If your RTO delivers the Certificate III or Diploma of Early Childhood Education and Care, two significant changes to Australian law that took effect on 27 February 2026 deserve your attention even if your first instinct is that they apply to ECEC services, not to you as a Registered Training Organisation.
You wouldn’t be entirely wrong. The new mandatory national child safety training and the restrictions on personal device use in education and care services sit squarely within the Education and Care Services National Law and are ultimately the responsibility of approved ECEC providers to enforce. The centre is responsible for ensuring every person in their service has completed the mandatory training. The centre is responsible for enforcing the personal device rules.
Here is where it gets relevant to you as an RTO though – for your vocational placement students to successfully complete their qualification, they need to complete mandatory hours required by the training product. And Placement is now subject to legal requirements that your students need to understand (and observe) before they walk through a centre’s door for the first time. If they are not informed, not prepared, and have not completed the mandatory training modules, they cannot be placed. If they are not placed, they cannot complete their hours.
This is not the centre’s problem to solve. It is yours.
In this article, we outline actions you can take to ensure your students are prepared and your placement framework holds up.
The mandatory child safety training
The Early Childhood Legislation Amendment (Child Safety) Act 2025, passed by the Victorian Parliament on behalf of all Australian states and territories, introduced mandatory national child safety training for everyone working or volunteering in a National Quality Framework (NQF)-regulated ECEC service. The requirement applies across all NQF-regulated service types, including:
- Centre Based Day Care;
- Family Day Care;
- Outside School Hours Care; and
- Preschools and kindergartens.
While In Home Care and some Community Child Care Fund Restricted services are not regulated under the NQF, the industry encourage staff at these services to complete the training.
This includes students undertaking placement as part of an approved education and care qualification.
The training is delivered exclusively through Geccko, the Australian Government’s official online learning platform for the ECEC sector. It consists of two Foundation modules that must be completed in sequence. The training is free and takes approximately two hours to complete. Advanced modules are expected from July 2026 and will also become mandatory once released.
The consequences of non-compliance are serious. Approved ECEC providers who fail to ensure everyone in their service has completed the training face fines of up to $34,200.
Understandably, centres are not going to let an unprepared student through the door.
To complete the foundation training, under National Law, learners have until 27 August 2026.
So why does this matter to your RTO?
Let us be direct. The responsibility to ensure a student has completed this training before placement rests with the approved service, not with you as the RTO. Despite this, consider what happens in practice if your students do not know this requirement exists.
A student arrives for their first day of placement. The centre asks for their Geccko certificate. The student has never heard of Geccko. The placement does not proceed, and this doesn’t look good for you as a training provider for the sector. There is a delay to their placement. And you have a student who feels blindsided by something they were never told.
Now consider the alternative. Your pre-enrolment information clearly explains the requirement. Your student enrols in Geccko, completes both Foundation modules, downloads their certificate, and arrives at the centre ready to go. Placement proceeds without disruption. The student succeeds. The student is informed about child safety, prior to placement – some might even consider this a requirement under the Outcome Standards (Standard 1.8, Standard 2.1 and 2.2).
The difference between these two scenarios is not the centre’s policy. It is your upfront information.
Under the Outcome Standards for NVR Registered Training Organisations 2025, RTOs are required to provide students with clear, accurate information about all obligations and requirements associated with their training product, including work placement, prior to enrolment. The mandatory child safety training is now one of those requirements. Failing to disclose it is not just poor practice; it is a gap in your upfront information.
What your students need to know before they enrol
The mandatory child safety training requirement should be prominently included in your public facing student information and any pre-enrolment information provided to prospective students. It should not be buried in a placement guide that students receive months into their course and after enrolling. Students need time to complete it and they need to know it is coming.
They also need to understand that the content might be sensitive depending on their background and life experiences, this is another reason they should be informed up-front.
Here is what to tell them, in plain terms:
Before your first day of placement in an NQF-regulated service, you are required by law to complete the national child safety training through Geccko, the Australian Government’s official ECEC learning platform, available at education.gov.au/early-childhood. Training completed through any other platform does not satisfy the legal requirement.
The training is free and takes approximately two hours. To complete it:
- Create a personal Geccko account using your own personal email address. Shared, generic, or work email addresses are not permitted, as individual completions must be trackable.
- Log in and select the national child safety training from the homepage.
- Complete Course 1 first. Course 2 will not be accessible until Course 1 is done.
- Once both courses are finished, download your completion certificate.
- Provide a copy of your certificate to the centre before, or on the day that placement commences.
This is a non-negotiable condition of placement commencement. No certificate, no placement.
