When placements involve infants and young children, the standard for safety, supervision and assessment must be higher than anywhere else in education. That is the clear message of the joint alert issued on 12 November 2025 by Australia’s higher education regulator and national VET regulator. The alert identifies emerging risks in workplace learning across early childhood education and vocational training and signals an uplift in regulatory scrutiny where admission, agent conduct, placement quality, supervision, and assessment integrity fall short. In short, providers that cannot demonstrate robust governance over these risks should expect compliance assessments and possible enforcement action.
Although the alert is timely, none of the underlying expectations are new. They are embedded in the Higher Education Standards Framework (Threshold Standards) for universities and higher education providers, the 2025 Standards for RTOs for VET providers, and a growing suite of sector-specific child-safety resources, including new national guidance for assessing early childhood students in the workplace and a model code to reduce digital harms. The difference now is emphasis: consistent governance across admission, placement design, third-party oversight, and assessment is being tested more directly against real-world harms and public trust.
Why this alert matters now
Early childhood staff play a critical role in children’s development. That responsibility amplifies the consequences when workplace learning becomes transactional, when admission standards are diluted to fill places, when agents over-promise, when placement sites are chosen for convenience rather than quality, or when supervision is nominal. In recent months the sector has seen a raft of reforms and guidance to tighten expectations: TEQSA has refreshed guidance on work-integrated learning, emphasising that placements are a formal component of a course under the Threshold Standards; ASQA, with ACECQA and government partners, has published detailed guidance on assessing early childhood students in the workplace; and governments have promoted ACECQA’s National Model Code on taking images to curtail unsafe or intrusive practices during learning and assessment. These resources should now anchor every provider’s quality framework for early childhood placements.
Beyond guidance, broader regulatory alignment is underway. TEQSA and ASQA recently released a dual-sector regulatory strategy that aims to streamline oversight while sharpening focus on common risk areas, including third-party delivery and integrity in assessment. In practice, this means dual-sector providers should expect more coherent expectations across both arms of their business and fewer excuses for gaps between VET and higher education processes. Boards should read the strategy as a signal that coordinated audits and shared risk intelligence will increasingly test how well governance controls travel across the whole enterprise.
What regulators are seeing
The alert’s concerns can be grouped into four systemic weaknesses.
First, admission integrity and agent conduct. Providers are enrolling students who are not genuinely prepared or do not meet entry standards, sometimes via agents who promote overly convenient pathways. For early childhood, this can place unprepared learners in sensitive environments and increase the burden on host services to remediate basics before genuine learning can occur. Under the Threshold Standards, admissions are an academic governance matter; under the 2025 Standards for RTOs, admission policies must support fitness for the training product, including mandated checks. Weakness here is a board problem, not just an operational one.
Second, placement readiness and site selection. Students are commencing placements without mandatory checks completed, without appropriate induction, and sometimes without sufficient numbers of suitably qualified supervisors. Provider duty of care begins before day one on site and continues until assessment records are finalised; it includes due diligence on placement partners, formal agreements that set out roles and responsibilities, and oversight mechanisms that escalate concerns quickly. ASQA’s new workplace-assessment guidance is explicit about unacceptable practices, including digitally recording children during assessment activities.
Third, supervision and assessment oversight. The quality of supervision and the integrity of workplace assessment are inseparable. The guidance emphasises assessor capability, structured observation, clear evidence requirements, and prohibition of practices that compromise child safety or the rules of evidence. TEQSA’s WIL guidance similarly frames placements as assessable learning that must be deliberately designed, monitored and quality-assured within the provider’s overall assessment system.
Fourth, digital and photographic harms. Even well-intentioned evidence practices can create risks when images or videos of children are captured or stored. The ACECQA National Model Code sets out a child-safe culture for taking, sharing and storing images in early childhood settings and explicitly seeks to curb casual or undocumented recording during learning or assessment. Providers should embed the code into placement agreements, assessor handbooks and student conduct expectations.
The public context: scrutiny has intensified
Public scrutiny of early childhood safety has deepened through 2025, including media investigations into abuse, supervision failures, and regulatory fragmentation, and a broad push by academics and advocates for stronger national coordination, tougher quality controls, and more transparent oversight. While proposed reforms vary in detail, they converge on the same pressure point: frontline safety and supervision must be funded, governed and checked as core quality, not as an afterthought. Providers should expect that community expectations will keep rising, and regulators will calibrate their risk settings accordingly.
A whole-of-provider response: what good looks like
The alert asks every provider to undertake a check of current practices. A credible response requires a whole-of-provider approach that integrates academic governance, risk, legal, people, culture, and student support. The following elements describe a defensible standard of practice for early childhood placements in both VET and higher education.
1) Admission integrity and agent governance. Admission decisions must be evidence-based and auditable against published standards, including language, literacy and numeracy where applicable, and mandatory prerequisites. Agent agreements should prohibit misleading messaging and include audit rights, complaint handling, and termination triggers for non-compliance. Agent dashboards that monitor conversion quality, withdrawal rates, and placement incident correlations strengthen oversight at the board level. TEQSA’s guidance notes on admissions and academic governance, while advisory, outline expectations that the sector is judged in practice.
