The Australian Vocational Education and Training (VET) sector is built on trust — trust that qualifications represent genuine skills, that assessments are fair and rigorous, and that providers act in the best interests of students, industry, and the community. When that trust is broken, the damage ripples far beyond a single provider. The recent decision by the Administrative Review Tribunal (the Tribunal) to affirm the Australian Skills Quality Authority’s (ASQA) cancellation of a qualification issued by the now-defunct Gills College is not just a legal ruling — it is a stark reminder of what happens when the principles of quality and integrity are traded for profit and expediency.
This is the second Tribunal decision affirming ASQA’s actions against Gills College, and it underscores a growing and necessary crackdown on fraudulent practices that undermine the credibility of Australia’s education system. It also brings into focus the ongoing challenge of ensuring that Recognition of Prior Learning (RPL) — a legitimate and powerful assessment method — is not misused or manipulated by bad-faith operators seeking to exploit students and the system alike.
The Case: When RPL Becomes a Sales Pitch
At the heart of the Tribunal’s latest decision (Case No. 2025/0927) lies the story of an individual who obtained a Certificate IV in Kitchen Management from Gills College through an agent called eHub. The individual was told they could gain the qualification via RPL, given their hospitality experience, by paying a fee of $1,150. They were never required to attend the college, never met a qualified assessor, and were never guided through a legitimate RPL process. There was no evidence of assessment, no mapping of skills to units of competency, and no demonstration that the required learning outcomes had been achieved.
The Tribunal found that Gills College had issued the qualification without providing any genuine training or assessment. Senior Member Harrowell, in affirming ASQA’s decision to cancel the qualification, noted there was “no evidence of any member or staff of the College being assigned the task of carrying out assessments for the purpose of recognition of prior learning generally, let alone in respect of the application made by the applicant.”
Importantly, the Tribunal also recognised that the student had not acted in bad faith. The individual did what they were told, trusting the agent and assuming the process was legitimate. “There is no suggestion that the applicant has acted inappropriately or failed to do what was asked of him by eHub in making the RPL application,” Harrowell stated.
This distinction is vital. It places the responsibility where it belongs — on the RTO and its agents, not on students who are often vulnerable, hopeful, and unaware of the complexities of RPL compliance.
ASQA’s Response: Protecting Public Trust
Following extensive investigations, ASQA cancelled Gills College’s registration in November 2024 after finding the organisation to be critically non-compliant. The regulator determined that Gills College had issued qualifications and statements of attainment without adequate assessment, failed to ensure students had met competency requirements, and disregarded core standards of assessment integrity.
To protect the public and the reputation of the VET system, ASQA went further — cancelling the qualifications and statements of attainment issued to more than 3,300 individuals. This was not a step taken lightly. It was a necessary intervention to preserve the value of Australian VET qualifications, particularly those recognised nationally and internationally.
Since late 2024, ASQA has deregistered 15 RTOs for similar offences and has cancelled more than 29,000 qualifications issued fraudulently to over 26,000 individuals. These actions form part of ASQA’s broader Qualification Integrity Program, a targeted initiative to identify and remove illegitimate credentials from the national system.
ASQA CEO Saxon Rice made the message clear: “There is no place for any training provider who seeks to undermine the sector or exploit students. The targeting of non-genuine providers and bad-faith operators is one part of an ongoing program of work by ASQA to ensure the integrity of the VET sector for students, industry, and the community.”
The RPL Debate: Legitimate Process or Loophole?
The case reignites a long-standing debate within the sector about Recognition of Prior Learning — one of the most misunderstood and misused assessment methods in vocational education.
RPL is, at its core, a formal and structured assessment process that allows individuals to have their existing skills, knowledge, and experience recognised against the requirements of a qualification. It is an important avenue for lifelong learning and workforce mobility, particularly for experienced workers, migrants, and adults re-entering the education system.
However, as this case demonstrates, when RPL is marketed as a “fast-track” or “no-study” pathway, it ceases to be recognised and becomes deception. Phrases like “no classes required”, “guaranteed qualification”, or “receive your certificate in seven days” are red flags — signals of an RPL process that is not compliant with the Standards for RTOs or the National Vocational Education and Training Regulator Act 2011 (NVR Act).
ASQA’s guidance to students is unambiguous: if it sounds too good to be true, it probably is. RPL, when done properly, involves detailed evidence gathering, validation, assessor judgement, and sometimes gap training. It is not an administrative exercise — it is an assessment of competence.
The Compliance Lessons for RTOs
For compliant and ethical RTOs, the Gills College decision serves as both a warning and a reaffirmation of the standards expected in RPL practice. Under the Standards for RTOs 2015 — and reaffirmed under the forthcoming Standards for RTOs 2025 — RTOs must ensure that all assessments, including those conducted through RPL, meet the principles of assessment (fairness, flexibility, validity, and reliability) and the rules of evidence (validity, sufficiency, authenticity, and currency).
Failure to uphold these principles can lead to findings of critical non-compliance, deregistration, and the cancellation of qualifications.
