Now that Queensland’s Reportable Conduct Scheme (Scheme) has been in effect for 2 months, schools, education providers, not-for-profit organisations and other child-focused organisations have had an opportunity to move beyond implementation and assess how their compliance arrangements are working in practice.

Introduced under the Child Safe Organisations Act 2024 (Qld) and overseen by the Queensland Family and Child Commission (QFCC), the Scheme establishes a framework for reporting, investigating and managing allegations of reportable conduct involving workers.

While many organisations spent considerable time preparing policies, procedures and governance structures before commencement, the more important question now is whether those arrangements are operating effectively when real issues arise.

This is a useful time to pause and take stock of your organisation’s compliance position.

What should organisations be checking?

The Scheme applies to a broad range of organisations that provide services to children, including early childhood services, schools, student exchange programs, TAFEs, universities and registered training organisations.

For organisations operating across multiple campuses, entities or service locations, one practical question is whether reporting responsibilities are clearly understood. Have the appropriate decision-makers, reporting officers and investigators been identified? Is there a shared understanding of who is responsible for notifications, investigations and oversight?

Organisations should also consider whether staff are identifying reportable conduct consistently.

The Scheme covers allegations involving:

  • child sexual offences;
  • sexual misconduct;
  • ill-treatment of a child;
  • significant neglect of a child;
  • physical violence against a child; and
  • behaviour causing significant emotional or psychological harm to a child.

While certain conduct may be excluded in some circumstances, such as physical restraint, behaviour management, medical treatment or first aid, it is important to focus on the substance of the conduct rather than how it is described internally. Reviewing the way incidents have been assessed over the past 2 months can help identify any inconsistencies, uncertainty or training gaps.

Is your organisation’s approach working in practice?

The Scheme places primary responsibility on the head of the reporting entity (HRE), who is responsible for receiving and assessing allegations, implementing child safety measures, making notifications to the QFCC, overseeing investigations and reporting outcomes.

Two months into the scheme, organisations should consider whether the HRE has sufficient operational support and whether delegations, escalation pathways and leave coverage arrangements are functioning as intended.

Importantly, the definition of “worker” extends beyond employees and includes volunteers, contractors, trainees and work experience participants. Organisations should consider whether reporting obligations and training have been effectively communicated across the entire workforce and whether reporting pathways are understood by all worker categories.

Are notification processes operating effectively?

One of the most significant practical challenges under the Scheme is that reporting obligations may continue to apply even when other processes are underway.

This includes situations where:

  • police are investigating;
  • child protection authorities are involved;
  • the worker has resigned; or
  • the worker’s employment has already ended.

A common compliance issue is assuming that criminal investigations, employment processes or child protection interventions replace the organisation’s obligations under the Scheme.

Organisations should review whether their incident response processes adequately address these parallel obligations and ensure reporting requirements are not overlooked.

Could you meet the required timeframes?

The Scheme includes strict reporting deadlines, including:

Requirement Timeframe
Initial notification to the QFCC Within 3 business days
Investigator details provided As soon as practicable
Interim report Within 30 business days
Final report As soon as practicable following completion

 

Meeting these deadlines requires more than well-drafted policies. It requires clear workflows, assigned responsibilities, escalation processes and access to appropriate investigative resources.

A useful test is to ask whether the organisation could confidently respond to a reportable conduct allegation received today and comply with all reporting obligations within the required timeframes.

Where might gaps have emerged?

In many organisations, compliance challenges emerge not because policies are missing, but because implementation is inconsistent.

Child safety risk management remains an ongoing obligation throughout an investigation. Organisations must balance:

  • the protection of children;
  • procedural fairness to workers; and
  • the integrity of investigations.

Practical measures may include enhanced supervision, temporary changes to duties, restrictions on contact with children, suspension in appropriate circumstances and preservation of evidence.

This is a good opportunity to review whether risk management decisions are being made consistently and whether decision-making frameworks remain fit for purpose.

Organisations should also consider their approach to historical records and former workers. While conduct occurring before 1 July 2026 will often fall outside the Scheme, certain historical matters may still require assessment where new allegations or convictions emerge after commencement.  Historical records and investigation files should remain accessible and capable of supporting future assessments.

What should organisations do next?

The Scheme represents a significant shift towards proactive child-safe governance. Two months into its operation, organisations should focus not only on whether compliance frameworks exist, but whether they are working effectively in practice.

This is an ideal time to review lessons learned, test response capability, identify implementation gaps and refine existing processes. Regular reviews of governance arrangements, reporting pathways, investigation capability and record-keeping systems can help ensure organisations remain well-positioned to meet their obligations and respond confidently when issues arise.

If you would like assistance reviewing your organisation’s compliance arrangements under the Scheme, or responding to a reportable conduct allegation, please contact our team.