ECEC Child Safety: Maximum Penalties Have Tripled. Are You Ready?
Child safety reform now carries tripled penalties and, from July 2027, a funding consequence. Community-managed centres need a dated compliance plan, not a policy refresh. Here are the deadlines, the records regulators look for, and how your board can oversee the work.
Maximum penalties under the National Law tripled in January 2026. From July 2027, a centre that doesn’t meet Quality Area 2 may also lose Worker Retention Payment funding. If you are the approved provider for one or two community-managed centres, you need a dated child safety compliance plan, not a policy refresh.
A refreshed policy shows what you intend to do. Regulators now look for proof of what happens: training certificates, register entries, device records and board minutes. Building that proof takes months, and the next real deadline is 31 March 2027.
You can start this quarter with four checks:
• Training. List who has finished foundation child safety training, and who still needs the advanced courses for their role.
• Worker Register. Confirm every educator, volunteer and student is entered, and that changes go in within 14 days.
• Devices. Check your personal device rules match your state or territory’s current restrictions.
• Board oversight. Put a short child safety report on every committee meeting agenda.
Free Resource: Child Safety Compliance Tracker
Child safety compliance tracker for Australian ECEC services. Track reforms, training, worker checks, device rules, Quality Area 2 and compliance actions.
Digging Deeper
Key child safety dates from 2025 to July 2027
The reforms arrived in stages, and two deadlines remain. This table shows what changed and what it means for a small community-managed provider.
| Date | Change | What it means for you |
|---|---|---|
| August 2025 | Education Ministers make child safety a shared national priority. | Every government is now working to the same agenda. |
| November 2025 | Unannounced spot check visits begin. | Officers can arrive without notice. |
| January 2026 | Maximum penalties under the National Law triple. | Each breach costs far more than before. |
| 27 February 2026 | Worker Register launches; inappropriate conduct offence, Working with Children Check and training rules start; device restrictions apply. | Records and onboarding steps became legal requirements. |
| 27 March 2026 | Current workforce details due on the Worker Register. | Your register should already be complete. |
| 31 July 2026 | Advanced child safety training (Courses 3 and 4) available. | Staff and leaders can start now. |
| 30 September 2026 | Course 5, for leaders and governors, available. | Committee members can start now. |
| 31 March 2027 | Advanced training deadline for people in role before 30 September 2026. | Your main training deadline. |
| July 2027 | Worker Retention Payment linked to Quality Area 2. | Safety now affects wage funding. |
Two 2025 laws link child safety to funding and penalties
The Early Childhood Education and Care (Strengthening Regulation of Early Education) Act 2025 makes quality and safety a condition of Child Care Subsidy approval. Regulators can now suspend or cancel that funding when a service fails quality, safety or compliance requirements.
The Department of Education describes the Early Childhood Legislation Amendment (Child Safety) Act 2025 as the biggest strengthening of child safety rules since 2012. It widens the responses to misconduct and expands regulators’ powers. It also tripled maximum penalties.
The Victorian Government gives one example. The maximum penalty for failing to protect children from harm and hazards is now $34,200 for an individual. For a provider organisation, it is $172,200.
Compliance is also more visible to families. StartingBlocks.gov.au now shows regulatory visits, enforcement actions and conditions placed on services and providers.
Quality Area 2 will affect your wage funding from July 2027
A policy refresh does not show what happens on the floor
Policies still matter, but they are only the starting point. For Child Care Subsidy approval, the Department of Education can weigh your compliance record, serious incidents and complaints. It can also consider whether quality has improved over time. A new policy document changes none of those things. Evidence that the policy works in practice does. Keep these records current and easy to find: • Training certificates. Keep a Certificate of Completion for each course in each person’s staff record. • Worker Register entries. Current details for every educator, volunteer, student and nominated supervisor. • Working with Children Checks. A current check sighted before each person starts, plus a log of status changes. • Device records. Any written authorisations to carry a personal device, with dates and review notes. • Incidents and complaints. What happened, what you did, and what you changed. • Board minutes. Evidence the committee reviewed child safety and acted on what it saw.Training deadlines differ by role, including your committee
| Role | Foundation | Advanced |
|---|---|---|
| Committee members (persons with management or control) | Courses 1 and 2 | Course 5 |
| Nominated supervisor and person in day-to-day charge | Courses 1 and 2 | Courses 3, 4 and 5 |
| Staff who work directly with children | Courses 1 and 2 | Courses 3 and 4 |
| Other staff, volunteers and students | Courses 1 and 2 | Not required |
Plan for committee turnover. ACECQA lists each member of an association’s management committee as a person with management or control. New members elected at your AGM will need Course 5 within three months.
