Audit Triggers You’re Not Watching: Scope, Complaints & High-Risk Products

In this insight-packed episode, Angela Connell-Richards uncovers the silent risks that could land your RTO in an ASQA audit—even if you’ve already met the 1 July deadline. From additions to scope, to complaints, to the delivery of high-risk qualifications, Angela shows how audit triggers have changed—and what RTOs must now do to stay audit-ready.

Key points discussed:
 ✅ How scope changes can trigger a full audit
 ✅ Why even one student complaint could launch an investigation
 ✅ The list of training products ASQA considers “high risk”
 ✅ Tools to assess and reduce your audit exposure

Angela offers clear guidance on what you can do this week to identify and address your biggest hidden risks.

Listen now and download Angela’s free Audit Trigger Checklist at Vivacity to safeguard your RTO from unexpected compliance breaches.

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 Join host Angela Connell-Richards as she opens each episode with a burst of insight and inspiration. Discover why compliance is your launchpad to success, not a limitation. 

Wrap up with gratitude and guidance. Subscribe, leave a review, and join our community as we continue supporting your compliance journey in vocational education. 

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Episode Transcript

Speaker 1 (00:01):
Hey there, rto superheroes.
Welcome back to another episodeof the RTO Superhero Podcast
with me, angela Connell-Richards, your guide to all things
compliance, clarity andconfidence in the VET sector.
Now, last week, we took a goodhard look at marketing
compliance and, judging by themessages I've received, you're

(00:22):
starting to realise that.
Well, we're just at the tip ofa compliant rabbit hole as it
goes.
So today I wanted to take you abit deeper, because if you
think you'll be in the clear on1 July, you might be in for a
rude awakening.
This week's episode is allabout hidden audit triggers.

(00:46):
You know the ones that sneak upon you when you're not
expecting them, and the threebig culprits are changes to
scope, complaints, high risktraining, products.
So buckle up.
We're here to shine a spotlighton the quiet compliance bombs

(01:06):
waiting to go off.
I thought audits only happenedat re-registration.
Well, let's start with thismyth.
I hear all the time, angela,we're not due for an audit until
2026.
We've got plenty of time?
Nope, that thinking is outdatedand honestly dangerous.

(01:33):
Asqa no longer works on asimple cycle of re-registration
and registration.
They've adopted a risk-basedapproach, which means they can
and do initiate audits at anytime, based on scope activity,
risk assessment of your trainingdelivery, student or industry

(01:55):
complaints or internal dataanalysis from surveys and
national registers.
And the standards now give themeven more grounds to
investigate Scope changes thesilent audit trigger.
Let's dive into the first majortrigger addition to scope.

(02:16):
Adding a course to your scopemight seem like business as
usual like business as usual,but under the 2025 standards is
also an invitation for scrutiny.
Here's what often happens.
You submit your applicationthrough traininggovau or
Asquanet, you upload yourdocuments, tas resources,

(02:39):
assessment tools, you clicksubmit and within days or weeks,
you're contacted for an audit.
And that's not just a review ofyour new course.
It's often a full RTO audit.
Why?
Because adding to scope tellsASQA you're expanding your
delivery, you're potentiallyreaching a new cohort, you're

(03:08):
offering something they may deemhigh risk or underperforming.
If your documents aren'tairtight or not even created in
the first place, you're exposed.
Complaints One voice can triggeran audit.
So next up, let's have a lookat complaints.
Most RTOs are reactive when itcomes to complaints.

(03:28):
You wait until a student sendsan email or calls ASQA and by
then you're already in hot water.
Here's what you need to know.
A single complaint can triggeran investigation or a targeted
audit.
If ASQA receives multiplecomplaints about similar issues

(03:58):
course quality, poor support,misleading advertising they may
initiate a full compliance audit.
I recently supported an RTOwhere a single student lodged a
complaint about no propersupport for online learning.
The RTO had a support system onpaper, but they couldn't
demonstrate that the student hadbeen guided on how to use it.
The lack of evidence hurt them.
Moral of the story you're notbeing audited because you did

(04:22):
something wrong.
You're being audited becauseyou can't.
Okay, high-risk trainingproducts.
Are you delivering one?
Let's talk about the thirdhidden danger high-risk training
products.
Now, asqa has been trackingqualifications in unit

(04:44):
circumferences with highnon-completion rates, high
complaint volumes, loweremployer satisfaction or
historically poor outcomes, andif you're delivering one of
these products, you'reautomatically under the
microscope.
Common examples include earlyeducation and care and support,

(05:07):
individual support, businessadministration, security
operations, hospitality andcookery and first aid.
Delivering these isn't theissue.
It's whether you'redemonstrating quality,
consistency and student support.
So if your TAS isn't aligned,your placement partners are

(05:30):
underperforming or yourvalidation records are a bit
thin, watch out, what can you doabout it?
You might be thinking okay,angela, you've just scared the
hell out of me.
What am I going to do nowhere's what I want you to do
this week Download our audittrigger checklist.

(05:51):
We've created a practical,no-fluff checklist you can run
through in just under 20 minutes.
It covers your scope historycompliant handling process,
risky training products,evidence gaps.
So head to vivacitycomau orcheck out the link in the show

(06:11):
notes.
Review your addition to scopehistory If you've added anything
in the last 12 months.
Pull up your documents and do aself-audit.
Does your TAS, assessment toolsand trainer credentials stack
up?
Do you have a delivery andassessment plan in place?

(06:32):
Have you updated your trainer'smatrix?
You need to have all of thesein place.
Number three strengthen yourcomplaint handling framework.
Do you have an accessiblecomplaints form?
Are complaints lodged andreviewed monthly?
Do you have records of outcomesand student follow-ups?

(06:54):
Because when you candemonstrate transparency and
responsiveness, you'reprotecting your RTO's integrity.
Let me share a story.
Names changed, of course SilverSky, college, fictional.
They added a Certificate IV inCommunity Services to SCOPE.

(07:17):
In January their TAS was copiedfrom a previous QUAL.
Trainer didn't have relevant orrecent industry experience.
Complaints had been lodged, butno documented outcomes.
Asqa requested additionalevidence.
Documented outcomes ASQArequested additional evidence.
What should have been atwo-week review turnaround

(07:40):
turned into a targeted audit.
The outcome scope suspended forthree months, whilst they were
required to fix multiplenon-compliances.
Here's your lesson Everythingyou submit for scope is an audit
of your integrity.
Don't cut corners.
So what's the?

(08:04):
What's the takeaway for today?
Audit triggers don't wait foryour calendar.
They don't care if you're busy.
They happen when you add a newcourse, miss a complaint or
deliver a course that's alreadyunder ASQA's radar.
But the good news is, you canprepare for it proactively.

(08:24):
Download the audit triggerchecklist from vivacitycomau and
use it at your next teammeeting Next week.
We're zooming in on one of themost dangerous assumptions in
RTO land.
We updated our policies.
We're fine now right Spoileralert you're probably not.

(08:46):
Until then, keep leading, keeplearning and remember.
Compliance is your culture, nota document in a folder.
Catch you next week on the RTOSuperhero Podcast.