Queensland's New Reportable Conduct Scheme From 1 July 2026

^{Queensland's New Reportable Conduct Scheme: What Organisations Need to Know Before 1 July 2026}

From 1 July 2026, Queensland organisations that work with children will be required to comply with the new Reportable Conduct Scheme (RCS) established under the Child Safe Organisations Act 2024 (Qld) (the Act). The scheme represents a significant reform to Queensland's child safeguarding framework and aligns Queensland with other Australian jurisdictions that have already implemented reportable conduct regimes.

The RCS is designed to strengthen child safety by ensuring organisations have effective systems to prevent, identify, respond to and investigate allegations of misconduct involving children. It also introduces independent regulatory oversight by the Queensland Family and Child Commission (QFCC), creating greater accountability and consistency in how child safety concerns are managed.

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^{Who Will Be Affected?}

The scheme applies to organisations that care for, supervise, educate or exercise authority over children, referred to under the Act as "reporting entities". It is expected that approximately 10,000 Queensland organisations will fall within the scope of the scheme.

Reporting entities include schools, early childhood education providers, disability service providers, health services, religious organisations, sporting clubs, youth organisations and other prescribed entities.

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Importantly, the Act adopts a broad definition of "worker", extending beyond employees to include volunteers, contractors, consultants, labour hire personnel, trainees and religious leaders. Allegations may be reportable even where conduct occurs outside the workplace or outside working hours if it raises concerns about a person's suitability to work with children.

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^{What Is Reportable Conduct?}

Section 26 ( 1 ) of the Child Safe Organisations Act 2024 defines reportable conduct as including:

• 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; and

• Behaviour that causes significant emotional or psychological harm to a child.

Importantly, section 26 ( 3 ) confirms that reportable conduct may consist of a single act or a series of acts.

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The RCS is not limited to criminal conduct. Conduct may be reportable even where police do not lay charges or where the behaviour does not result in a criminal conviction. The focus is on identifying and managing risks to children.

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The QFCC's guidance also clarifies that organisations do not need definitive proof before taking action. A "reasonable belief" exists where the available information would lead a reasonable person to believe the conduct may have occurred. Allegations do not need to be substantiated before reporting obligations arise.

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The guidance further identifies conduct that would generally not be considered reportable, including reasonable behaviour management consistent with organisational policies, accidents where there is no neglect or recklessness, trivial incidents that do not create a risk of significant harm and appropriate care or support practices for children with disabilities or additional needs.

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^{The Role of the Queensland Family and Child Commission}

Under the Act, the QFCC has been appointed as the independent regulator of the Reportable Conduct Scheme. Its role is to provide oversight and quality assurance of how reporting entities identify, respond to and investigate allegations of reportable conduct.

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The Commission will receive notifications and investigation reports, monitor organisational responses, conduct investigations where necessary, work collaboratively with police, child safety authorities and sector regulators, provide education and guidance, identify systemic child safeguarding issues and undertake compliance and enforcement activities where required.

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While reporting entities remain responsible for investigating allegations involving their workers, the QFCC has powers to assess the adequacy, independence and timeliness of organisational investigations and intervene where appropriate.

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^{Key Reporting Obligations}

The primary responsibility for compliance rests with the "head of the reporting entity", as defined in section 7 of the Act. In most organisations, this will be the Chief Executive Officer, Executive Director or equivalent senior leader with ultimate responsibility for service delivery.

When a reportable allegation or reportable conviction becomes known, reporting entities must:

• Assess the allegation and any immediate risks to children;

• Implement appropriate risk management measures;

• Notify the QFCC within three business days;

• Conduct an investigation into the allegation;

• Provide an interim report within 30 business days; and

• Submit a final report as soon as practicable after the investigation is completed.

Importantly, the QFCC expects reporting entities to apply the same reporting and risk assessment obligations to allegations arising in a worker's private capacity as they would to allegations arising in the workplace. The involvement of police, child safety authorities or another regulator does not remove an organisation's obligation to assess and manage risks within its own environment.

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^{Preparing for Compliance}

Section 30 of the Act requires reporting entities to establish systems that prevent, report and respond to reportable conduct.

These systems should enable organisations to:

• Prevent reportable conduct through effective child-safe policies, codes of conduct and risk management practices;

• Allow workers and members of the public to report allegations and reportable convictions;

• Facilitate direct reporting to the QFCC where allegations involve the head of the organisation; and

• Investigate and respond appropriately to reportable allegations and reportable convictions.

To prepare for the introduction of the RCS organisations should be reviewing their child safeguarding frameworks, complaint handling procedures, reporting pathways, investigation processes and governance arrangements. Staff and volunteers should be trained to recognise and escalate concerns, and leaders should ensure reporting obligations are clearly understood throughout the organisation.

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The introduction of the Reportable Conduct Scheme under the Child Safe Organisations Act 2024 (Qld) represents a significant shift in accountability for organisations that work with children. Organisations that prepare early will be better positioned to meet their legal obligations while demonstrating a strong commitment to protecting children and young people.

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Sentara Consulting can play a pivotal role in helping organisations prepare for Queensland’s new Reportable Conduct Scheme by providing tailored, end‑to‑end support across governance, compliance and operational readiness. This includes conducting gap analyses against the Child Safe Organisations Act 2024 (Qld), reviewing and strengthening child safety policies and reporting pathways, and ensuring alignment with QFCC expectations. Sentara Consulting brings deep expertise in managing complex and sensitive reportable conduct matters, combined with the delivery of fair, thorough and defensible investigations. By leveraging this specialist experience, we support organisations to respond confidently to allegations, meet regulatory expectations and demonstrate best practice in safeguarding children and young people.  

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Sentara Consulting provides this information for general informational purposes only. It does not constitute professional advice and should not be relied upon as a substitute for independent advice tailored to your particular circumstances.

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