The Difference Between "Offering RPL" and "Having an RPL Kit for Every Qualification"

ASQA correctly stated that:

• RTOs do not need a fully developed RPL kit for every qualification on scope

• But RTOs must have policies and procedures so they can be “ready to go”

This interpretation aligns with the legislative instrument.

The Standards do not require:

• A pre-developed, fully resourced RPL toolkit for every qualification

They do require:

• The ability to develop or adapt tools as needed

• A compliant assessment system

• Trained assessors

• Evidence requirements that align with the training product

• Decision-making that protects integrity

So RTOs must be ready to conduct RPL, even if they do not have a kit for every qualification prepared in advance.

RPL Under the Assessment System Requirements

Standard 1.6 does not stand alone. It interacts with other key assessment Standards, including:

• Standard 1.3 – Assessment system must be fit-for-purpose

• Standard 1.4 – Assessment must be fair, flexible, valid, and reliable

• Standard 1.5 – Validation of assessment practices and judgements

These Standards apply equally to RPL.

Evidence Must Adhere to the Rules of Evidence

Under Standard 1.4(2)(b), evidence must be:

• Valid – truly reflects the competency requirements

• Sufficient – enough to make a judgement

• Authentic – proven to be the student’s own work

• Current – recent enough to reflect current competence

RPL evidence often fails these requirements, which is why it is high-risk.

RPL Decisions Must Follow the Assessment System

Standard 1.6 explicitly ties RPL decision-making to the RTO’s assessment system:

“...undertaken in accordance with the organisation’s assessment system.” Legislation-SRTOs

This means:

• RPL cannot use “shortcut evidence”

• RPL cannot be treated as a simple form-filling exercise

• Assessors must be trained and competent in RPL assessment

• RPL tools must be valid and consistent

• RPL outcomes must withstand regulatory scrutiny

ASQA’s Rising Risk Profile for RPL: Why It Matters

ASQA has highlighted increasing concern about:

1. Inconsistent RPL practices across the sector

2. RPL is being used to fast-track students improperly

3. Assessment evidence is insufficient or fabricated

4. Assessors lacking RPL-specific capability

5. RPL documentation lacking transparency or rigour

6. RPL decisions are not being validated

7. RPL processes are being treated as an afterthought

This risk profile is shaping ASQA’s regulatory posture. It also informs why the Standards embed RPL within assessment systems rather than treating it as an optional add-on.

Why Clear Guidance for RTOs Is Now Essential

Regulatory Ambiguity Damages Compliance Confidence

When ASQA’s spoken statements appear to conflict with the legislative instrument, RTOs face:

• Compliance uncertainty

• Risk of incorrect application

• Fear of unintentionally breaching Standards

• Inconsistent implementation across the sector

• Lost trust in regulatory messaging

RTOs Require a Clear Regulatory Position on the Following Questions

1. Must every RTO offer RPL? (The legislation strongly indicates yes.)

2. Can an RTO decide it is “not suited” to delivering RPL? (Only if it removes the qualification from scope or reduces its scope so it can meet all requirements.)

3. Can an RTO refer students elsewhere? (Only as a last resort—and not as a replacement for the RTO’s own obligations.)

4. Does “providing advice about RPL” satisfy the requirement? (No—advice is not equivalent to offering and supporting access.)

5. Must RTOs have an RPL kit for every qualification? (No, but they must have the capability to develop or adapt tools when needed.)

Without clear guidance, RTOs risk non-compliance

If providers incorrectly assume they can avoid RPL, they may:

• Breach Standard 1.6

• Breach Standard 1.3 (assessment system)

• Breach Standard 1.4 (fair assessment)

• Breach Standard 2.1 (information to students)

• Mislead students

• Fail to support experienced workers

• Become subject to regulatory sanction

Clear written guidance from ASQA is needed urgently.

Practical Implications for RTOs Under the 2025 Standards

What RTOs MUST Do

Based on the legislation:

• Offer RPL for every qualification in scope

• Make students aware of their right to seek RPL

• Include RPL in enrolment and pre-training review processes

• Maintain an assessment system capable of supporting RPL

• Train assessors in RPL-specific methods

• Document all RPL decisions

• Validate RPL decisions like any other assessment

• Ensure evidence meets the rules of evidence

• Maintain fairness and avoid barriers to access

What RTOs DO NOT Need to Do

The Standards do not require RTOs to:

• Pre-develop extensive RPL toolkits for every qualification

• Conduct RPL in every instance

• Guarantee RPL outcomes

• Lower evidence standards to make RPL “easier”