Students should also be aware that the training must be renewed every two years, and that Advanced modules (expected from July 2026) will become an additional mandatory requirement once released. Students will be notified of the timeframes for those modules when they are confirmed.
A separate requirement, equally important: The device rules
The same legislative reforms that introduced mandatory child safety training also brought significant restrictions on the use of personal digital devices in ECEC services, and these too, apply to students on placement from day one.
Sections 175H and 175I i prohibit a person from having a personal device “in the person’s possession or under the person’s control” while working directly with children (unless an exception applies). This goes beyond simply using the device.
The examples given are generally consistent with that concept:
- A phone in a pocket = likely in the person’s possession.
- A smart watch on a wrist = likely in the person’s possession/control. ACECQA ii specifically identifies smart watches as personal devices covered by the reforms.
- A tablet being carried in a bag while working directly with children = likely in the person’s possession/control.
The law allows possession or control in certain circumstances, such as:
- Where the approved provider has authorised the device under section 175J;
- During excursions or transport where necessary for safety or care;
- Certain disability, health, emergency, family communication, or WHS circumstances.
Working directly with children means being physically present with children at the service. During a “genuine break” away from children, personal devices may be used. At all other times, devices must be stored in a bag, locker, or other designated area away from children’s spaces.
Important: students must never use a personal device to photograph, film, or record children under any circumstances, even where an exception to the possession rule might otherwise apply. Images of children in care may only be captured using service-supplied or service-authorised devices.
Breaching these rules is not a matter of centre policy. It is a breach of the National Law and can have serious regulatory consequences for the approved provider; consequences that could include disciplinary action against the student and immediate removal from placement.
Your students need to understand this before they arrive at a centre, not after they have left their phone in their pocket out of habit on their first morning.
Updating your placement framework
Beyond what students are told, RTOs that manage their own placement frameworks should ensure these requirements are embedded in their placement documentation.
This means:
Child Safety Training
- Add national child safety training as a standalone mandatory pre-placement requirement with clear evidence requirements. Students must provide their Geccko completion certificate to the RTO before placement is confirmed.
- Update host service agreement templates to include a clause confirming the host is aware that students will arrive with evidence of completion, and a clause requiring the host to notify the RTO if a student without a valid certificate attempt to commence placement.
- Flag state-by-state variation where relevant. Geccko completion satisfies the existing child protection training requirement under s.162A of the National Law in some jurisdictions, including Queensland, but not all. Your framework should reflect this.
Personal Device Rules
- Set out clearly what students must and must not do with personal devices during placement. Acknowledge that host services may apply policies more restrictive than the legal minimum and make clear that compliance is a condition of placement, not a suggestion.
General Placement Requirements
Your placement framework should also address the following:
- Minimum placement hours per qualification, as specified in the relevant training product.
- Approved placement setting types, including long day care, outside school hours care, and kindergarten/preschool, and the criteria a provider must meet to be approved.
- Age group coverage requirements across placement hours, where specified by the training product.
- Currency requirements for first aid, CPR, anaphylaxis management, and asphyxia response, prior to placement commencement.
- Working with Children Check requirements (Blue Card in Queensland), including verification obligations.
- Written agreement between the RTO and placement provider, including roles and responsibilities of each party, and insurance and indemnity obligations.
- Supervisor eligibility and qualification requirements.
- RTO monitoring obligations during placement, including visit frequency and communication protocols between the RTO, student, and placement supervisor.
- Student acknowledgement of placement provider policies, particularly where assessment tools require students to read, apply, and demonstrate understanding of the host service’s policies as part of assessed tasks.
- Incident and complaint reporting procedures, including escalation pathways and documentation requirements.
The bottom line
The new child safety requirements are not an ECEC industry compliance burden that RTOs can observe from a distance. They sit at the intersection of the training package, your students’ obligations during placement, and your own obligations to provide complete and accurate pre-enrolment information.
Your students will encounter these requirements the moment they step into a centre. The question is whether they encounter them prepared (because you informed them) or unprepared, because the assumption was made that it was someone else’s job to do so.
Getting this right protects your students, supports the centres that host them, and demonstrates the kind of compliance maturity that distinguishes high-quality RTOs in a closely regulated sector. It is a small update to your documentation. The impact on your students is anything but small.
This article was prepared by Hawkeye for RTO requirements and placement framework guidance purposes. Legislative references are to the Education and Care Services National Law as amended by the Early Childhood Legislation Amendment (Child Safety) Act 2025, effective 27 February 2026. RTOs should seek independent advice on state-specific child protection training requirements applicable to their jurisdiction/s of delivery.