A significant change to child safety law is approaching for Queensland organisations that work with children. The Reportable Conduct Scheme, introduced under the Child Safe Organisations Act 2024, will commence on 1 July 2026, with early childhood education and care services and disability services that work with children among the first cohort required to comply from that date.
For Barrack Broking’s clients in the childcare and disability support sectors, this is a compliance shift worth understanding now, well ahead of commencement.
Where the scheme comes from?
The Reportable Conduct Scheme was originally recommended in the 2017 Final Report of the Royal Commission into Institutional Responses to Child Sexual Abuse. The Commission’s aim was to lift the standard of how institutions handle complaints relating to children, strengthen investigation practices, and improve reporting where abuse is known or suspected. Queensland has now legislated this through the Child Safe Organisations Act 2024, alongside a related set of Child Safe Standards that organisations must also meet.
What the scheme requires?
The scheme applies to organisations defined as “reporting entities” — those with a high degree of responsibility for children, or whose activities carry a heightened risk to children because of the type of institution, the nature of the work, or the vulnerability of the children involved. The categories of organisation captured are set out in the Act.
Reporting entities will be required to report and investigate concerns about the conduct of their staff and volunteers in relation to their work with children, and to notify the Queensland Family and Child Commission (QFCC) when an allegation or conviction meets the threshold for “reportable conduct.”
What counts as reportable conduct ?
Under the scheme, reportable conduct includes:
- a child sexual offence
- sexual misconduct committed in relation to, or in the presence of, a child
- ill-treatment of a child
- significant neglect of a child
- physical violence committed in relation to, or in the presence of, a child
- behaviour that causes significant emotional or psychological harm to a child
This can arise from a single act or a series of acts or omissions. Importantly, the scheme does not capture conduct that is reasonable for the discipline, management or care of a child, taking into account the child’s age, developmental stage and health, and any applicable code of conduct or professional standard.
What’s required of organisation leaders?
Once the scheme applies to an organisation, the head of that organisation will be required to:
- ensure systems are in place to prevent reportable conduct, and to report, investigate and respond to reportable allegations or convictions involving workers
- notify the QFCC of reportable allegations or convictions
- arrange an investigation and provide a final report to the QFCC
- provide further information to the QFCC if requested
How this interacts with police investigations?
If an organisation becomes aware of alleged conduct that may be criminal, it must report the matter to police promptly. Any police investigation takes priority over a Reportable Conduct Scheme investigation. In that situation, the organisation is still expected to take steps to manage risks to children’s safety and wellbeing — including interim risk management action — provided this doesn’t interfere with the police investigation.
Key dates
- 1 October 2025 — Child Safe Standards obligations began commencing in phases under the Act.
- 1 July 2026 — The Reportable Conduct Scheme commences. Early childhood education and care services and disability services working with children are among the entities expected to be ready from this date.
- 1 July 2027 — All reporting organisations are required to be fully compliant, with the scheme introduced through a staged approach in the interim.
What this means for your organisation?
This is a structural change to how childcare providers and disability support organisations will be expected to manage, document and report concerns about worker conduct. Organisations in scope should be reviewing governance arrangements, complaint-handling processes, recruitment and screening practices, and incident response plans well ahead of the 1 July 2026 start date — preparation of this kind isn’t something that can be put together at short notice.
This article is general information only and isn’t legal advice. We’d recommend organisations seek independent legal guidance on how the scheme applies to their specific operations, and refer to the QFCC’s own Reportable Conduct Scheme resources for authoritative detail.
As an insurance broker, Barrack Broking is also tracking how this changing compliance landscape may intersect with risk management and insurance arrangements for childcare and disability support clients. If you’d like to talk through what this means for your organisation, please contact our team.
