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September 16, 2025 22 mins

The training sector has witnessed significant regulatory changes with the introduction of the 2025 standards, leaving many RTOs uncertain about what to expect during their ASQA audits. This episode cuts through the noise to deliver practical insights from two practitioners who've recently navigated the new audit landscape.

Drawing from their combined experience with seven initial registration audits under the new standards, Angela and Maycheck reveal a fundamental shift in ASQA's approach. Auditors are now prioritising the "tell and show" method – they want to hear RTOs explain their implementation strategies rather than simply reviewing documentation. This represents a move toward outcome-focused assessment, where your understanding of compliance obligations carries more weight than perfectly crafted policies.

The conversation explores several critical aspects of audit preparation, from ensuring comprehensive resource readiness to establishing clear accountability structures. Particularly valuable is their discussion of how auditors are comparing verbal explanations against submitted documentation to identify discrepancies. Both hosts stress the importance of thorough preparation: contextualising any purchased materials, testing assessment tools, and ensuring all team members have a solid grasp of compliance requirements.

Perhaps most refreshingly, Maycheck and Angela dismantle the fear narrative surrounding ASQA and the new standards. They emphasise that while the standards require interpretation based on your RTO's unique context, they're not designed to be impossibly complex. Their parting advice? Read the standards thoroughly, understand your obligations, and don't hesitate to seek guidance when needed. With proper preparation and the right mindset, your next audit can be an opportunity to demonstrate excellence rather than a source of anxiety.

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Episode Transcript

Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Speaker 1 (00:01):
Welcome to the RTO Superhero Podcast with Angela
and Maycheck.
Hello, maycheck and I aremeeting up in person today in
Darwin, so I just happened to beup here speaking at an event
and Maycheck just happened to bein town.

Speaker 2 (00:19):
Still stuck here for three weeks, three and a half
weeks now.

Speaker 1 (00:22):
And he's looking forward to getting back on the
road.

Speaker 2 (00:24):
Indeed.

Speaker 1 (00:25):
Yeah, yeah.
So Maytec, and I thought well,for this in-person, let's talk
about audits and our very firstASQA audit under the new
standards.
So, maytec, your first auditwas initial registration.
It was Just RTO.

Speaker 2 (00:44):
Just RTO About a week into the new standards.

Speaker 1 (00:47):
Yay, and what was your experience compared to
pre-2025?

Speaker 2 (00:54):
I think the biggest difference between these audits
other than, obviously, thestandards and really focusing on
the difference of the approachthe main thing was the
implementation how are you goingto implement the actual
standards?
Again, what we've spoken aboutin the past, it's not just about

(01:15):
documents, policies andprocedures, but also about tell
me how you're going to do thingsand making sure that the
applicant had a solidunderstanding of what they
actually needed to do, based onbecoming an RTO, for example,
tomorrow, as opposed to kickingoff a bunch of documents and

(01:35):
then saying, yep, you're good togo.
So there was a bigger focus onthat understanding and tell me
how you're going to do things.

Speaker 1 (01:42):
Yeah, because in the practice guys they're talking
about outcome focused.
So how are're going to dothings?
Yeah, because in the practiceguides they're talking about
outcome focused.
So how are you going to do thisand what are the outcomes?

Speaker 2 (01:51):
Yeah, all the auditors so far have really been
spruiking the whole concept oftell and show.
So tell us what you're going tobe doing.
And they already know what's inthe documents because they've
got it in front of them on theirscreens.
And they already know what's inthe documents because they've
got it in front of them on theirscreens.
But often they're comparing towhat the applicant is saying
versus what's on their documentsand if there's discrepancies,

(02:16):
that's where there starts tobecome issues.
So I think for anyone that'sgoing down that path, it's
really important to know yourdocuments.
If you're buying them off theshelf, if you're getting them
from another consultant, makingsure that you've got that
understanding of those documents.

Speaker 1 (02:26):
Yeah, and you know where to find things.

Speaker 2 (02:28):
Correct.

Speaker 1 (02:28):
Yeah, and you have a good understanding of your
policies.
And because the important part,if you don't know as a CEO or a
senior management position, ifyou don't know, how is everyone
else?

