Feature Article Topic: Preparing the Annual Declaration on Compliance (ADC)under SRTOs 2025

The requirement for the CEO to submit an ADC is not an administrative task. It is a formal regulatory attestation about an RTOs current compliance position and the integrity of its training and assessment outcomes. Under ASQA’s self‑assurance approach and the SRTOs 2025, the declaration functions as a public statement of organisational control, governance maturity, and confidence in a Provider’s systems.

Each year, RTOs are typically required to submit the declaration by 31 March. The declaration is issued to the CEO via ASQA’s nominated contact arrangements. Failure to receive the notification does not remove the obligation to submit. It is the RTO’s responsibility to ensure that CEO contact details are current, monitored, and capable of supporting regulatory communications at all times.

Why the declaration matters more under SRTOs 2025

The SRTOs 2025 reinforce that compliance is not episodic and not audit‑driven. RTOs are expected to know whether they are compliant at any point in time and to be able to evidence how that assurance is formed. The ADC is therefore not a snapshot based on goodwill or confidence in staff. It is a confirmation that the organisation has reliable, current evidence demonstrating:

compliance across the entire scope of registration

integrity of AQF certification issued in the previous 12 months

training and assessment systems that meet the Standards in practice, not just on paper

From ASQA’s perspective, the declaration is a direct test of whether an RTO’s self‑assurance arrangements are operating as claimed. Where subsequent audits or investigations contradict the declaration, the issue is rarely framed as a technical oversight. It is framed as a governance failure.

CEO accountability is not symbolic

While compliance teams, quality managers, and consultants may support preparation of the declaration, accountability sits with the CEO. The declaration is made in the CEO’s name and reflects their reasonable assurance that the organisation meets its regulatory obligations.

This requires more than verbal confirmation from staff. CEOs should expect to draw on:

internal audit outcomes and validation data

systematic monitoring of training and assessment practices

complaints, appeals, and feedback trends

regulatory correspondence and prior audit findings

evidence of continuous improvement activities

If this information cannot be produced, analysed, and explained with confidence, the issue is not the declaration itself. It is the absence of a functioning self‑assurance system.

The risk of treating the declaration as a formality

A common misconception is that the declaration is simply a compliance tick and flick unless ASQA raises concerns. In practice, declarations are routinely used by ASQA to:

test the credibility of an RTO’s governance arrangements

assess whether known risks should trigger regulatory activity

compare declared compliance against audit outcomes and data intelligence

Inconsistencies between what is declared and what is later evidenced can escalate matters quickly. Under the SRTOs 2025, ASQA is less tolerant of explanations based on misunderstanding, reliance on third parties, or historic practices that no longer align with regulatory expectations.

Preparing the declaration: what mature practice looks like

Well‑governed RTOs do not prepare for the declaration in March. They arrive at March already knowing their position. In practice, this means:

compliance monitoring occurs throughout the year, not in response to deadlines

non‑compliances are identified early, addressed proportionately, and tracked to closure

leadership receives regular, intelligible assurance reports, not raw data dumps

decision‑making is informed by evidence, not assumption or optimism

Where gaps exist, they are acknowledged and managed, not obscured. The declaration does not require perfection. It requires honesty, insight, and control.

Using self‑assessment appropriately

Self‑assessment tools can be useful where assurance arrangements are immature or where leaders need visibility across complex operations. However, self‑assessment should not be treated as a once‑a‑year exercise to justify a declaration. When used properly, it feeds into an ongoing cycle of monitoring, review, and improvement.

If an RTO cannot complete a self‑assessment with confidence, or cannot interpret its own findings, that limitation itself signals a governance risk that should be addressed before the declaration is submitted.

A leadership obligation, not a compliance task

The CEO annual declaration of compliance is ultimately a statement about leadership. It reflects how seriously the organisation treats its regulatory obligations, its learners, and the integrity of the VET system.

Under the SRTOs 2025, ASQA expects RTOs to stand behind their declarations with evidence, insight, and accountability. Organisations that invest in genuine self‑assurance are rarely unsettled by the declaration process. Those that rely on hope, habit, or last‑minute checks increasingly find that the declaration becomes the start of regulatory scrutiny, not the end of it.