Registration is the start of regulatory scrutiny, not the end of it. In the first 24 months a new RTO cannot add training products to its scope, must deliver training or assessment to keep its registration, and must meet annual obligations, including the Annual Registration Charge and the Annual Declaration on Compliance. This article sets out what applies in those two years and how to stay audit-ready.
You cannot expand scope straight away
Newly registered RTOs cannot apply to add training products to their scope until they have been registered for 24 months (ASQA: apply for registration). Your first scope is your scope for two years, so carefully choose the training products that align to the businesses first 2 years of intended operations.
Training and assessment activity
Training or assessment must be delivered to maintain registration. An RTO that is inactive for 12 months without an approved reason will have its registration cancelled.
Licensing claims need confirmation
RTOs must not tell learners they will be eligible for a licence or accreditation unless the issuing authority has confirmed it. Licensing requirements can also be additional to the training package or accredited course requirements. Any such claims must be supported in writing by the licensing or accreditation bodies.
Annual obligations
- Annual Registration Charge: invoiced each July, based on qualifications on scope and student numbers (ASQA).
- Annual Declaration on Compliance: ASQA emails RTO CEOs a unique link each year. Usually required by the 31 March.
- Standards compliance: a newly registered RTO is required to apply for renewal no less than 90 days before the expiry date, which is 2 years from initial approval. This application will require demonstrating compliance with the Standards for RTOs 2026 in an audit.
What follows the initial period
Successful reregistration will usually result in a 7 year registration.
A first-two-years checklist
- Enrol learners and deliver training within the first 12 months.
- Gather evidence continuously against the Standards for RTOs 2025.
- Develop and implement a self-assurance strategy and retain evidence of improvements implemented.
- Develop a calendar of important dates including the annual invoice in July, the annual declaration, Total VET Activity report in February, QI data submission in June and the date at which you will submit your intention to renew.
Planning to apply for RTO registration? RTO Consulting can help you prepare an application that is complete and compliant the first time.
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