Update the Worker Register within 14 days of any change
The National Early Childhood Worker Register launched on 27 February 2026. Approved providers enter details through the NQA ITS, the system they already use with their regulator. By mid-2026, over 96% of approved services had entered their workforce.
For each worker, you record their name, date of birth, contact details, role and employment dates. You also record relevant qualifications, training and Working with Children Check or teacher registration details.
You must update the register within 14 days of employing someone, or of learning about a change to their details. Build that step into your onboarding and exit checklists, so it does not rely on memory.
Working with Children Check rules also tightened. A person must hold a current check before starting work, and services must report changes in a worker’s status.
Personal device rules now apply in every state and territory
Every state and territory has banned or restricted personal devices while educators work directly with children. The detail varies, so check your own regulator’s rules.
New South Wales is one example. Since 27 February 2026, people working directly with children cannot carry personal devices that can take, store or send images. The approved provider can authorise a device in writing for specific needs, such as health reasons or emergencies.
In NSW, each authorisation lasts up to three months, and the records must be kept for at least three years. Those records are exactly the evidence a regulator may ask to see.
CCTV is a separate question. A national assessment of more than 300 services is under way, and nationally consistent guidance is still pending. You may want to wait for that guidance before committing to a major purchase.
Unannounced visits check records as well as practice
Since November 2025, Department of Education officers have made unannounced visits to more than 1,300 services. They review enrolment and attendance records, record-keeping, and how the Child Care Subsidy is administered.
Officers refer any quality or safety concerns to the state or territory regulator. These visits sit alongside the regulators’ own checks, which continue.
A useful test is simple: could the person in charge on any given day find your training, register and device records within minutes? Our earlier article on childcare spot checks covers what to expect on the day.
A dated child safety compliance plan to July 2027
Work backwards from the two fixed deadlines: 31 March 2027 for advanced training and July 2027 for the Worker Retention Payment link. Spreading your child safety compliance work over five stages keeps the load manageable for a small team.
- October to December 2026: gap analysis. Compare your training, register, Working with Children Check and device records against current requirements, and list every gap.
- By 31 December 2026: records in order. Reconcile the Worker Register, log Working with Children Check status for every worker and file device authorisations.
- January to March 2027: training complete. Roster time for Courses 3 and 4. Schedule Course 5 for leaders and committee members before 31 March 2027.
- April to June 2027: test the evidence. Run an internal walkthrough against Quality Area 2, including supervision, incident records and child protection responses.
- From July 2027: steady state. Keep the 14-day register updates, two-yearly training refreshers and a standing board report.
Fixed dates and planning dates. Only 31 March 2027 and July 2027 are set by government. The other dates are planning milestones you can adjust to suit your centre.
Your board should see a short child safety report at each meeting
Your committee members are persons with management or control, with their own training obligation. Course 5 is called “Leading and governing child safety”, which signals what regulators expect from boards.
A one-page report lets the committee see progress without reading every record. It should cover:
• Training. Completion by role against the 31 March 2027 deadline, and any refreshers due.
• Register and checks. Update the Worker Register within 14 days, and note any Working with Children Check changes.
• Devices. Personal device authorisations issued, reviewed or revoked.
• Incidents and complaints. What was reported, the response and any change in practice.
• Plan progress. Where the centre sits against the dated plan, and any slippage.
Record the discussion and any decisions in your minutes. That record shows oversight in a form a regulator can read.
Common questions from community-managed centres
Do our volunteer committee members need child safety training?