Speaker 2 (02:41):
going to know Yep?
If you don't know, how iseveryone else going to know Yep?
And ASQA just wants to beconfident that the auditor, the
assessor, wants to be confidentthat when they walk away, that
you're not relying on theconsultant, that you're not
relying on someone else to dothis job for you.

Speaker 1 (02:55):
Yeah, yeah, yeah.
So I've had one audit since thenew standards.
I know you've had a few morethan me.
I feel like I'm a veteranalready and my experience was my

(03:16):
assessor had a list of thingsthat she had to ask for, so my
assessor was an external auditor, not an ASQA employee.
So she basically went throughher checklist of do you have
this, do you have this?
So we submitted and I'massuming your client did as well
, but we submitted before the 1May change and they still asked

(03:37):
for 2025 documents.
So what we did is we preemptedand when they asked for further
evidence, we provided them withthe policies and procedures
before we went to them, we did avery simple thing.

Speaker 2 (03:52):
Rather than this time in the past, I guess under 2015
, they would ask for specificcontinuous improvement process,
the record retention process,the record retention process For
all of these audits, I've justgot the client to send through
their whole suite of documents,from start to finish, aligned to
every single standard, and it'sworked really well because I

(04:16):
found that actually all of themI've had two external
contractors and now threeinternal staff members.
The approaches have been alittle bit similar, but there
still have been theirdiscrepancies.
But I find that the moredocuments that I get up front,
the less questions they'reasking as well, which is very

(04:38):
different to in the past.
So, yeah, that was reallyinteresting, but the one that
really threw me and this is, Iguess, a lesson for everyone be
prepared with all of yourlearning resources.

Speaker 1 (04:54):
Right so.

Speaker 2 (04:55):
I had one auditor on two occasions at the end of the
audit say now can you show yourscreen and show me, take me
through, where all of yourlearning materials are, your
learner guides, your assessmenttools, your session plans,
powerpoints, et cetera.
If it's face-to-face delivery,luckily enough we had them ready

(05:15):
.
But it's just a very.
It was one of those eye-openingthings.
Well, yeah, an auditor, aperformance assessor, has the
right to request and change thescope if they feel that it's
appropriate.

Speaker 1 (05:26):
Yes, that's right, and I have seen people who just
get the assessment tools forthose units.
And that's not prepared.
That's not prepared to starttraining.
Correct, yeah.

Speaker 2 (05:39):
And so, yeah, look, like I said, each auditor has
their own little style, theirquirks and their little nuances.
Like I said, each auditor hastheir own little style, their
quirks and their little nuances,but overall there has been a
consistent approach aboutensuring readiness and a general
level of understanding, notthat you've memorized your
documents, but that you knowwhat they are, that you know how

(06:00):
they are applied and what therequirements of the standards
are.

Speaker 1 (06:03):
Yeah.

Speaker 2 (06:04):
Including what the CEO's obligation for reporting
is which was an interesting one,yeah, yeah.

Speaker 1 (06:11):
So I want to talk about accountability.
Did you get any questionsaround accountability and did
they ask for an organisationalchart or anything like that?

Speaker 2 (06:22):
They didn't ask for them because we supplied it
already.
Yeah, but they did ask, and soone of the audits that I had was
I keep saying audits, buteveryone for context performance
assessment et cetera was thatthe CEO actually had probably
only about 5% input into thewhole running of the RTO.

(06:46):
They had a delegated authorityas the RTO manager and so,
effectively, the RTO manager wasa pseudo CEO within that
environment.
So the accountability is not somuch.
Does the CEO know everything?
Is there enough operationalreadiness across the whole

(07:07):
workforce, which again goes backto the standard quality outcome
three, where it talks aboutdoes the RTO have all of the
sufficient resources from aworkforce perspective as well?

Speaker 1 (07:18):
Yeah, yeah, yeah, so we preempted as well with
position descriptions, so weprovided those with the
accountable roles and chart aswell, and, yeah, we provided.
So how we've done our policiesand procedures is we've got a
map of how they all worktogether.

(07:38):
Correct, yeah.

