ASQA have updated their top areas of concern

This week, the National VET Regulator - ASQA - updated the VET sector on the top areas of concern during performance assessment (audit).

In March and again in May 2026, the list of the Top 4 went as follows:

1. Poor quality assessment systems or practices

2. Poor quality training

3. Continuous improvement

4. Unsuitable or unqualified trainers and assessors

Slide from an ASQA update session, March & May 2026

In September 2026, the list of the Top 5 is:

1. Unsuitable or unqualified trainers and assessors

2. Ineffective or unsuitable organisational leadership

3. Ineffective assessment validation

4. Poor quality RPL

5. Poor quality assessment systems or practices

Slide from an ASQA update session, September 2026

What does this tell us?

ASQA are following leads on areas of issue and finding more issues. Concerningly, being taught by an unqualified/unsuitable trainer/assessor can only lead to fast-growing cancer within the sector and further decay of VET's reputation as a viable pathway into post-secondary education.

If the trainer/assessor does not meet requirements, neither will any of their teachings and/or assessment judgements. Which, when you extrapolate out, means a domino effect for anyone who is issued AQF certification documentation as an outcome of 'instruction' under that unqualified/unsuitable individual. (See the current spread of cancelled qualifications and statements of attainment).

And insistence on meeting the requirements and modelling positive culture toward quality and excellence comes from the top. Managers, owners, CEOs... anyone in a leadership position within an RTO must know that the example they set is the one that will be followed.

Here are some key facts about the latest top areas of concern (noting we do not agree with the Outcome Standards' listings on the ASQA slide):

Area 1 – Unsuitable or unqualified trainers and assessors

The issue of trainer credentialling and suitability is dealt with in Outcome Standard 3.2 (not 3.1).

Outcome Standard 3.2 tells us that "Training and assessment is delivered to VET students by credentialled people with current skills and knowledge in training and assessment."

And Outcome Standards 3.2.2a-3.2.2c say:

An RTO must demonstrate:

"a) training and assessment is only delivered by persons who hold the appropriate credentials for the delivery of training and assessment as specified in the Credential Policy;

b) where the Credential Policy permits a person to deliver any training or assessment under direction – the organisation has systems in place that ensure the person does not make assessment judgements and is delivering quality training and assessment; and

c) how it ensures all trainers and assessors undertake continuing professional development to maintain current skills and knowledge in training and assessment, including skills and knowledge relating to engaging and supporting VET students."

It's plain - trainer/assessors must meet the requirements in the Credential Policy and undertake ongoing PD to stay up-to-date with how to deliver VET.

Outcome Standard 3.3 goes further to outline the requirements for staying up-to-date with industry skills and knowledge.

A "suitable" trainer/assessor will be one who meets the requirements.

Slide from the Skills Education PD session on "The Human Factors Contributing to Assessment Non-compliance"

The trainer qualification is in the Credential Policy section according to the circumstance of the individual. For example, ability to train and assess independently, see Section 1A; enrolled and currently working towards Certificate IV in TAE, see Section 1C etc.

In some cases licences or other registrations will be required by industry to train and assess, and if applicable, these requirements must be met also.

When it comes to "currency", the following applies:

Trainer currency >> TAE PD / VET PD >> how we train

– stay up to date in ways of training for VET; supports TAE credential, and training and education competencies

Vocational currency >> industry PD >> what we train

– stay up to date in ways of industry practices; supports vocational competencies

Area 2 – Ineffective or unsuitable organisational leadership

Slide from the Skills Education PD session on "The Assessment Systems and Tools Contributing to Assessment Non-compliance"; Organisational factors to support compliance

When the provider culture is contaminated by leadership focused on the wrong things, or by a leadership team that is not focused at all, staff are left to make their own way and can quickly become disenchanted with work. Productivity and satisfaction will likely slip and shortcuts emerge in daily practice. It's the shortcuts that can mean "this is the way we do things around here" becomes unethical and on the slippery slope to fraudulent operations.

