ASQA Risk Priorities 2026–27: What Has Changed and What Your RTO Should Do

A training plan can look complete. An assessment file can contain every signature. A management report can say that everything is on track.

But there is still an important question: 

Does the evidence show that students received the training they needed and genuinely demonstrated the required skills? 

With 16 years in the Australian vocational education and training sector, I approach RTO compliance through that question. My advice is to look beyond whether a document exists and examine whether the process behind it works. 

ASQA’s 2026-27 risk priorities provide a useful starting point. They bring attention to how RTOs are managed, whether training develops the intended skills, whether qualifications can be trusted, and whether providers maintain control over delivery involving other organisations.

This article explains what has changed, what the terminology means and what I recommend RTO owners and managers examine. 

The practical checks below are recommendations, not an ASQA-prescribed checklist. Examples are illustrative rather than accounts of particular clients. 

What are ASQA risk priorities? 

A risk is something that could go wrong and affect students, staff, the organisation or confidence in qualifications. 

A risk priority is an area ASQA has identified for particular regulatory attention, based on research, information and consultation. The priorities help explain the problems ASQA considers significant across the sector.

They are not a separate set of RTO Standards. Your obligations under the applicable legislation and Standards continue; the priorities identify important risks within that regulatory environment.

My recommendation is to use them as a management question:
Where could this problem occur in our RTO, and what evidence would tell us whether it is happening? 

ASQA risk priorities: 2025-26 compared with 2026-27 

ASQA identified six interconnected priorities for 2025-26. Its 2026-27 framework contains four interconnected themes.

The table below is my practical comparison, not an official ASQA mapping. Earlier headings are shortened for readability, and some risks connect with more than one current theme.

These connections draw on ASQA’s archived priorities and the four current priority descriptions.

What has genuinely changed? 

The grouping is broader and makes the connections between problems more visible. 

For example, an unsuitable short course may involve more than a timetable problem. Consider an illustrative situation where recruitment staff promise rapid completion, management approves the model without checking capacity, students receive little practice, and assessors face pressure to record successful outcomes. 

I would examine that situation across recruitment, management, training and assessment – not allocate it to one department and assume the rest of the RTO is unaffected. 

Some concerns are more explicit in the current wording. Governance, training suitability, learner support and oversight across delivery arrangements have prominent positions in the current themes. That does not mean these responsibilities began in 2026-27.

Existing risks have not disappeared. RPL misuse and unreliable workplace evidence remain expressly identified. AI-related cheating is not an entirely new concern either: ASQA discussed AI in the previous year’s academic-integrity material.

Why should your RTO prepare before an audit? 

There is a direct compliance reason. Standard 4.3 requires risks to students, staff and the organisation to be identified and managed. ASQA’s guidance specifically identifies failing to consider its regulatory risk priorities in the context of an RTO’s operations as a risk to quality outcomes.

There is also a practical business reason. 

Imagine finding a weakness in an assessment tool before it is used. Now imagine finding the same weakness after several groups of students have completed it. 

The second situation raises additional questions: Which decisions were affected? How far does the problem extend? What needs to happen for those students? 

That is why I recommend preparing to find and address problems early, rather than preparing only to explain them during an audit. 

Preparation should also help management decide where to invest. A new policy may not be the answer when the underlying problem is insufficient trainer time, unsuitable equipment or a partner that cannot provide reliable evidence.

Priority 1: Is your RTO being managed responsibly? 

ASQA’s title: “Provider governance, market conduct and non-genuine operations.” The priority covers deliberate misconduct and management weaknesses that allow harmful practices to develop or remain hidden.

What do those words mean? 

The practical question is:
Could somebody make an important decision affecting students without the right person knowing, checking or challenging it? 

What I recommend checking – and why 

Priority 2: Is your training suitable – and is there enough of it?

ASQA’s title: “Quality, sufficiency and fitness-for-purpose of training delivery.” This concerns situations where training happens, but is inadequate or unsuitable for developing the intended skills.

What does “fit for purpose” actually mean? 

Here, fitness means suitability. It does not mean physical fitness. 

Purpose means the result the training is intended to achieve. 

So, fit for purpose means suitable for achieving the required learning outcome, for the students undertaking the training and in the conditions in which it is delivered. 

In everyday language: 
Will this course, delivered this way, give these students a proper opportunity to develop the required skills? 

Quality asks how well the training works.

Sufficiency asks whether there is enough training, practice, feedback and support. 

These questions are related, but they are not identical. A course could contain useful teaching but insufficient practice. Another could run for many weeks without using that time effectively. 

Standard 1.1 requires training to be structured and paced so students have sufficient time for instruction, practice, feedback and assessment.

My six-question “fit-for-purpose” check 

This is a suggested review method, not a regulatory checklist. 

What does “contextualised” mean? 

It means adapted to the relevant situation. 

For example, a customer-service activity for a hospitality setting could use realistic hospitality interactions. Instructions should also match the equipment and arrangements students will actually encounter. 

It does not mean removing required skills, lowering the standard or changing a logo and calling the resource suitable. 

ASQA’s assessment guidance addresses adapting materials to students and the work context while maintaining training-product requirements. It also requires assessment tools to be reviewed before use and necessary changes to be made.

Do not overlook support and inclusion

The current priority includes readiness, support, cultural safety and access – not just course duration.