Speaker 2 (07:40):
The only differences that we do.
In all of our documents we saythe CEO or their delegate, and
then we have a delegation tablethat allows that.
And so at the end of the day,we all know that the buck stops
with the CEO, because they'rethe ones legally signing that
the RTO will remain compliant,that it will operate under the
requirements of the standards.
But at the end of the day, it'snot always the CEO that has to

(08:02):
do and be responsible for everyaspect.
There is the ability todelegate those tasks.

Speaker 1 (08:08):
Yeah, yeah, okay.
So out of all of your auditsthat you've had so far, were
they all initial or have you hada re-reach?

Speaker 2 (08:16):
No, since July 1, they've all been initial.
So what are we up to?
Six initials, and they've allgenerally flown the same way.
The one that I've got at themoment in progress was
interesting.
Even though we submitted theevidence on the 2nd of July,
they sent through aquestionnaire of five or six

(08:37):
questions to say how have youprepared for the 2025 standards,
which I thought was reallystrange, given that we submitted
on the 2nd of July.
But, either way, look, it wasfine.

Speaker 1 (08:49):
So you submitted your application on the 2nd of July
and you've already gone to audit.

Speaker 2 (08:52):
Yes.

Speaker 1 (08:53):
And I know of so many people who are still waiting
for their audits and theysubmitted last year.

Speaker 2 (08:58):
Yeah, look, I think the approach is and ASQA openly
say this that it's not afirst-come, first-served
application basis.
I don't know the inner workingsof ASQA and I will never
suggest that I do, but I do havea feeling that they will pick
the industries that are quiteniche and there's not many RTOs

(09:23):
out there that are doing that.
So I know, for example, bsbqualifications they don't
necessarily put that as a highpriority and I haven't seen many
BSB RTOs just dedicated to BSBgo through very quickly.

Speaker 1 (09:38):
And I have seen in the past that RTOs that were set
up with just BSB on their scopewere being targeted by ASCOA
because it was an easyapparently an easy thing to
start with and then do anaddition to scope following.

Speaker 2 (09:53):
And I think that's where the legislation changed a
couple of years ago, where itstopped RTO who's applying for a
change of scope within thatfirst two year period to try and
combat that as well.
Because you know, diplomabusiness eight units of
competency it was the go-to qualto get something registered
because you know it was low risk, easy to get through.
So look, a lot of the changesthat ASCA have implemented.

(10:13):
I think they've got still along way to go from a
consistency perspective, butcredit to them.
They're trying.
I know that there's a lot offear that's promoted but I think
overall they're doing as bestas they can.
A lot of people refer to themas the ASQA standards because
they think, you know, asqa isjust another stakeholder that is

(10:35):
embracing what was basicallythrown onto them as well.

Speaker 1 (10:39):
So yeah, the way I word it is.
Asqa is like the police, whoneed to enforce the regulators.

Speaker 2 (10:47):
Or the ATO, with.
You know, the ATO doesn'tcreate their own legislation,
they're just another regulatorthat forms part of that whole
cycle.

Speaker 1 (10:54):
Yeah, yeah, and they're just making sure that we
are compliant against thosestandards.
So, yeah, so you've got tochange that way of thinking.
And I see it all the time ASQAstandards yeah.

Speaker 2 (11:08):
ASQA standards or ASQA's.
You know, the training packagesthat they developed are rubbish
or blah, blah, blah, and it'slike that's where people don't
understand, I guess, how thewhole system works.
And, at the end of the day,asqa doesn't pick and choose
what training packages arecreated and how they're created.
Um, it's, it's, they justenforce what's in writing yeah,
yeah, uh.

Speaker 1 (11:29):
So I know with my audit that I had.
I was asked some specificquestions and there were things
like you were your client theclient.
Oh, it's funny though, becausethe auditor said you know you're
a consultant, you can'tparticipate.
Blah, blah, blah blah.
But then she asked questionsdirect.

Speaker 2 (11:44):
For anyone listening.
I think it's important to setthe tone with anyone that the
management of the RTO or theapplication understands it and
that the consultant is oftenthere just as an interpreter to
change or rephrase somethingthat the client doesn't
understand.
That's being asked.
But if you can demonstrate thatconfidence as the applicant,

(12:08):
that you've got that knowledge,then the performance assessor
doesn't have that fear of theconsultant answering questions
on your behalf.
That's been my experience.

