Feature Article Topic: What ASQA Is Really Looking For In Your Annual Declaration of Compliance Responses.

Many RTOs still approach the The Annual Declaration on Compliance (ADC) as a routine administrative task. That assumption is increasingly risky. ASQA have made it clear in recent sector briefings that the ADC is not a formality – it is regulatory intelligence.

With more than 3,800 providers delivering VET to over five million students, regulatory scrutiny is intensifying. Since July 2025, only 62% of assessed providers have met the compliance benchmark, and ASQA has received over 7,200 tip-offs since late 2023. Investigations, monitoring activities, and qualification cancellations are all increasing.

Against that backdrop, the ADC is one of the ways ASQA identifies where to look next.

The ADC Is a Regulatory Signal

ASQA does not simply collect ADC responses. It analyses them for patterns, authenticity and risk indicators.

Responses are cohort-profiled across the sector. Previous ADC submissions are reviewed during regulatory assessments. Even behavioural signals are visible, such as providers who submit declarations minutes after opening the form. In one example highlighted to the sector, 42 providers submitted their ADC within five minutes of opening it. ASQA have interpreted that as a red flag. The regulator’s advice to RTOs was simple: be genuine in your responses, not perfect.

Where ASQA Is Seeing Risk

According to ASQA, across recent Performance Assessments, four recurring weaknesses are driving most regulatory findings.

Assessment quality remains the most common issue, with 76% non-compliant findings. ASQA continues to see poorly aligned assessment tools, knowledge-only approaches, inappropriately clustered units, inconsistent assessor decisions and academic integrity gaps.

Training quality appears in 63% non-compliant findings. Common problems include unrealistic course durations, delivery models that do not suit the cohort, and online delivery used where it cannot genuinely achieve competency outcomes.

Continuous improvement is another persistent weakness, present in 57% of non-compliances. Too many providers rely on reactive reviews or generic templates rather than systematic monitoring and analysis of performance.

Trainer and assessor suitability appears in 56% of non-compliant findings. ASQA continues to identify gaps in competency verification, professional development and industry currency.

These areas map directly to the Outcome Standards declared in the ADC.

When CEOs confirm compliance, they are effectively declaring confidence in these systems.

Authenticity Matters

ASQA also issued a clear warning about AI-generated ADC responses in its recent workshops.

The issue is not the technology itself. The concern is generic answers that do not reflect the provider’s real operations. Regulators are already identifying submissions containing visible AI prompts or templated language. Their messaging was direct: authentic responses are both expected and verifiable.

The Real Test

Ultimately, the ADC tests whether organisational leadership genuinely understands its compliance position.

The declaration sits within a broader regulatory framework that includes the NVR Act, the ESOS Act for CRICOS providers, and the 2025 Standards for RTOs. ASQA assesses against all of them.

A thoughtful ADC submission demonstrates something ASQA values: an RTO that understands its risks and is actively managing them.

In that sense, the strongest declarations are rarely the ones claiming perfection. They are the ones that demonstrate awareness, honesty and governance maturity.