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3 Common Non-Compliances You Need to Know, Direct from Auditors

November 18, 2019

Lauren Hollows, Thrive Education
Director of Thrive Education; National VET Speaker & Writer

If you don’t work for a large RTO, it may be years since you’ve been handed a dreaded report by an ASQA auditor (I once received a 100-page audit report on Christmas Eve, apparently Santa had put me on the naughty list that year). You may see the regulator as the Oogie Boogie Man, hiding in shadows and lurking around corners, waiting to pounce. We’ve all heard the horror stories—audit fears can keep any trainer, RTO manager or CEO awake at night. Think of this article as your warm cup of milk and soothing night light—a way to stay informed without the stress of an audit.

Here’s three common non-compliances that consistently turn up in audit reports, and how you can avoid them.

3. Detailed Training & Assessment Strategy (TAS)

Your TAS is usually the first thing to be scrutinised by auditors. They want a detailed framework for every training product (Qualification, Skill Set, etc.) that you offer. If you offer different packages to different cohorts—for example two short course versions with differing lengths—these will need separate TAS’s too. Each TAS must be comprehensive, as shown by these two quotes taken from ASQA audit reports (July—Sept 2019):

“The evidence reviewed does not demonstrate that the strategy provides a framework to guide the learning requirements and the training and assessment arrangements of each training product - at the macro level requirements of the learning and assessment process.”

“The Training and Assessment Strategies do not contain an assessment plan that indicates when the various assessment tasks are required to be submitted in relation to sequence of delivery and delivery schedule.”

If your TAS is missing frameworks for your qualifications, it doesn’t necessarily mean you don’t have working frameworks in place, but rather, haven’t outlined them thoroughly in your TAS.

Your TAS is a guide for your assessors on when, where, and how to run courses, making the level of detail critical. It should cover essential info for each qualification, such as:

  • When units stop and start
  • How the training is delivered—in a classroom, online, etc.
  • When assessments are due 
  • How students are assessed
  • How training is structured week-to-week, or in a short course, day-to-day
  • Required resources

These macro level requirements are sought by auditors, and must be covered in your TAS. Without them, ASQA non-compliance will follow.

2. Trainer and assessor capability

Trainer and assessor capability continues to be a critical concern for ASQA, who understand its importance for delivering quality training. 

The following quote from an auditor shows their concern regarding the workload of a trainer, who may have little time left for professional development:

“There were approximately 60 childcare placements across [RTO name], the RTO has only one trainer/assessor that coordinates all learner placements. The same trainer delivered training and assessment for the RTO face to face component at the RTOs facilities in [date] and worked part time.”

Despite their frenetic schedule, the trainer in question may still have time for professional development, but without evidence, the auditor won’t know.

The following comment finds lack of evidence for current industry skills:

“The [trainer matrix] indicates that this trainer assessor is not currently employed in the industry and has detailed ‘onsite visits’ and ‘validation and moderation of mine sites working with best practice’ as evidence of current industry skills. However, there is not enough information provided in the summary or in the individual trainer competency mapping form to demonstrate this trainer/assessor meet the requirements of clause 1.13 b.”

Again, your trainers may be delivering quality, up-to-date training, but without evidence, the auditors won’t know. When breaking down unit currency, you must explain how you’ve validated each skill against the industry itself. Auditors care a lot about skill currency when auditing your business. They try to find evidence of “current industry skills directly relevant to the training and assessment being provided” (Standard 1.13(b)). 

To validate the skill currency of your trainers, it can be helpful for them to ask this question: “when was the last time I performed this skill in a way that industry could validate it?”

Ways to maintain skill currency might include the following:

  1. Asking your trainers to work in the industry for a short period
  2. Inviting workers from the industry to come in and validate your trainers’ skills
  3. Ask industry workers to validate the student’s work while they’re on-site

There’s a range of other ways to maintain skill currency. You’ll need to figure out what works for your trainers, as every industry is different.

1. Assessment

The most common non-compliance comes under Standard 1.8, for practical assessment and collecting performance evidence. This comment is seen over and over again:

“The ‘Observation’ assessment does not provide any context to the actual assessment task that the student is required to perform and states: ‘Each task must be observed. You will need to ensure you provide the learner with the correct equipment and/or materials to complete the task. You will also need to inform the learner of the time they have to complete the task; this will once again vary, depending on the task.’ This does not provide the learner with clear instructions or information in relation to the assessment task/s that are required.”

This type of generic assessment feedback is common, and relates back to your TAS. Provided that everything above is outlined in your TAS, and your trainers are following it to the letter, auditors should be satisfied.


Those are three common non-compliances that you’ll want to focus on, but as a bonus, here’s feedback from an auditor who found issues with an RTO’s marketing:

“No information was provided on the RTOs rolling intake process where new learners joined existing learners in the same class.”

“Contrary to providing learner support the RTO had a policy of charging the learner a penalty fee of $50.00 if they did not submit a complete assessment within 1 week of the end of delivery of a unit of competency and a further $50.00 for every week late thereafter.”

Auditors want to make sure that your learners are properly informed during their time with you, and are given the support that you’ve promised. Are you practising what you preach? If your learners are constantly surprised after enrolling, there’s big improvements to be made. Consistent, up-to-date documentation and communication helps your training run smoothly.

By being aware of common non-compliances, you’re able to become a master thief capable of stealing an auditor’s ammunition. More importantly, you’re improving the quality of your training, putting you a step ahead of everyone else. 

With a bit of luck, you’ll promote yourself to the nice list, just in time for Christmas.

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