Speaker 1 (12:17):
Yeah, it's really important that you know how to
answer things any questions thatyou get from the assessor but
also know where it is when itcomes to difference of opinion

(12:44):
and if they were working forother RTOs, Right yeah.

Speaker 2 (12:49):
So I think that would come down to more the 4.2 being
the conflict of interest.
That's it, yeah.

Speaker 1 (12:57):
So we didn't have one , but I had it under senior
management.
But it was interesting thatthey wanted one for trainer as
well, so I quickly wrote onearound conflict of interest for
the trainer.
But that was what she wasspecifically asked to ask us.

Speaker 2 (13:14):
Yeah, I think the conflict of interest, one which
is under that risk management,is an area that ASQA, I think,
is still working through,because it's new.
It's new, and even though weprovide a conflict of interest
policy, a register and adeclaration form, as well as a
risk management process, no onehas yet asked about risk

(13:36):
management or a risk managementmatrix in any of the audits yet,
and I dare say it's becausethey're still trying to work out
how to navigate what would bean appropriate amount of
evidence to show?
Because when you interpret thestandards, there is a
significant focus on overallrisk management.
Now, that's not just financial,but that's what happens if a

(13:58):
trainer is sick.
What happens if a trainerleaves halfway through a course
and you're suddenly left withouta trainer?
How do you manage that risk?
So there's a lot of points thatwould need to be broken down
into that risk management matrixand I dare say they're just not
quite sure what level is goingto be compliant yet.

Speaker 1 (14:16):
Yeah, and being initial registration, we weren't
asked anything about the risk.
We've got a risk register, butwe weren't asked anything yet.
So, for initial registration,what would be your advice to
anybody who is waiting for theiraudit for initial registration,
Probably the biggest thing ismake sure that you are as

(14:40):
prepared as possibly can be.

Speaker 2 (14:41):
Go through, whether you're using a consultant or
doing it on your own.
Go through each quality outcomeand ask yourself the questions
how do I do X?
So how do I ensure thattraining is fit for purpose, or
assessment is fit for purpose,that it's engaging, it allows

(15:08):
sufficient time?
Ask yourself those questions.
By all means.
Use ChatGPT or another AIplatform to develop those
questions.
I know you've got questionsthat you've prepared as well.
So, basically, go through andmake sure you are sufficiently
prepared to answer everyquestion against every quality
outcome, every KPI.
That's there, so that nothingis a surprise for you.

(15:28):
Yeah, yeah, yeah and make sureyou've got everything ready.
Like, make sure all your TASsare there and you know you don't
need a TAS under these newstandards, but TASs are just
still the simplest way topresent the information in the
format that is recognised bymost people.
But yeah, like trainer matrices, make sure you've got them in
place.
The industry consultation,everything should be ready

(15:53):
before.
I mean, in theory it should beready at the time of submission,
but we know that that's notalways the case.
So at least for audit, makesure that all the documents are
there and that you've got asolid understanding and so does
your team.

Speaker 1 (16:04):
Yeah, what I recommend is, once you've
submitted, what you should bedoing is, if you've purchased
materials, contextualise it 100%.
Go through.
You know, assess your tools,your assessment tools, test them
, because that's one of therequirements now is testing your
tools.
So you can do that followingyour submission.

Speaker 2 (16:29):
It's funny listening to how many auditors try and
drop the word accidentallypre-validation and they sort of
stop themselves.
How do we do this?
Before we use the tools, how doyou ensure that they align to?

Speaker 1 (16:43):
the units.

Speaker 2 (16:44):
So there seems to be an industry scare like to use
that word pre-validation.

Speaker 1 (16:49):
But I think also we're still learning to change
our language as well.
Like we used to train ourclients to hold a monthly
quality compliance meeting, nowwe're calling it the governance
meeting to tie in with thestandards.

Speaker 2 (17:05):
We still call it a monthly management meeting as a
concept, but it's the sameprinciple.
Whatever you call it is as longas you guys understand the
terms and your system, so thatyou're not referring it to a
continuous improvement log whenit's a systems register or
something like that.