• Accept poor-quality evidence

• Replace assessment with desktop paperwork reviews

What RTOs SHOULD Avoid

• Telling students, “You need to enrol first before we consider RPL”

• Charging for RPL before an assessment plan is established

• Offering RPL only as a marketing tool

• Outsourcing RPL because the RTO cannot do it

• Assuming industry experience alone equals competence

• Providing RPL in a single meeting or without sufficient evidence

What High-Quality RPL Looks Like Under the New Standards

Evidence-Based, Not Assumption-Based

Evidence may include:

• Work samples

• Observation

• Portfolio evidence

• Employer validation

• Interviews

• Third-party reports

• Challenge tests

• Practical demonstrations

Clear Assessment Tools Aligned to the Training Product

Tools must:

• Identify performance evidence

• Identify knowledge evidence

• Reflect assessment conditions

• Include mapping

• Include assessor instructions

• Include student instructions

• Allow for reasonable adjustment

A Documented RPL Assessment Process

This includes:

• Pre-screening

• RPL application

• Evidence collection

• Competency conversation

• Practical demonstration

• Assessment judgement

• Outcome documentation

• Feedback to the student

Integration Into the Assessment System

RPL is not separate. It is a method of assessment.

Does the 2025 Legislation Support ASQA’s Interpretation?

Short answer: No.

Long answer: Only in a very narrow administrative context.

ASQA may be referring to situations where:

• An RTO cannot maintain the capability for a specific qualification, and

• The RTO removes that qualification from scope (thus eliminating the obligation to offer RPL for it), and

• Students are informed appropriately, and

• The RTO ensures integrity by not delivering training or RPL it cannot competently support.

This is a valid compliance approach.

But:

An RTO cannot be registered to deliver a qualification, yet refuse to conduct RPL for that qualification.

That would be a breach of Standard 1.6.

The Case for Clearer ASQA Guidance

Given the sector confusion, ASQA’s spoken interpretation should be clarified in writing, addressing the following:

1. Can an RTO be on scope for a qualification and refuse to conduct RPL for it? (Legislatively, no.)

2. Can an RTO direct a student to another RTO for RPL? (Not as a substitute for its own obligation.)

3. Is “providing advice” equivalent to “offering RPL”? (Clearly not under the legislative wording.)

4. What constitutes “being ready to go” in terms of RPL capability? (Policies, systems, trained assessors, evidence frameworks.)

5. What is the minimum evidence expected for RPL validation? (ASQA could provide examples.)

A regulator whose guidance is clear, consistent and aligned with the legislative instrument supports fairness, transparency and sector capability, as the Standards themselves require.

RPL Is a Cornerstone, Not an Optional Extra

The Standards for RTOs 2025 significantly strengthen expectations around assessment quality, student fairness and system integrity.

Standard 1.6 makes it unequivocal:

• RPL is mandatory to offer

• RPL must be supported

• RPL decisions must be evidence-based

• RPL outcomes must be fair, transparent, and consistent

• RPL must uphold integrity

ASQA’s webinar commentary has raised important questions, but the legislation is clear.

RTOs cannot avoid delivering RPL simply because it is complex or resource-intensive.

What they can do is:

• Remove qualifications from scope

• Strengthen assessor capability

• Improve their assessment system

• Build or adapt RPL tools

• Seek compliance support from experts

• Validate RPL practices more rigorously

The VET sector needs clear, nationally consistent guidance from ASQA so that:

• RTOs know their obligations

• Students know their rights

• Assessment integrity is protected

• Australia’s workforce can rely on qualifications being credible

• RPL continues to support fairness, workforce mobility and skill recognition

Recognition of Prior Learning is too important to be left to interpretation. The legislation has spoken; now the regulator must ensure its guidance matches it.

Disclaimer

The views expressed in this post and the accompanying article are my own, based on my interpretation of the current legislative instruments, ASQA publications and publicly available research at the time of writing. They are provided as general information for discussion within the Australian VET sector and do not constitute legal, regulatory, or professional advice.

RTOs and other stakeholders should not rely on this content as a sole basis for compliance decisions. Instead, they should refer directly to the relevant legislation, Standards for Registered Training Organisations, ASQA guidance, and other official sources, and seek their own independent legal or compliance advice where necessary.

Any references to ASQA, NCVER, government reports or other organisations are for context only and do not imply endorsement. While I have taken care to ensure accuracy, the regulatory environment and guidance may change, and I accept no responsibility for any loss, consequence or action taken as a result of relying on the information provided here.