Understanding Your Legal Obligations as an RTO (Without the Jargon)
Quick Takeaways
- Credit Transfer is mandatory when the unit is current, identical, and authentic — even if the student asks to redo it.
- RTOs are not allowed to re-enrol students in units they’ve already completed with valid AQF certification.
- Clause 3.5 (Standards 2015) and Outcome Standard 1.7 (2025) strictly govern how RTOs must process CT.
What This Blog Covers
- ✔️ Real RTO scenario involving Cert III & IV in commercial cookery
- ✔️ When CT is mandatory (and when it’s not)
- ✔️ FAQs from students & RTOs — with clear answers
- ✔️ Tips to pass audit when CT gets reviewed
- ✔️ SEO-optimised compliance checklist
The Real-Life Story Behind the Blog
A client called me yesterday with this question:
“A student just finished Certificate III in Commercial Cookery and now wants to do Certificate IV in Kitchen Management. There are many matching units — but the student doesn’t want any credit transfer.
Can we let them re-enrol in those units anyway?”
I understood her concern — sometimes students think it helps to repeat a unit or want a refresher. But here’s what I told her (and what every RTO must know):
The Compliance Rule Is Crystal Clear
If a student provides:
- Authentic AQF certification documentation (e.g. a Statement of Attainment, USI transcript)
- A unit that is current and identical in code and title
… then you must issue a Credit Transfer. No exceptions.
No reassessment. No repeat training. No fee.
This is outlined in:
- Clause 3.5 of the [Standards for RTOs 2015]
- Standard 1.7 of the [2025 Outcome Standards]
Why You Can’t Let Students “Opt Out”
Even if a student asks to redo a unit, you must still record it as Credit Transferred if the unit qualifies. Repeating units could lead to:
- ❌ Non-compliance at audit
- ❌ Extended course durations (violating ESOS, VSL, or funded contracts)
- ❌ Charging for training already completed (breach of fee protection)
How to Handle the Situation
Here’s what I told my client to do — and what your RTO should have in place:
Credit Transfer Workflow:
- Collect evidence (e.g. USI transcript or certified Statement of Attainment)
- Verify the unit is current and identical
- Authenticate the document and issuing RTO
- Record Credit Transfer in the student file and training plan
- Exclude the unit from delivery, assessment and fees
FAQs: What RTOs and Students Ask (And What ASQA Expects)
❓“The student doesn’t want the CT. Can we ignore it?”
No. If the unit is valid for CT, you must apply it. Student preference doesn’t override compliance.
❓“The student wants to refresh their skills — can they just attend?”
No. You must not deliver, assess, or allow participation in a CT unit. It impacts the course duration, timetable, and creates audit risk.
❓“What if the unit code is similar but not identical?”
Then it’s not eligible for CT. You can consider RPL instead, which involves an assessment process.
❓“What if the issuing RTO is deregistered?”
It depends on why the RTO was deregistered:
- ✅ If due to business closure — CT may be valid.
- ❌ If cancelled for assessment non-compliance — you must use RPL, not CT.
❓“Can we give the full qualification via CT?”
No — CT can’t be used to issue a full qualification unless:
- The student has already completed all required units from other providers, and
- You verify all units and comply with issuance rules under the AQF and Standards.
Compliance Toolbox: Your CT Audit Checklist
Use this to confirm you’re ready for any audit:
| Item | ✅ Yes / No |
|---|---|
| Policy clearly outlines CT process | |
| Staff trained on mandatory CT rules | |
| Student files contain evidence of verified CT | |
| No CT unit appears in delivery/assessment schedule | |
| Student acknowledgment and CT recorded in plan |
Final Word
Credit Transfer is not a flexible “nice-to-have.”
It’s a nationally recognised requirement designed to ensure consistency, integrity, and fairness across Australia’s VET system.
If the unit is the same and the evidence is valid, Credit Transfer must be granted.
There is no room for negotiation — even from well-meaning students.
Disclaimer:
The information presented on the VET Resources blog is for general guidance only. While we strive for accuracy, we cannot guarantee the completeness or timeliness of the information. VET Resources is not responsible for any errors or omissions, or for the results obtained from the use of this information. Always consult a professional for advice tailored to your circumstances.
