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RTO Policies and Procedures Are Useless Without Compliant Practices

October 22, 2019

When embarking on a quest for compliance, the first thing that many RTOs want to do is write policy documents. They believe that once exhaustive RTO policy is written, they can be used to gleefully tick each and every compliance box on ASQA’s list, and the audit will be successful. While RTO policies and procedures may have been the focus for ASQA a few years ago, their processes are now different.

Auditors used to have a list of policies and procedures that they wanted to see reflected in an RTO’s day-to-day, based on the Standards for RTOs 2015. In the weeks leading up to an audit, RTOs scramble to write policies and procedures to meet the standards, often without consideration for the actual processes that staff are following. Today, there’s still frantic scrambling, but the audit focus has changed. Instead of examining your policies and procedures, auditors want to see compliance through your practices. They want clear evidence that your day-to-day operations align with their standards. They don’t care about what you say, they care about what you do. Comprehensive RTO policies and procedures provide a solid framework of rules for staff, but if they don’t reflect compliant practices, they’re useless.

Many RTOs seem to think that once policies are written, neatly typed and filed away in some dark virtual corner, they’re all set. Unfortunately, arcane RTO policies and procedures won’t help them pass their audit. Evidence of compliant practice will. Writing policy before forming practices is like trying to learn to swim by writing about it. No amount of fancy words or well-composed sentences are going to teach you to swim, just as no document can train your RTO to be compliant.

Compliant practices are the starting point, with policies and procedures to follow. Once everything is in place, and your RTO policies and procedures are based on compliant practices, you’ll be able to clearly demonstrate compliance to auditors. When the madness of the audit is over, and ASQA policy has been satisfied, all that’s left to do is raise a glass!


Special thanks to VET Gurus Angela McGregor and John Price, for their input and assistance with the article.

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