September 2025 marked the most significant amendment to child safety obligations under the Education and Care Services National Law 2010 since the National Quality Framework was introduced. Two changes in particular have fundamentally altered the compliance landscape for every approved provider in Australia — and many services are still not fully across what they mean in practice.
This article explains both changes in plain English, walks through what they require of your service operationally, and tells you exactly which of your policies, SOPs and registers need to be reviewed and updated if you have not already done so.
The Two Key Changes
Change 1 — Physical and Sexual Abuse Now Requires 24-Hour Notification
Prior to September 2025 the National Law required services to notify the regulatory authority of a notifiable incident as soon as practicable. For most incidents the practical timeframe was within 24 hours, but for allegations of physical or sexual abuse there was no explicit 24-hour deadline written into the legislation — it was a matter of what was practicable in the circumstances. That ambiguity allowed some services to defer reporting while they investigated internally, and in the worst cases to never report at all.
The September 2025 amendment removed that ambiguity. From 1 September 2025, where a child has been physically or sexually abused, or where an allegation of physical or sexual abuse has been made, the approved provider must notify the regulatory authority within 24 hours — no exceptions, no discretion. A service that notifies at 25 hours is in breach. The regulatory authority must also receive a written notification within 7 days of the verbal or electronic notification.
What this means operationally is that your nominated supervisor must have a clear, practised protocol for the moment an allegation is made. The clock starts from the moment the approved provider becomes aware — not from when the incident is confirmed or investigated. An allegation alone is sufficient to trigger the obligation. That includes a disclosure from a child, a concern raised by a parent, an observation by an educator, or an external report from another agency.
Practically this requires three things. First, every educator must know the immediate escalation pathway and must escalate to the nominated supervisor without delay — not at the end of the shift, not the next morning. Second, the nominated supervisor must have the regulatory authority phone number and online notification portal bookmarked and accessible at all times, including after hours. Third, the service needs a written record of when awareness occurred so the 24-hour clock can be evidenced if questioned later.
Change 2 — The National Early Childhood Worker Register
The second major change — with a slightly later implementation date of 27 February 2026 — is the introduction of the National Early Childhood Worker Register. This is a national register of all persons working in early childhood education and care services across Australia, accessible to every state and territory regulator.
From 27 February 2026, approved providers are required to enter all staff on the register before they commence work with children. This is in addition to — not instead of — the existing Working With Children Check requirements in each state and territory. A person must have both a current state WWCC and an entry on the National Register to legally work with children in an ECEC service.
The register serves two purposes. It creates national visibility of who is working in the sector, and it provides a mechanism for regulatory authorities to flag concerns about a person across state borders — something that was not previously possible under the state-based WWCC systems alone. A person de-registered in one state cannot quietly relocate and resume work in another.
Who must be entered: all educators, nominated supervisors, and approved providers who work directly with children. Volunteers and students on placement must also be entered where they engage in regulated activities. Cleaners and contractors who do not have contact with children during operating hours are excluded.
What approved providers must do: register on the National Register portal, enter all current staff before 27 February 2026, and enter new staff before their first day of work from that date onwards.
Which Documents Need Updating
The amendments have a knock-on effect across most of a service's compliance suite. At minimum the following documents require review and republication:
- Child Safety and Wellbeing Policy must reference the 24-hour notification obligation explicitly, with the regulatory authority contact details current to your state.
- Incident, Injury, Trauma and Illness Policy must be updated with the new timeframe and the distinction between general notifiable incidents and the new 24-hour category.
- Incident Response SOP must have the 24-hour deadline built into the step-by-step procedure as a numbered, time-stamped step.
- Staff Qualifications Register must include a column for National Register entry date alongside WWCC details.
- Staff Induction Procedure and Induction Checklist must include National Register entry as a pre-employment requirement from 27 February 2026.
- Code of Conduct must reference the digital device and photography provisions introduced alongside the 2025 amendments.
What to Do Right Now — Action Checklist
- Review your Child Safety and Wellbeing Policy and confirm it references the 24-hour notification obligation for physical and sexual abuse allegations.
- Brief your nominated supervisor and all educators on the 24-hour rule — the clock starts from awareness, not confirmation.
- Post the regulatory authority contact number prominently in the staff area so it is immediately accessible when needed.
- Check that your Incident Response SOP includes the 24-hour deadline as a specific, numbered step with a timestamp field.
- Create an account on the National Early Childhood Worker Register portal now — do not wait until February 2026.
- Begin entering current staff on the register progressively so you are not doing it all at once at the deadline.
- Update your Staff Induction Procedure and Induction Checklist to include National Register entry as a day-one requirement from 27 February 2026.
- Review your Staff Qualifications and WWCC Register template to ensure it includes a National Register entry date column.
The Cost of Non-Compliance
A breach of the 24-hour notification obligation is not a minor administrative issue. The regulatory authority can issue a compliance notice, place conditions on the service approval, require the provider to demonstrate improvement against a defined plan, and in serious cases suspend or cancel the service approval entirely. The authority can also conduct unannounced compliance visits and may request to sight incident registers and notification records at any time. A pattern of late notifications — even by a few hours — will be treated as evidence of systemic failure, not isolated oversight.
For the National Register, allowing a person to work with children without an entry is itself an offence under the amended National Law. There is no discretionary period after 27 February 2026 to "catch up" — the obligation crystallises on the day.
The Bottom Line
The 2025 amendments are not bureaucratic box-ticking. They reflect a genuine legislative intent to make child safety in Australian ECEC services faster, more visible, and harder to avoid. The 24-hour notification rule removes the discretion that previously allowed some services to delay reporting while they managed the situation internally. The National Register removes the gaps between state-based screening systems that have allowed unsuitable persons to move between states and continue working with children.
For a well-run service with good documentation practices these changes are manageable. The challenge is for services that have been relying on informal processes and outdated templates. If your policies still say "as soon as practicable" without specifying the 24-hour timeframe, your procedures need updating today.