2) Placement design and capacity matching. Student numbers must be matched to the real capacity of qualified supervisors and the availability of quality placement sites. For VET, that mapping should be explicit in the Training and Assessment Strategy; for higher education, it should be visible to academic governance bodies when approving or varying courses with placement components. Where government guidance restricts certain evidence practices (for example, no digital recording of children for assessment artefacts), that must be reflected in assessment design from the outset.
3) Due diligence on host services. A layered approach to site selection is essential: licence and regulatory status checks; documented supervision ratios for the student’s level; sighting policies on child protection, image use, digital device restrictions, and incident reporting; confirmation of Working With Children Check processes and continuous monitoring where available; and clarity on escalation pathways. Reference recent national guidance and model codes in your due diligence checklist so expectations are unambiguous.
4) Student readiness and onboarding. No placement commences until all prerequisites are verified and recorded: WWCC clearances, vaccinations where relevant, site inductions, and training in grooming awareness, professional boundaries, and safe evidence collection. The provider’s orientation should explicitly cover prohibited practices and confirm how learning outcomes will be demonstrated without capturing children’s images or personal data. Align your onboarding content with the ASQA/ACECQA workplace-assessment guidance.
5) Supervision architecture. Define the chain of supervision in writing: the host’s on-site supervisor, the provider’s academic supervisor/assessor, and the escalation contacts on both sides. Minimum contact frequency, observation moments, and feedback milestones should be timetabled; ad hoc “check-ins” are insufficient. For VET, ensure assessor competence and evidence mapping meet the rules of evidence; for higher education, ensure academic oversight meets the Threshold Standards for assessment and course delivery.
6) Assessment integrity and evidence policy. Replace high-risk artefacts (photos, videos, identifiable child data) with safer alternatives: assessor observation records, anonymised scenario-based evidence, reflective journals evaluated against rubrics, and supervisor attestations cross-checked by the provider assessor. Where workplace artefacts must be de-identified, set the de-identification protocol and storage rules centrally and audit them. ASQA’s ECEC workplace-assessment guidance squarely addresses what is and is not acceptable evidence.
7) Real-time incident and trend monitoring. Build a placement risk dashboard that aggregates incidents, near misses, supervision breaches, assessment anomalies, agent-linked complaints, and WWCC issues. Report the dashboard to academic and governing bodies at a cadence proportionate to placement volume and risk. Use TEQSA and ASQA risk priorities to calibrate what constitutes a “material” issue warranting prompt governance attention.
8) Third-party and agent transparency. Publish a clear statement for students about what agents and host services may and may not do, how to report concerns, and what will happen next. Embed a right for the provider to audit placements and for students to request a change of site where safety or supervision is inadequate. In dual-sector organisations, standardise these rights across VET and higher education to avoid confusion.
Building a safer evidence ecosystem
A recurring theme is the need to keep evidence of learning robust without compromising child safety. The sector now has clear national guidance and a model code for image use. Providers should therefore retire legacy assessment practices that rely on images or footage of children and instead normalise assessor-generated evidence, structured workplace observations, and triangulated supervisor attestations. Where digital tools are used, they should enforce redaction by default, watermark assessor-generated documents, and block the upload of image files from placement settings. Align policy settings with the ACECQA National Model Code and reference it explicitly in placement agreements and student handbooks.
Governance: moving from policy to proof
The alert’s final expectation is governance oversight you can demonstrate. Boards and academic committees should be able to show:
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how admission policies prevent under-prepared students from entering placement streams
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how agent oversight works in practice (audit results, terminations, and corrective actions)
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how placement capacity is matched to student volume and supervision availability
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how assessment integrity is verified without risky artefacts
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how incidents are escalated, analysed and reported to governance bodies.
Providers that can evidence these elements will be better positioned if regulators commence a compliance review or seek explanations about trends. TEQSA’s broader suite of guidance notes and ASQA’s provider guidance are designed to help you demonstrate that journey from policy to proof.
What to do this month
To translate the alert into immediate action, every provider should complete a rapid, documented health check across both VET and higher education portfolios:
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Admissions and agents: sample-test recent admits against entry standards; mystery-shop agent marketing to detect over-promises; issue corrective notices where needed.
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Placement inventory and capacity: reconcile enrolled student numbers to confirmed, quality-assured placement slots and supervisor availability for the next two study periods.
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Site due diligence refresh: reconfirm child-safety policies, WWCC processes and image-taking rules at every host site; update agreements to reference the ACECQA model code and ASQA workplace-assessment guidance.
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Assessment redesign: remove any requirement for student-captured images/videos; publish a replacement evidence matrix and train assessors accordingly.
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Escalation and reporting: hard-wire a placement risk dashboard into academic governance and governing body agendas each term. Align your thresholds with regulator risk priorities.
The path forward
The joint alert is not an isolated signal. It sits within a wider national effort to rebuild public trust in early childhood education and care by tightening governance, lifting transparency, and resourcing regulators to act more quickly where risk is high. For providers, the safest and most sustainable response is cultural: treat placement safety and assessment integrity as core business, not compliance afterthoughts; design courses and assessments that assume image-free evidence; and hold agents and third parties to the same standards you apply internally.
Done well, these steps protect children, respect families, support educators, and give the public confidence that our qualifications mean what they claim. That is not just a regulatory goal; it is a community obligation.
