ASQA’s New Regulatory Expectations: Governance Visibility Is Now the Test

A few days ago I wrote about the noticeable shift underway in the VET sector.

A more confident regulator. Sharper intelligence-led enforcement. A clearer line between providers delivering quality outcomes and those exploiting the system.

ASQA’s new Statement of Regulatory Expectations on Fit and Proper Person Requirements and Material Change Notifications confirms that this shift is now firmly operational.

And I think there is one message in the statement that every RTO CEO, board member and governing person should pay very close attention to:

Governance accountability is no longer judged simply on whether issues are eventually fixed.

It is increasingly judged on whether leadership had accurate visibility of issues in the first place.

This statement fundamentally changes the conversation from:

“Did you fix the issue?”

to:

“How did you not know the issue existed?”

That distinction matters enormously under the 2025 Standards.

Because fit and proper person obligations and material change requirements are not passive obligations. ASQA describes them as an “inherent and continuing obligation.”

And that means CEOs and governing persons must be able to demonstrate they have a clear, accurate and current view of compliance across the organisation.

Not quarterly. Not when an audit is announced. At all times.

ASQA is explicit that providers must engage with the regulator in an “open, honest and transparent manner” and maintain “effective governance and compliance arrangements.”

More importantly, the statement repeatedly reinforces the importance of timely, accurate and complete disclosure.

That is significant.

Because the regulator is now drawing a very clear connection between governance integrity and visibility of risk.

If leaders do not have genuine visibility of risks, non-compliances, significant events, overdue actions, unresolved issues or governance concerns, then there is a serious question to ask:

Are they actually meeting their fit and proper person obligations?

Because ignorance is no longer a defensible governance position under a self-assurance model.

ASQA states that:

• undocumented decision-making
• assumptions of immateriality
• withholding information
• delayed disclosure
• incomplete information
• mischaracterisation of issues

all undermine regulatory confidence.

This is the new normal for RTO governance.

The era of fragmented spreadsheets, siloed information, disconnected teams and relying on key individuals to “keep an eye on things” is rapidly becoming untenable.

Governance now requires operational transparency.

At Octossure, we believe this is one of the biggest structural shifts occurring in compliance management.

It is no longer enough to believe you are compliant.

You need to be able to demonstrate it clearly, consistently and with evidence that holds together.

That means leaders need real-time visibility of:

• compliance risks
• overdue actions
• audit findings
• rectification activity
• governance declarations
• material issues and escalation points
• quality assurance outcomes

Because you cannot govern what you cannot see.

And if an organisation cannot demonstrate visibility, oversight and informed decision-making, the regulator may reasonably question whether governing persons are truly fit and proper to hold those responsibilities.

ASQA’s statement is important not because it introduces entirely new obligations.

It is important because it confirms that governance accountability is now being judged by the quality, transparency, accuracy and maturity of an organisation’s compliance oversight systems.

That shift cannot be ignored.

Source: ASQA Statement of Regulatory Expectations - Fit and Proper Person Requirements and notification of material changes. asqa.gov.au/newsroom/latest-news/statement-r… asqa.gov.au/sites/default/files/2026-05/Stat…