When discussing language, literacy, numeracy and digital skills, explain them plainly: communicating, reading and writing, working with numbers, and using the technology needed for the course. 

My recommendation is to connect each identified need with an actual response. Who will help? What will they provide? How will you check whether it helped? ASQA’s support guidance addresses access to relevant assistance throughout training.

For cultural safety and equitable access, examine whether students feel respected and whether avoidable barriers prevent participation. Giving everyone the same materials is not, by itself, a test of whether everyone can use them effectively. ASQA expressly includes these concerns in this priority.

My practical test: a completed support form should lead to a support decision – not simply another document in the student’s file. 

Priority 3: Can the qualification and assessment evidence be trusted? 

ASQA’s title: “Integrity of qualifications and competency outcomes.” The focus includes cheating, fabricated records, AI-enabled fraud, misuse of RPL and unreliable workplace evidence.

What do those words mean?

The practical question is: 
Can the assessor explain why this particular student was judged competent? 

What I recommend checking – and why

Start with the evidence, not the completion status. 

Select completed assessments and examine what supports the result. 

The four rules of evidence can be expressed as these questions:

These are summaries of the rules under Standard 1.4, not replacement definitions.

I recommend asking the assessor to show how the evidence supports the decision. That is a more useful conversation than asking only whether every field has been completed.

Connect submitted work with the student’s own capability. 

Depending on the task, consider follow-up questions, observation and appropriate verification of workplace evidence. 

For example, ask a student to explain a decision in their submitted work or respond to a changed situation. Any additional check should suit the assessment requirements and the student’s needs. 

The aim is to establish confidence in the evidence – not to create unnecessary barriers. 

For AI, make task instructions clear about permitted assistance. My recommendation is to investigate concerns fairly rather than treating a software score as a complete assessment decision. 

Keep RPL as an individual assessment process. 

Recognition of prior learning means assessing skills and knowledge a person has already developed, rather than requiring them to repeat learning unnecessarily. 

It remains a legitimate pathway. ASQA’s RPL guidance expects evidence-based, documented decisions and the same assessment rigour as other pathways. 

A resume may identify experience worth investigating. It should not automatically settle every competency question. 

Where evidence reveals gaps, work out what additional evidence, assessment or training is needed. Gap training means training directed at the skills or knowledge the person still needs. ASQA’s guidance specifically addresses identifying and responding to RPL gaps. 

Use validation to examine decisions, not just documents. 

Assessment validation is a structured quality review of assessment practices and judgements. 

In plain language: appropriately qualified people examine whether the assessment process and resulting decisions are sound. Standard 1.5 addresses this process and how findings inform changes. 

My recommendation is to ask the review team: 
“What did we learn about the decisions being made – and what changed because of that finding?”

Priority 4: Do you know what your partners are actually delivering? 

ASQA’s title: “Transparency, accountability and assurance in complex and international delivery models.” The concern is that complicated arrangements can make it harder to see what happens, identify responsibility and verify quality.

What do those words mean? 

ASQA identifies offshore and partner delivery, weak checking and monitoring, and reliance on intermediaries as concerns. It also recognises that risk can arise through complexity rather than deliberate wrongdoing. 

What I recommend checking – and why 

Draw the arrangement before reviewing the contract. 

Map who recruits, trains, assesses, provides support and holds records. 

Then ask: Who handles a complaint? Who can access the original evidence? Who approves a change in delivery? 

This can expose a responsibility gap that is difficult to see when reading documents separately. 

Check capability before relying on promises. 

This is often called due diligence. It means making reasonable enquiries and verifying important information before committing to an arrangement. 

I recommend examining actual staff availability, facilities, systems and delivery capacity – not just what appears in a proposal. 

ASQA’s accountability guidance includes checking a third party’s capability and capacity before engagement.

Use the agreement – and check the service. 

Where the applicable third-party requirements apply, a written agreement and required notifications are necessary. But outsourcing does not remove the RTO’s compliance responsibilities.

My suggested monitoring could include speaking with selected students, reviewing underlying assessment evidence and checking how complaints were handled. 

For example, if a partner reports that every student completed an activity, examine selected records supporting that statement. This tests whether the report can be relied on.

A signed agreement explains what should happen. Monitoring helps establish what actually happened. 

Where should your RTO start? 

I would begin with a manageable review of a course or arrangement where the potential consequences of failure are significant. 

Follow a student’s experience from recruitment to completion. Compare the promises, training activities, assessment evidence and final result. 

Then turn findings into actions. 

There is no universal sample size or completion deadline proposed here. Choose a scope and response appropriate to the risk; serious concerns should not wait for a routine review cycle. 

ASQA’s continuous-improvement guidance includes checking practice after changes have been implemented.

I would not close an action merely because a policy was updated. I would close it when there is a sound basis to conclude that the required change has occurred. 

Common questions from RTO owners and managers 

My final advice: examine the experience behind the paperwork 

Do not begin by asking your team to produce more documents. 

Begin by asking them to show you how a student learns, receives support, demonstrates competence and reaches an outcome. 

Where the evidence is strong, understand what makes the process work. Where it is weak, investigate before making assumptions. 

For me, the most useful question is: 

“What do we know is working – and what have we only assumed is working?” 

Use that question in your next management meeting. Choose one area, examine the evidence and agree on the next action. 

That is a practical way to turn ASQA’s priorities into decisions that support students and strengthen your RTO. 

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