Among the most important lessons are the following:
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RPL Must Be a Structured Assessment Process:
RPL is not an alternative to assessment; it is assessment. It must be planned, documented, and conducted by qualified assessors. There must be evidence of candidate engagement, evidence mapping, and assessor judgment based on the rules of evidence. -
Third-Party Arrangements Require Oversight:
RTOs remain responsible for all activities conducted on their behalf by brokers, agents, or third-party providers. In the Gills College case, the agent (eHub) acted as the conduit between the student and the RTO, but it was the RTO’s duty to ensure compliance, oversight, and quality assurance. Delegation does not equate to abdication. -
Marketing and Recruitment Must Be Ethical:
Misleading advertising that promises instant qualifications or guaranteed outcomes is a direct breach of Standard 4 (Marketing and Recruitment) of the Standards for RTOs. The integrity of marketing communications reflects the integrity of the organisation itself. -
Assessment Evidence Must Be Authentic and Sufficient:
Simply collecting documents such as résumés or work references is not enough. RTOs must verify the authenticity of evidence and ensure it aligns with the performance criteria and assessment conditions of the units being recognised. -
Transparency Protects Everyone:
Transparent RPL policies and clear communication with students build trust and reduce disputes. Students should understand that RPL involves verification, not automatic recognition.
The Broader Implications for the Education Sector
While the Gills College case falls squarely within the VET sector, its implications extend to the broader education landscape, including higher education and non-accredited training. Both sectors face increasing pressure to demonstrate integrity, especially as pathways between vocational and higher education become more fluid.
Universities that accept RPL or credit transfer from VET qualifications rely on the quality of those qualifications. When fraudulent or non-genuine credentials enter the system, the credibility of credit transfer arrangements is compromised. This undermines confidence in both sectors and erodes the value of national frameworks designed to support lifelong learning.
Moreover, as international education recovers post-pandemic, maintaining the integrity of Australian qualifications is vital to the country’s global reputation. The misuse of RPL in migration-linked courses, in particular, has drawn the attention of regulators, migration authorities, and the public. Cases like this one send a clear message to offshore agents and unethical operators: Australia will not tolerate shortcuts that devalue its qualifications or exploit its students.
The Human Cost of Fraudulent RPL
While the headlines focus on institutional failures and regulatory action, it is the students who bear the greatest cost. Many of the 3,300 individuals whose qualifications were cancelled by ASQA are now left in limbo — uncertain of their standing, facing reputational harm, and in some cases, facing visa or employment consequences.
Most of these individuals were not complicit. They trusted what appeared to be legitimate providers and agents. For many international students and workers, RPL offered a chance to formalise years of hard work and gain recognition for real skills. Instead, they were sold false hope.
ASQA has provided opportunities for affected individuals to demonstrate that they did, in fact, complete the required training and assessment, but for many, this process is complex and time-consuming. The lesson here is clear: protecting the public also means protecting students from being misled in the first place.
Rebuilding Trust Through Compliance and Culture
The VET sector’s future depends not only on compliance but on culture. Regulatory frameworks provide the minimum standard, but integrity requires a mindset — one that values fairness, authenticity, and student-centred practice above short-term gains.
Every CEO, compliance manager, and trainer in the sector must recognise that trust is their greatest asset. When an RTO issues a qualification, it is making a promise to industry and to Australia’s workforce that the holder is competent, capable, and qualified. That promise must never be broken.
To rebuild and sustain trust, education leaders must go beyond avoiding non-compliance. They must actively champion best practice:
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Embed Ethics in RPL Systems: Treat every RPL application as a reflection of your organisation’s values. Build robust evidence checklists, require assessor signatures, and validate evidence authenticity.
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Train and Support Assessors: Many assessors lack confidence in conducting RPL assessments. Provide regular training on mapping evidence, conducting professional conversations, and applying assessment judgements.
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Audit Marketing and Third-Party Activities: Review all promotional material and ensure agents represent your organisation accurately. Establish contractual controls and monitoring mechanisms for third-party arrangements.
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Engage in Continuous Improvement: Treat every audit finding and complaint as an opportunity to strengthen systems. Use internal validation and external review to maintain integrity.
A Sector Under Renewal
The Gills College case also signals a broader shift in how ASQA is exercising its regulatory powers. The regulator has become more proactive, transparent, and data-driven, focusing on systemic risk rather than isolated incidents. Its focus areas — including fraudulent issuance, RPL abuse, and third-party misrepresentation — reflect a determination to clean up the sector once and for all.
The Tribunal’s affirmation of ASQA’s decisions lends weight to this approach. It demonstrates that the regulator’s actions are not arbitrary or overreaching but grounded in evidence and consistent with the National Vocational Education and Training Regulator Act 2011 (NVR Act). The message is simple: compliance is not optional, and integrity is not negotiable.
For legitimate RTOs, this is good news. Every fraudulent operator removed from the system strengthens the reputation of those who do the right thing. Every cancelled illegitimate qualification reinforces the value of the real ones. The sector is evolving — and those who uphold integrity will emerge stronger.
Conclusion: Reclaiming the Meaning of Recognition
Recognition of Prior Learning remains one of the most powerful tools in Australian education. It honours the experience of workers, values lifelong learning, and provides pathways to formal qualifications for those who have earned their competence outside traditional classrooms. But RPL must never be reduced to a transaction — it must remain an assessment process grounded in evidence, integrity, and fairness.
The Tribunal’s decision on Gills College reminds us that shortcuts are not recognition. They are exploiting. And while bad-faith operators may temporarily profit, the long-term cost to students, the sector, and Australia’s international reputation is far greater.
As ASQA’s ongoing actions show, the regulator is not only enforcing compliance but also safeguarding the soul of the VET system. Every genuine RTO has a role to play in that mission. By embedding integrity into every stage of RPL — from marketing to assessment to certification — the sector can ensure that every qualification issued is one that Australia can stand behind with pride.
When recognition is earned, not sold, everyone wins — students, employers, educators, and the nation itself.