Slide from the Education Matters members-only session "Let's talk about workplace culture"

Instead, effective, suitable leadership means individuals not only meet the Fit and Proper Person Requirements, but that they work to instil positive culture for staff and stakeholders. Via things such as:

• Leaders who listen

• Leaders who lead with purpose and accountability

• Staff feel valued and as though their work matters

  • Mentoring by more experienced workers to promote a pipeline of internal capability

  • RTO invests in continuing PD for all staff

  • Proper resourcing so staff can perform tasks without pressure to cut corners to meet deadlines; so students are afforded environments with all of the equipment and materials for authentic learning

  • Professional wellbeing is supported

• Continuous improvement is “a thing”

• There is a psychologically safe environment and people feel it is ok to speak up; make mistakes

• Ethical conduct, diversity and inclusivity is encouraged

Area 3 – Ineffective assessment validation

For us, this begins with the validation as a pre-use review.

If the tools are not confirmed as fit-for-purpose and consistent with the training product (as required in Outcome Standard 1.3), any assessment judgements made using the tools will be impacted, which in turn will affect results in any activity undertaken as part of meeting the requirements of Outcome Standard 1.5.

Slide from the Skills Education PD on "Confirming a quality-assured approach to assessment"

Validation continues to be an area in VET that can cause confusion:

• What it is

• When to do it

• Which one to do when (because yes, there is validation of assessment practices and judgements after tools are used (1.5) and validation as pre-use review to confirm tools are fit-for-purpose before they are used (1.3))

• Who can do it

• How to do it

• How to do it properly

• Implications, limitations and allowable use of AI

And one of the biggest areas of concern we see is the deficit in skills and capability to complete the validation in a truly robust and thorough manner, and for pre-use activity, the skills to properly confirm ALL requirements can be met with sufficient, valid evidence.

When the following types of instruments are accepted through validation, an error occurs as well as a breach of the requirements:

Question/task developed	Unit requirement
Describe what actions the business can take to show their customers that diversity is valued by the organisation. This should include reference to the actions of individuals, as well as corporate actions	PC2.3 Identify and implement inclusive work practices to demonstrate value of diversity in the workplace BSBTWK301 Use inclusive work practices
Analysis: Although the topic of diversity in the workplace is addressed by the question, it’s not in the right context according to the PC. AND it provides no evidence of the student having implemented anything
Write a brief summary (2-3 paragraphs) to identify and explain the principles that underpin adult learning	KE2.1 Principles and techniques involved in the management and organisation of: adult learning BSBHRM523 Coordinate the learning and development of teams and individuals
Analysis: You can see that only half of the KE requirement for principles and techniques is addressed, and again the question is not in the right context according to what the KE requires.  Further, how is this question providing evidence the student knows about the management and organisation of adult learning? It isn’t.
Prepare and present at least three of the following to a customer within commercial timeframes: caffe latte cappuccino espresso (short black) flat white long black piccolo latte mocha ristretto short and long macchiato	PE1 prepare and present each of the following espresso-based coffee beverages on three different occasions within commercial timeframes: caffe latte cappuccino espresso (short black) flat white long black piccolo latte mocha ristretto short and long macchiato SITHFAB025 Prepare and serve espresso coffee
Analysis: The PE does not give the option to pick and choose – all of the listed coffees must be made three times each

None of the above are valid questions or tasks according to what the unit requires. Accepting these instruments as suitable will indicate an incorrect interpretation of the unit and/or a shallow or immature understanding of compliance and instructional design. (To upskill in this area, see the Assessment Tool Do's and Don'ts master series and/or The Ultimate Guide to Understanding Validation).

Validation must confirm the tools and decisions made using those tools are producing graduates with the requisite skills and knowledge for safe, effective performance in the workplace. Which means for competency - all requirements must be met. Which means the tools must be designed and developed to allow an opportunity for that.

Far more than an administrative exercise, validation underpins the sustained quality of provider outputs.

