Two Stages, One Standard: Why the Sector Keeps Confusing the Two Jobs Recognition of Prior Learning Must Do

Recognition of Prior Learning is the most argued-about practice in vocational education and training, and most of the confusion traces to one fixable error: treating RPL as a single activity when it is one process doing two distinct jobs. Under the 2025 Standards, RPL is assessment, bound by the same principles and rules of evidence as any other judgement, and ASQA has made it a regulatory priority. Separating the two jobs is what keeps a recognition decision defensible, and what that means for RTOs, assessors and the integrity of the qualifications they issue is the subject of this analysis.

The Most Argued-About Practice in VET

Ask ten practitioners in Australian vocational education and training (VET) what Recognition of Prior Learning is, and the answer will come back ten different ways. Recognition of Prior Learning (RPL), the process of recognising skills and knowledge a person already holds so they need not repeat training they have effectively done, is probably the single most argued-about practice in the sector. The arguments are not new. What is striking is that they continue among people who have spent decades in compliance, auditing and assessment, and who genuinely know their craft. If the experts cannot agree, the trainer in the classroom and the assessor in the field have no chance.

Most of that confusion, this article argues, comes from a single fixable error. The sector treats RPL as one undifferentiated activity, when in truth it is one process that has to do two completely different jobs. Separate those jobs cleanly, and almost every dispute about RPL dissolves. Leave them tangled, and no amount of new templates, kits or guidance will help.

1. What the Legislation Actually Says

The Standards for RTOs 2025, in full regulatory effect from 1 July 2025, define RPL plainly. It is an assessment process. Standard 1.6 describes it as the assessment of an individual's relevant prior learning and experience, including skills and knowledge gained through both formal and informal learning, to determine the extent to which that individual meets the requirements specified in the training product. Two things follow from that definition that the sector routinely ignores.

First, RPL is assessment. It is not a softer, lighter alternative path that sits outside the assessment rules. It sits squarely inside them. Standard 1.6 requires RPL decisions to be based on evidence of prior skills, learning and experience, and to be undertaken in accordance with the organisation's assessment system, the same assessment system that governs every other judgement the provider makes. There is no separate, gentler rulebook for RPL.

Second, because RPL is assessment, it must satisfy the principles of assessment and the rules of evidence that apply to all assessment under the Standards. The principles are fairness, flexibility, validity and reliability. The rules of evidence are validity, sufficiency, authenticity and currency. Every one of these applies to an RPL judgement exactly as it applies to a judgement made about a learner who sat through the full course.

This is where the 2025 wording matters most. Standard 1.4 now requires that assessment includes practical application components that enable the student to demonstrate the relevant skills and knowledge in a practical setting. Read together with the validity and currency rules of evidence, that requirement is decisive for RPL. A recognition judgement that rests on a folder of historical documents and a conversation does not demonstrate current skills in a practical setting, and so it cannot satisfy validity or currency. The legislation has quietly closed the door on the portfolio-and-conversation model, and a large part of the sector has not noticed.

2. The Two Jobs, Named

Here is the reframe. RPL is one process, but it carries out two distinct functions, and they must never be confused.

The first job is determining suitability. Before any assessment begins, the provider needs to work out whether this candidate is a plausible RPL candidate at all. Do they appear to hold relevant prior learning? Have they worked in the field, recently and for long enough? Is there any point in taking them down a recognition pathway rather than enrolling them in training? This is the stage where self-assessment forms, resumes, position descriptions, references, certificates and work samples belong. These materials are intake and screening tools. They tell the provider whether to proceed and where to focus the assessment. They are diagnostic. They are not, in themselves, proof of competence.

The second job is assessment of competence. Once a candidate has been judged suitable, the provider must assess them against the training product with the full rigour the Standards demand. This means gathering genuine, current evidence that the person can do the job, predominantly through observation, demonstration, practical tasks and structured questioning of current knowledge. This is where competence is actually established, and this is the part that must satisfy validity, sufficiency, authenticity and currency. This is the assessment.

The error that runs through the sector, including through many commercial RPL kits, is to mistake the first job for the second. Candidates are asked to submit a mountain of documentary evidence at the application stage; that evidence is mapped against units of competency, and a judgement of competence is reached largely on the strength of paper. The screening material has been quietly promoted to the role of competence evidence. That is the precise point at which RPL becomes indefensible.

3. Why the Distinction Is Not Academic

When the two jobs are tangled, four predictable failures appear, and they map directly onto the rules of evidence. Reverse the approach, using the documents only for what they are good for and then conducting a real assessment built on observation and demonstration of current skill, and the same four rules are satisfied without strain. The following table sets out both directions.

The candidate's prior learning has still been recognised, in the sense that they have been spared unnecessary training, and their competence has been genuinely established. That is what the legislation has always intended, and it is what the word recognition means: the learning is acknowledged as done, and then the person gets on with a full, current assessment of what they can do today.

4. A Note on Terminology

Some colleagues argue that recognition and assessment-only are different things. They are not. They are the same family. An assessment-only pathway and a recognition pathway both rest on the identical principle: this person already has the skills, so the provider will assess rather than teach. The evidence requirements do not soften because RPL has been written on the cover sheet. Treating recognition as a category exempt from ordinary assessment rigour is the original error from which most poor practice descends.

5. What Providers Should Do Now

ASQA, the national VET regulator, has made RPL a heightened regulatory priority. Its published risk priority targets inadequate assessment practices, false or misleading marketing of RPL, the unavailability of gap training, and the issuing of qualifications that are not properly earned. The regulator has warned about high-volume, low-quality RPL models, the particular fraud risks in sectors such as aged care, individual support, childcare, security and the trades, and the role of unregistered brokers and agents, and it has published a Practice Guide on Recognition of Prior Learning and Credit Transfer. ASQA has acted against providers with non-compliant RPL practices, including removing some from the sector and cancelling fraudulently issued qualifications. Providers should not wait to be audited to act.

Every provider should pull out its RPL tools and ask two questions of each one. Does this tool clearly separate the suitability stage from the assessment stage, so that nobody mistakes intake documents for competence evidence? And does the assessment stage require current, practical demonstration of skill, not merely a review of paper? If a tool fails either test, it needs rebuilding, because it will not survive scrutiny and, more importantly, it will not produce graduates who can actually do the work.

Conclusion: Name the Two Jobs, Keep Them Apart

Recognition of Prior Learning is not broken because it is hard. It is broken because the sector keeps asking one process to do two jobs at once and then wonders why the result is confused. The fix is not another template or another kit. It is conceptual. Name the two jobs, keep them apart, and hold the second one to the full standard. Use the documents for what they are good for, deciding suitability, and build the competence decision on current, practical demonstration of skill. Do that, and the candidate is spared unnecessary training, the qualification means what it says, and the recognition decision survives any audit. The rest follows.

References and Further Reading

Australian Skills Quality Authority (2025). Recognition of Prior Learning: Risk Priority. https://www.asqa.gov.au

Australian Skills Quality Authority (2025). Practice Guide: Recognition of Prior Learning and Credit Transfer. https://www.asqa.gov.au

National Vocational Education and Training Regulator (Outcome Standards for NVR Registered Training Organisations) Instrument 2025 (F2025L00354), Standards 1.4 and 1.6. https://www.legislation.gov.au

Australian Qualifications Framework Council (2013). Australian Qualifications Framework. https://www.aqf.edu.au