NQF Changes 2025–2026: What Australian Childcare Services Need to Do Right Now

The National Quality Framework has undergone its most significant set of changes in years, with reforms rolling out in three distinct phases from September 2025 through to early 2026. These changes affect every approved provider and every service type across Australia, covering child safety policies, incident reporting, staff registers, and governance obligations. If you are an approved provider, nominated supervisor, or OSHC coordinator, this guide covers every change, what it requires of you, and what your documentation needs to show.

Why the NQF Changed: The Child Safety Review

These reforms follow a comprehensive review of child safety arrangements under the NQF, published by ACECQA in December 2023 at the request of Education Ministers. The review examined how existing regulations and the National Quality Standard (NQS) were working to protect children, and where stronger safeguards were needed.

Education Ministers agreed to a staged package of reforms in response. The intent is clear: child safety is no longer just one consideration among many. It is the paramount obligation of everyone operating or working in an education and care service in Australia.

The changes have been implemented in three phases.

Phase 1: Changes from 1 September 2025

Digital Technology Policies Are Now Mandatory

From 1 September 2025, all approved services must have a written policy and procedure covering the safe use of digital technologies and online environments. This is a new requirement under Regulation 168 (Education and care service must have policies and procedures) of the Education and Care Services National Regulations (the National Regulations), and it applies to every service type, including OSHC, long day care, family day care, kindergarten, and preschool.

Regulation 168(2)(ha) specifies that the digital technology policy must address each of the following:

The taking, use, storage, and destruction of images and videos of children. Your policy must document exactly how photos and videos of children are captured at your service, what they are used for, where they are stored, how long they are retained, and how they are permanently destroyed when no longer needed.

Obtaining permission and authorisation from parents and guardians. The policy must set out how your service obtains authorisation from families before taking, using, or sharing images or videos of their children. Existing enrolment consent forms should be reviewed to confirm they meet this requirement.

The use of digital devices by children at the service. This covers how children are permitted to access and use devices such as tablets or computers, including any restrictions, supervision expectations, and age-appropriate considerations.

The use of any digital devices issued or owned by the service. If your service provides devices such as cameras, tablets, or computers for educator use, the policy must address how these are managed, who has access, and how they are stored when not in use.

The use of optical surveillance devices. If your service uses CCTV or any other optical surveillance equipment, the policy must address how it is operated, who can access footage, how long footage is retained, and how privacy is protected.

Beyond these five specific sub-items, the broader heading of Regulation 168(2)(ha) also requires that your policy address the safe use of online environments at the service generally. This means addressing how children are supervised when using the internet at the service and what protections are in place against inappropriate content or contact.

ACECQA released a voluntary National Model Code and Guidelines in July 2024 to support services in developing child-safe practices around taking, sharing, and storing images and videos of children. Services are encouraged to consult this alongside your state or territory regulatory authority guidance when drafting your policy.

What your documentation needs to show: A written policy document covering all of the above areas, evidence that educators and staff have read and understood the policy (such as a signed acknowledgement record), and records showing the policy has been shared with families.

Incident Notification Timeframes: Now 24 Hours

From 1 September 2025, if a child in your care is the subject of an allegation, complaint, or incident of physical or sexual abuse, you must notify your regulatory authority within 24 hours.

This is a significant tightening of the previous requirement, which allowed seven days for notification. The change reflects the seriousness with which Education Ministers are treating child safety reporting, and aligns education and care services more closely with mandatory reporting obligations in other children's services sectors.

This applies to:

• Allegations of physical or sexual abuse against a child at the service
• Complaints of physical or sexual abuse involving a child at the service
• Incidents of physical or sexual abuse that occur at the service or in connection with its operation

What your documentation needs to show: A clear record of the date and time you became aware of an incident or allegation, the date and time you notified the regulatory authority, and the content of that notification. Your incident response procedures should be updated to reflect the 24-hour requirement.

Vaping Prohibition

From 1 September 2025, services must ensure children are provided with an environment free from the use of tobacco, vaping devices, vaping substances, illicit drugs, and alcohol. This is set out in Regulation 82 (Environment to be free from tobacco, vaping devices, vaping substances, drugs and alcohol) of the National Regulations. The regulation already prohibited tobacco, drugs, and alcohol; the 2025 amendment formally added vaping devices and vaping substances.

This applies to staff, parents, visitors, and anyone else on the premises or in connection with the service.

If your smoke-free policy did not already reference vaping devices and vaping substances, it must now be updated. Display your updated policy in visible areas of your service.

Phase 2: NQS Refinements from 1 January 2026

From 1 January 2026, refinements to the National Quality Standard took effect, sharpening the focus on child safety within Quality Area 2 (Children's Health and Safety) and Quality Area 7 (Governance and Leadership). These are not wholesale rewrites but targeted amendments that make existing child safety obligations more explicit and enforceable.