Area 4 – Poor quality RPL

It's hard to know exactly which practices are contributing to poor quality RPL as this is an area that providers have struggled with consistently over the years. Flexibility is VET's superpower and one of the ultimate tools for flexibility toward a student's needs is RPL - recognising the prior learning they have, no matter how, when or where the experience, knowledge and skill was obtained. Yet RPL is approached with hesitation and an attitude of "it'll just be easier for you to do the course".

Slide from the Skills Education PD session on "The Assessment Practices Contributing to Assessment Non-compliance"

Yes, RPL is an advanced assessor skill. Yes, it deals with "wild" evidence in that not every individual will put forward the same artefacts as evidence toward their claim for competency. And yes, RPL is an assessment that is governed by the same Outcome Standards, including the Principles of Assessment and Rules of Evidence. And yes, as explained in this article by Vanessa Solomon for VET Perspectives, RPL is both an art an a science.

No, it is not necessarily a quicker, easier, cheaper option to formal qualifications. And no, it is not something that can result in a "piece of paper" without actual assessment of knowledge and skill.

The poorest of poor RPL isn't even RPL - it's fraud. Cash for quals and signing people off on the basis of a resume and a payslip!

Through Wendy Cato's Advanced RPL micro-credentials and the Skills Education RPL Matters Community of Learning about RPL practice, we've been supporting VET practitioners who want to know better ways to approach this fundamental part of the VET ecosystem. We even have a LinkedIn group for RPL-related discussion which anyone can join.

Area 5 – Poor quality assessment systems or practices

While we agree Outcome Standard 1.3 contributes to a provider's assessment system, it's probably more Outcome Standard 1.4 (not 1.3) that is most relevant in this case:

"The assessment system ensures assessment is conducted in a way that is fair and appropriate and enables accurate assessment judgement of VET student competency."

It's here that the principles of fair, flexible, valid and reliable assessment are explained as mandatory. And for assessors, to make judgements based on evidence that is valid, sufficient, authentic and current.

There are many variables as to why an assessment system may be poor quality. Here are a few:

• Invalid tools

• Systems that allow invalid evidence to be collected

• Procedures that mark students competent although competency is not confirmed

• Policies and procedures that are not connected to actual practice

• Policies and procedures that breach the compliance requirements of the RTO

When it comes to why assessment practices may be poor quality, it may be helpful to consider these practices that cause risk:

• Using unqualified/unsuitable assessors

• Using non-compliant tools

• Not applying the principles of assessment

• Not collecting enough valid evidence

• Using inadequate facilities and/or equipment

• Unrealistic simulations

• Reasonable adjustment - not applying it, or not applying it properly

• [Forcing] online assessment (as not everything is suited to online)

• Not verifying competency prior to sign off

• Being in a hurry - determination of competency deserves a measured, thorough approach

• Unhelpful feedback or not giving any feedback

• Any practice that results in poor quality outcomes

Slide from the Skills Education PD session on "The Assessment Practices Contributing to Assessment Non-compliance"

Without doubt, assessment practice can fail because of the attitudes and actions in the process. But we will also draw your attention back to the point that a poor quality system may be characterised by policies and procedures that are not connected to actual practice.

The concept of "Say it - Do it - Show it" as a governance framework was first introduced by Ian Whitehouse in the 2021 series: ‘Say Do Show’ - A compliance mantra for providers and regulators alike! Say Do Show also formed the basis of the DDEER model for self-assurance.

When considering the assessment system, RTOs must ensure what is written is reflected in practice because it's the actual delivery of VET that can expose the real quality of a provider's systems.

This concept has been a topical focus throughout the 2026 "From the Coal Face" series where Ian and his team of senior quality and compliance consultants have been sharing insights from ASQA audits and from the perspectives of actually being an auditor as well as representing providers.

While it's great that ASQA are sharing the themes emerging from their regulatory activity, in reality, all providers should be continuously focused on all areas of operations and aware that "passing audit" is only a snapshot of a regulator's decision about a single point in time.

Additionally "passing audit" is only relevant to whatever was reviewed by the auditing team - it is not a blanket approval for all aspects of operations sight unseen.

Continuous improvement is an ASQA focus and it should be yours too

This article is AITAS Rating 1

What is the AITAS?

18.9.26