Join ACA NSW Sign in

NQF Review proposes to replace 3rd & 4th ECTs with Suitably Qualified Persons

On page 92 of the Consultation Regulatory Impact Statement (CRIS), the Review of the NQF is proposing to replace the 3rd and 4th degree-qualified Early Childhood Teacher with Suitably Qualified Persons.


The NQF Review confirmed that the number of waivers to Regulation 272 (which imposes the 3rd and 4th ECTs on NSW-based services) issued by the NSW Department of Education have been increasing, suggesting that this may not be sustainable due to severe labour shortages (see Page  24 of https://childcarealliance.org.au/documents/reports-of-interest/161-aca-pre-budget-submission-dec-2020/file).


Interestingly, the NSW Productivity Commissioner’s Green Paper had identified NSW’s higher requirements are out-of-step with all other Australian states and bears negative consequences (https://nsw.childcarealliance.org.au/news/939-aca-nsw-asks-nsw-government-to-financially-offset-more-costly-nsw-regulations-toward-achieving-parity-with-other-states-and-fee-affordability-for-parents).


The Australian Childcare Alliance (ACA) NSW has already calculated that the effect of Regulation 272 increased labour costs at services by up to 17.44% (see Section 2.1 of A State of Possibilities – Volume 1: Immediate Solutions (https://nsw.childcarealliance.org.au/images/2021/Documents/ACA_NSW_-_A_State_of_Possibilities_-_Vol_1_-_Immediate_Solutions.pdf).


Moreover, we understand that services in other states/territories (outside of NSW) have found difficulty in recruiting their equivalents of Suitably Qualified Persons when their ECT requirements were increased from 1 to up to 2 ECTs.


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 live and interactive session where the Review of the NQF can still be discussed is:



And if you require any further information/clarification, please contact ACA NSW via 1300 556 330 or nsw@childcarealliance.org.au.


Related Articles (links available upon release):



PUBLISHED: 27 APRIL 2021