Yes. ACECQA treats each member of an association’s management committee as a person with management or control, who must complete foundation training and Course 5.
Is the mandatory training free?
Yes. It is free on Geccko, the Department of Education’s learning platform, and training from other providers does not count.
Will a new child safe policy meet the new rules?
A current policy is necessary, but it is not enough on its own. Regulators also look for records showing that training, checks, and oversight happen in practice.
Should we install CCTV now?
National CCTV guidance is still pending, and more than 300 services are being assessed. Waiting may help you avoid buying a system that doesn’t match the final guidance.
Where can families see a centre’s compliance history?
StartingBlocks.gov.au shows regulatory visits, enforcement actions and conditions placed on services and providers.
How can SBAAS help
Tripled penalties and a funding link from July 2027 mean a policy refresh is not enough. Your centre needs evidence that training, records and oversight work in practice.
SBAAS starts with a compliance gap analysis against the current requirements. We then update your child-safe policies and procedures and build a role-based staff training plan with deadlines.
Our Managing Director is a member of the Small Business Association of Australia (SBAA) Think Tank, which is consulted on policy matters.
We work from a scoped proposal, so your committee can see the work and cost before it commits.
Request a scoped proposal you can take to your board:
Not ready to talk? Download the Child Safety Compliance Tracker
Child safety compliance tracker for Australian ECEC services. Track reforms, training, worker checks, device rules, Quality Area 2 and compliance actions.
General information
This article is general information only. It is not legal, financial or tax advice. Requirements change and can vary by state and territory. Check current requirements with the relevant regulator, and we recommend legal review before you rely on it for compliance decisions.
Sources
Australian Children’s Education and Care Quality Authority. (2026, March 31). National Early Childhood Worker Register, launched on 27 February 2026. https://www.acecqa.gov.au/node/1114756
Australian Children’s Education and Care Quality Authority. (2026, July 27). Quality Area 2: Children’s health and safety. https://acecqa.gov.au/nqf/national-quality-standard/quality-area-2-childrens-health-and-safety
Australian Children’s Education and Care Quality Authority. (2026, September 30). Child safety and child protection training. https://www.acecqa.gov.au/national-quality-framework/child-safety/child-safety-and-child-protection-training
Australian Children’s Education and Care Quality Authority. (2026, September 30). Information sheet: Identifying persons with management or control of a service. https://www.acecqa.gov.au/node/1114836
Department of Education. (2026). A year of action to strengthen child safety in early childhood education and care. https://www.education.gov.au/node/20468
Department of Education. (2026). More than 1,300 child care services visited through spot check program. https://www.education.gov.au/node/20595
Department of Education. (2026). Worker retention payment extended to 30 June 2028. https://www.education.gov.au/node/20428
NSW Department of Education. (2026, June 23). Restriction on personal devices. https://education.nsw.gov.au/early-childhood-education/regulation-and-compliance/regulation-assessment-and-rating/child-safety/restriction-on-personal-devices
Parliamentary Library. (2025). Bills Digest No. 4, 2025-26: Early Childhood Education and Care (Strengthening Regulation of Early Education) Bill 2025. Parliament of Australia. https://www.aph.gov.au/Parliamentary_Business/Bills_Legislation/bd/bd2526/26bd004
Victorian Government. (n.d.). Child safety reforms: National and Victoria-specific legislative changes. https://www.vic.gov.au/child-safety-reforms-national-and-victoria-specific-legislative-changes
Eric Allgood is the Managing Director of SBAAS and brings over two decades of experience in corporate guidance, with a focus on governance and risk, crisis management, industrial relations, and sustainability.
He founded SBAAS in 2019 to extend his corporate strategies to small businesses, quickly becoming a vital support. His background in IR, governance and risk management, combined with his crisis management skills, has enabled businesses to navigate challenges effectively.
Eric’s commitment to sustainability shapes his approach to fostering inclusive and ethical practices within organisations. His strategic acumen and dedication to sustainable growth have positioned SBAAS as a leader in supporting small businesses through integrity and resilience.
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