Quality Area 2: Element 2.2.3 Is Now "Child Safety and Protection"

Element 2.2.3 has been renamed from its previous wording to Child Safety and Protection. The updated element states:

Management, educators and staff are aware of their roles and responsibilities regarding child safety, including the need to identify and respond to every child at risk of abuse or neglect.

This is a significant shift in emphasis. The element now requires that everyone in your service, from the approved provider through to casual staff, can demonstrate awareness of their specific child safety responsibilities. It is not sufficient for a policy to exist. Authorised officers will be looking for evidence that the policy is understood and acted upon.

What your documentation needs to show under Element 2.2.3:

• Written child safety policies and procedures that clearly describe everyone's roles and responsibilities
• Records of child safety training completed by all staff
• Incident records and critical reflections showing how concerns were identified and responded to
• Evidence that child safety is discussed in staff meetings and supervision conversations
• Records of how the service has communicated child safety expectations to families

Quality Area 7: Governance Must Now Explicitly Support Child Safety

Standard 7.1 (Governance) and Element 7.1.2 have been refined to explicitly reference child safety within governance and leadership. The updated language confirms that well-documented policies and practices, developed and regularly evaluated in partnership with educators, coordinators, staff members, and families, contribute to the ethical management of a quality service that is child safe.

In practical terms, your governance structures, including committee meeting minutes, policy review processes, and leadership decision-making records, should now visibly incorporate child safety as a standing agenda item and a governance priority.

What your documentation needs to show under QA7:

• Governance documents (constitution, position descriptions, policies) that explicitly reference child safety obligations
• Committee or board meeting minutes that include child safety as a standing item
• Evidence that policies are reviewed regularly and that reviews are documented
• Records of leadership decisions that demonstrate the paramountcy of children's safety and best interests

Phase 3: Changes from 27 February 2026

The National Early Childhood Worker Register

From 27 February 2026, all approved providers must use the National Early Childhood Worker Register, built by ACECQA within the National Quality Agenda IT System (NQAITS). The Register gives regulatory authorities a national, consolidated view of people working in education and care services, supporting the identification and management of risk across the sector.

Staff notification obligations also commence from this date. Educators and staff must notify their approved provider in writing if they receive a negative Working with Children Check notice from any jurisdiction, or if there is a change to their teacher accreditation or registration. For both situations, staff must do this within 72 hours of the event occurring, or within 24 hours of becoming aware of the change, whichever is sooner. Approved providers must in turn notify their regulatory authority if they become aware of a negative WWCC outcome for any educator or staff member.

Mandatory National Child Safety Training

From 27 February 2026, all staff, volunteers, and students in early childhood education and care must complete mandatory national child safety training. The training has been developed by the Queensland Government and the Australian Centre for Child Protection, and is available on Geccko, the Australian Government Department of Education's online learning platform for the ECEC sector, at geccko.gov.au.

The training is structured in two tiers:

Foundation modules are currently available on Geccko. All relevant personnel must complete Foundation training by 27 August 2026. This is a firm national deadline.

Advanced modules become available from July 2026.

This national training does not replace existing state and territory child protection training requirements. You should check with your state or territory regulatory authority to confirm what additional training is required in your jurisdiction.

What your documentation needs to show: A register of all staff, volunteers, and students at your service, records of training completion with dates, and a documented plan for ensuring compliance with the 27 August 2026 Foundation training deadline.

The Paramountcy Principle

The reforms have established a paramountcy principle: the safety, rights, and best interests of children must be the paramount consideration for every person involved in the operation and delivery of education and care services. This includes approved providers, nominated supervisors, educators, staff, volunteers, and students.

The principle means that children's best interests take precedence over the financial interests of the approved provider, contractual obligations, and any other competing considerations. Where services are making significant decisions, including decisions about staffing, enrolment, risk management, or incident response, records should document how the paramountcy principle informed that decision.

What Approved Providers Need to Do Right Now

Use this checklist to audit your compliance across all three phases.

September 2025 phase:

• [ ] Write and implement a digital technology policy covering all required areas under Regulation 168(2)(ha)
• [ ] Brief all educators and staff on the policy and record their acknowledgement
• [ ] Communicate the digital technology policy to families
• [ ] Update your incident reporting procedures to reflect the 24-hour notification requirement
• [ ] Update your environment policy to explicitly reference vaping devices and vaping substances under Regulation 82

January 2026 phase:

• [ ] Review your child safety policies to ensure they describe everyone's specific roles and responsibilities, aligned with updated Element 2.2.3
• [ ] Add child safety as a standing agenda item to governance meetings
• [ ] Update governance documents (constitution, position descriptions, policies) to explicitly reference child safety
• [ ] Document how leadership decisions reflect the paramountcy of children's safety and best interests

February 2026 phase:

• [ ] Ensure your service is operating within the National Early Childhood Worker Register processes through NQAITS
• [ ] Enrol all staff, volunteers, and students in the Geccko Foundation training modules
• [ ] Create a training completion register and set a target completion date before 27 August 2026
• [ ] Update your staff notification procedures to include the 72-hour WWCC and accreditation change notification requirements

How One Child Supports Your NQF Documentation

While the NQF changes described in this article — digital technology policies, child safety training, and governance obligations — require their own management processes, the overall NQS assessment picture depends heavily on the quality of your educational program documentation. Authorised officers assess Quality Area 1 alongside Quality Areas 2 and 7, and services with robust, organised documentation are demonstrably better placed when an assessment visit occurs.

