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NQF Review proposals include increasing record keeping to 45 years

Contextually, it was the Royal Commission into Institutional Responses to Child Sexual Abuse ( that recommended the retention of records for 45 years.

It is the view of the Australian Childcare Alliance (ACA) NSW that the Review of the NQF and the Regulatory Authorities do not quickly embrace such a recommendation until whole-of-governments consider and adopt harmonised requirements.

Apart from the potential for additional operational cost to services, ACA NSW’s immediate concerns about the ability to retain such records for a period of 45 years include:

  • which software and hardware can be guaranteed to be available for a minimum of 45 years?
  • can all relevant persons be available and memories be reliable in up to 45 years’ time to confirm the record(s)’ accuracy and validity?
  • would Approved Providers be still operational in up to 45 years’ time?
  • who would be responsible to the records if the Approved Provider cease to exist within the 45 year period?
  • what are the obligations of and consequences to future successors to Approved Providers?

Only after when whole-of-governments propose plausible, cost-effective and feasible solutions (including state/territory governments bearing such costs and responsibilities) should then the early childhood education and care sector consider these solutions and not before.

ACA NSW has published the following documents that will help Approved Providers and services understand all the issues and assist them with their responses via the NQF Review’s via survey and written submission:

By copying-and-pasting some or all of the Template Response’s content, or developing your own responses, it is nonetheless ACA NSW’s most fervent recommendation that Approved Providers and services submit responses to BOTH channels (ie via the survey as well as the written submission).

Please note that all responses are due by 30 April 2021.

The last two live and interactive sessions where the Review of the NQF can still be discussed are:

And if you require any further information/clarification, please contact ACA NSW via 1300 556 330 or

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