The RTO Marketing Compliance Mistake That Could Cost You up to $50,000 — and How to Avoid It

If you’re a Registered Training Organisation (RTO), you’re expected to meet strict regulatory standards in everything you do — including your marketing.

But there’s one key area most RTOs overlook.

And it could be costing you more than you think.

The Problem: Most RTOs Think Their Marketing Is Compliant — Until It Isn’t

We’ve recently conducted compliance audits across a range of RTO clients. Across websites, brochures, social media pages, and agent listings, we found consistent issues that could lead to serious non-compliance findings.

Here’s what we discovered:

• Outdated course durations that no longer match the National Register
• Old fee information still visible on marketing pages
• Incomplete or misleading training and assessment descriptions
• Superseded courses still appearing on the site or in brochures
• Missing updates required by the 1 July 2025 standards (e.g. student handbook, LLND procedures, complaint handling)

Often, providers had updated their internal training documents but had missed their public-facing content — leaving them exposed to regulatory action.

Superseded Courses Must Not Be Marketed — Even Accidentally

Even if you’re not enrolling students, simply having an old course still visible on your website or brochures can be considered a breach.

Many RTOs are unaware that:

• Google may still index and display deleted pages
• Archived PDFs are often still accessible via direct link
• Affiliate or agent websites may use outdated materials
• Social media posts promoting superseded courses may still be circulating

This is what ASQA refers to as systematic misrepresentation — and it can carry penalties of up to $50,000. I saw an email from RTO Doctor related to the same issue.

What ASQA Looks For Under Standard 2.1

Clause 2.1 of the Standards for RTOs requires that all marketing and course information provided to prospective students is accurate and not misleading.

This applies to:

• Websites
• Printed and digital brochures
• CRICOS listings
• Emails, ads, and SMS marketing
• Third-party or agent promotions

If any detail — even one — contradicts your actual scope of registration, you could be deemed non-compliant.

Your Two-Part Marketing Compliance Solution (Made Simple)

Part 1: The 2–3 Business Day Update Rule

Any time there is a change to your:

• Scope of registration
• Training product status
• Delivery method
• Fees or funding eligibility
• Enrolment requirements
• Key policies (e.g. LLND testing, refunds)

You must update all public-facing materials — including your website, course flyers, student handbook, and agent materials — within 2 to 3 business days.

✅ Tip: Keep a log of what was updated, by whom, and when. This becomes critical evidence during audits.

Part 2: Monthly Marketing Compliance Audit

Set up a recurring calendar event every month to review all marketing channels:

Even one mismatch can trigger a compliance breach.

Frequently Asked Questions (FAQs)

1. How much can ASQA fine an RTO for incorrect marketing?

Up to $50,000, especially if it’s considered systemic or misleading under Standard 2.1.

2. Can I leave old course pages live if I mark them as “archived”?

No. Even if you label it archived, ASQA expects superseded training products to be fully removed from public view.

3. What if my internal documents are correct but the website isn’t?

It still counts as non-compliance. The Standards focus on what is visible to prospective students, not just internal accuracy.

4. What tools can help with monthly audits?

• Use Google Search Console to find indexed pages
• Tools like Screaming Frog can scan for outdated URLs
• Use a spreadsheet or checklist to track updates across all platforms

5. How do I manage agents using outdated brochures?

Include a clause in your third-party agreement requiring monthly marketing sign-offs. You remain accountable under Clause 2.3.

6. Is it enough to update the website?

No. You also need to update:

• Course flyers and downloadable PDFs
• Social media posts
• CRICOS course listings
• Marketing sent by agents or partners

7. What should my student handbook include after 1 July 2025?

It must outline:

• LLND assessment process (pre-enrolment)
• Fees and refunds
• Support services
• Complaint and appeal processes
• Training and assessment strategies

8. How can I prove updates to ASQA?

Maintain an audit trail:

• Screenshots of updates
• CMS logs or email confirmations
• Update checklist signed by compliance manager

9. What if we miss a change by a few days?

If ASQA sees effort, a system, and evidence of follow-through, they may accept minor delays. But repeated lapses or missing updates over weeks/months is what leads to findings.

RTO Marketing Audit Checklist (Quick Reference)

Here’s a simplified checklist you can start using immediately:

Want a Ready-Made Template?

We’ve created a downloadable Monthly RTO Marketing Compliance Checklist based on:

• ASQA’s current Standards
• The revised 2025 requirements
• Real audit findings across multiple RTOs

✅ Use it for internal compliance
✅ Provide it to your agents
✅ Show it to ASQA during audits

👉 Just comment or message “Send Checklist” and we’ll send it straight to your inbox.

Final Thoughts

RTO marketing compliance isn’t about fancy design — it’s about accuracy, consistency, and evidence.

By implementing a 2–3 business day update rule and running a monthly audit, you can stay ahead of the curve, avoid penalties, and build trust with your students and regulators alike.

Let your marketing reflect the quality of your training — and let us help you keep it that way.