One Child is designed to make that educational documentation straightforward.

Photo and media consent is built directly into the platform. Parents can opt out of photo sharing for their child, and that consent status is visible to educators every time they create an observation. This supports the requirement under Regulation 168(2)(ha) to have documented processes for obtaining authorisation from families before taking, using, or sharing images or videos of children.

Observations are the core of the platform — rich narrative records of children's learning and play, linked directly to EYLF v2.0, MTOP v2.0, QKLG, or custom framework outcomes. When an authorised officer asks to see evidence that your educational program is responsive to children's interests and development, your observation records are what you show them. One Child keeps all of that in one place, retrievable by child, by outcome, or by date.

Planning documents can be linked to observations as evidence that planned activities were carried out. This two-way connection between what you intended and what actually happened is exactly the kind of documentation trail that supports QA1 Standard 1.2 (Practice is informed by an understanding of individual children's development and learning).

Reflections can be attached to any observation or plan, or created as standalone records. Educator reflections on practice are the primary evidence for QA1 Element 1.3.2, which requires that critical reflection on children's learning and development, both as individuals and in groups, is used to drive continuous improvement.

Child portfolios aggregate every observation, plan, note, and reflection linked to a child into a single view, with PDF export. Having a complete, organised record per child means your documentation is audit-ready rather than scattered.

The AI writing assistant helps educators produce more professional, curriculum-aligned observations — particularly useful for OSHC and long day care teams where writing quality varies across staff.

If your current documentation system is making it harder to demonstrate the quality of your program, you can try One Child free for 14 days.

Frequently Asked Questions

Do all service types have to comply with the September 2025 digital technology policy requirement? Yes. The requirement applies to all services approved under the Education and Care Services National Law, including long day care, OSHC, family day care, kindergartens, and preschools.

Our service already had a social media policy. Does that satisfy the Regulation 168 requirement? Not automatically. A social media policy typically covers a different and narrower scope than the digital technology policy required under Regulation 168(2)(ha). Review your existing policy against the specific sub-items listed above and update it to address any gaps.

What counts as a child safety incident that requires 24-hour notification? The 24-hour notification requirement applies to allegations, complaints, and incidents of physical or sexual abuse involving a child in connection with the service. The notification must go to your state or territory regulatory authority. If you are unsure whether a specific situation triggers the requirement, contact your regulatory authority directly.

Do staff who completed child protection training through their state or territory also need to complete the Geccko national training? Yes. The national training from 27 February 2026 is a separate requirement and does not replace existing state and territory child protection training obligations. Both are required. Check with your regulatory authority for the full list of requirements in your jurisdiction.

Is the National Early Childhood Worker Register publicly searchable? The Register is operated by ACECQA within NQAITS and is designed primarily for use by regulatory authorities to monitor risk. For the most current information about what information is stored and who can access it, refer to the ACECQA website.

How do the Quality Area 7 changes affect parent-run committee services? Committee-governed services need to ensure that committee members understand their child safety governance obligations under the updated Standard 7.1. Committee meeting minutes should reflect child safety as a standing agenda item, and position descriptions for committee roles should explicitly reference child safety responsibilities.

For further information on these changes, visit ACECQA's child safety page or contact your state or territory regulatory authority.

References

1. ACECQA. NQF child safety changes from 1 September 2025 and 1 January 2026 (Information Sheet). Australian Children's Education and Care Quality Authority.

2. ACECQA. Child safety: what is changing? Australian Children's Education and Care Quality Authority.

3. ACECQA. National Model Code and Guidelines: Taking, sharing and storing images or videos of children in ECEC (July 2024). Australian Children's Education and Care Quality Authority.

4. Australian Government Department of Education. National Quality Framework.

5. NSW Department of Education. Child safety reforms.

6. SA Education Standards Board. National child safety reform and regulatory changes.

7. Education and Care Services National Regulations, Regulation 168 (Education and care service must have policies and procedures).

8. Education and Care Services National Regulations, Regulation 82 (Environment to be free from tobacco, vaping devices, vaping substances, drugs and alcohol).

9. Australian Government Department of Education. Geccko — online learning platform for the ECEC sector.