How ASQAs new audit model will affect your RTO.

by Emily Hodge

All ASQA registered RTOs and CRICOS providers who are subject to an audit by ASQA for any reason (compliance or applications) will be affected by ASQAs new audit model. These changes have a greater impact on compliance audits than on application audits. Applicants in the process of registering to become RTO will also be affected by these changes in their application audit.

What is the new ASQA model?

ASQA have developed a new approach to conducting audits that includes:

The student experience

A focus on the student experience and 5 stages of the student ‘lifecycle’

Customised approach

A more customised approach to deciding when and how to audit each RTO depending on risk identified prior (e.g. background searches, students interviews and other sources of information about the RTO).  Some RTOs may be subject to more or more rigorous audits and others less depending on compliance history and other factors to do with the ‘Compliance posture’ of the RTO. ‘Risk ratings’ are no longer in use and now replaced with ‘compliance history


Changes to the way audits are reported (new audit report tool with clauses organised in the order of the student lifecycle) and ‘reporting by exception’).

Redressing harm

RTOs now required to ‘redress harm’ not only rectify non-compliances. E.g. this may involve reconciling with students and/or other stakeholders implicated in ASQA’s findings.

Old vs New ASQA Model

Old: ASQA always audited the clauses chronologically.

New: Now these (along with the format of the audit report) are organised according to stage in the student lifecycle which are:

  • Marketing & recruitment
  • Enrolment
  • Support & Progression
  • Training and Assessment
  • Completion.

Old: audit evidence was generally sourced from the RTO and usually after the audit was called.

New: Now ASQA are investigating providers prior to deciding how and when to audit them as:

  • interviewing past and present students (this will be standard for compliance audits)
  • googling and looking at all marketing and advertising online
  • due diligence or research on third parties implicated
  • considering the above in relation to the risk of the provider – meaning the existing compliance history,(e.g. audit history,  payment of ASQA fees and charges on time, complaints received) funding source information and enrolment data on file.

Other changes:  

  • More variance on notice period, scope of audit and general audit approach based on identified risk of each provider.
  • ASQA may require RTO to take corrective/remedial action to repair damages to student rather than only rectify the non-compliances. 

Beware of the impacts

The biggest impact on your RTO is that the responses your students have when ASQA calls them about their understanding of their enrolment and experience of working with your RTO will have deep ramifications for your risk and ASQA’s approach to regulating your RTO. This will mean even stronger focus on standards 1 & 2.

ASQA have more opportunities to identify non-compliance based on a wider source of information so it will be important that all information about your RTO and its courses is consistent and compliant regardless of who publishes it or where it is published. This will mean an even stronger focus on standards 2, 4 and 5.

How RTOs can prepare

  • Ensure your students are prepared to answer questions on the ASQA student surveys at each stage of the lifecycle. This means conducting some surveys of your own and/or adapting your proformas for induction, enrolment, completion (checklists, session plans and templates used) to ensure that these key areas are addressed at each stage.
  • Conduct an audit of your marketing and advertising focusing on:
    • Information provided about courses prior to enrolment or commencement
    • All marketing about your RTO
    • All information about courses or your RTO provided by a third party
  • Audit the quality of your training & assessment focusing on:
    • Student outcomes including career and satisfaction levels
    • Competency and training package requirements (as always assessment and completion requirements)
    • Qualifications, currency and professional development of all training & assessment staff including any staff conducting training & assessment on your behalf.
  • Use the following online resources to review current information – ASQAs new audit model or ASQAs Student Centred Audit Approach

About Emily

For over 10 years, Emily Hodge has been working in RTO compliance and administration, Emily specialises in helping organisations achieve and maintain ASQA registration, and has an in-depth understanding of the compliance, business and operational needs of RTOs.