Speaker 1 (17:24):
Yeah.

Speaker 2 (17:25):
So use the terms that you have been provided as part
of your documents or that you'vedeveloped yourself.

Speaker 1 (17:30):
Yeah, yeah, and we call it the governance register
now.
So we have all of thegovernance requirements, so
everything that we've got totrack.

Speaker 2 (17:38):
The last thing I will say, I think, is people that
don't choose not to use aconsultant, which is obviously
fine, but rely on AI or chat GPT.
There is a big issue withregards to not knowing what you
don't know and thinking thatChachapiti knows everything.

(18:00):
Everything, and even though youcan train it, you can punch in
the standards, etc.
Personally and I'm sure you'veexperienced it as well it
doesn't always get it right, itdoesn't always get the numbering
right.

Speaker 1 (18:11):
And it gets confused, as we know, between the old
standards and the new standards.

Speaker 2 (18:16):
I've seen it come up with ridiculous standards that
don't even exist, and so just bemindful that you know there is
value in using consultants thatactually understand that space
and have been around long enoughto guide you, not just
basically present something thatyou think is right.

Speaker 1 (18:36):
Yeah, yeah, like we've trained our bots ChatGP to
bots over four years and stillmake some mistakes.
Correct yeah.
So yeah, be very careful ifyou're using AI and, as always
with anything you do with AI,you need to challenge it and
cross-check and make sure it isactually accurate.

Speaker 2 (18:59):
Yeah, and developing something using AI doesn't mean
that you're an expert or giveyou knowledge of that topic as
well.
Yeah, so read the practiceguides, read DEWA's policy
guidance.
There's some really, reallygood information in there on how
to interpret the standards.

Speaker 1 (19:15):
I'm liking the practice guides.
Yeah, good information in thereon how to interpret the
standards.

Speaker 2 (19:18):
I'm liking the practice guides.
Look the practice guides, Idon't mind.
But the DEWA's document thatthey released in March to me is
far better in terms of, yeah, itprovides a lot more guidance.
So there's a lot of people outthere that say, oh, ASQA's not
giving us enough information, etcetera.
Asqa have openly said thatthey're not going to.
There's two paragraphs that sayyou know, it's the RTO's

(19:41):
responsibility to interpret,based on their size, their scope
, their demographic, et cetera,and then it's the RTO's
responsibility to demonstratecompliance.
I actually don't have a problemwith those two statements.
I think the more that weencourage the ownership of the
documents for our clients, thebetter as an industry that we're
going to have, as opposed tothis running blind with

(20:02):
ignorance.

Speaker 1 (20:03):
Yeah, and it should be contextualised to your
learner cohort and your industrycentre as well, and that's why
we don't have like one set ofpolicies and procedures that
everyone uses that come from thegovernment, because you can't
with a totally different sizeand scope.

Speaker 2 (20:21):
Correct yeah.

Speaker 1 (20:21):
Yeah, okay, thank you very much, maytec.
That was wonderful.
So if you're wanting to knowmore about initial registration
and what that process is, Idefinitely recommend download
the practice guide and also theDWER guide that they released as
well, to help you get a betterunderstanding of what you need

(20:42):
to know prior to going to youraudit and what you need to do as
part of your process, followingsubmission of your application
and making sure that you have agood understanding.

Speaker 2 (20:54):
What's your?

Speaker 1 (20:55):
final, last words.

Speaker 2 (20:57):
Don't be scared.
Don't buy into the fear that alot of people are putting out in
industry that ask was evil,that the standards are difficult
, that there's no interpretation.
Don't be lazy.
Don't be lazy and don't bescared of something that is your
responsibility to own.

(21:18):
Start by reading them and youknow, if you ask how many CEOs
you ask now that have actuallyread the standards, most will
still say probably not.
And so yeah, if you're applyingfor initial registration and
investing a significant amountof money, read them, understand
them and then seek guidance ifyou need to, because it's not

(21:39):
that complicated.

Speaker 1 (21:40):
Yeah, okay, thank you very much, matej.
Thank you Next, the nextepisode we're going to be
talking about.
If you're coming up forre-registration under the new
standards, surprise you withthat one.
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