Updated VRQA Guidelines Increase Governance Requirements for Victorian Schools

16 May 2019

The Victorian Registration & Qualifications Authority (VRQA)’s updated Guidelines to the Minimum Standards and Requirements for School Registration (the 2019 Guidelines) commenced on 1 January 2019. To attain or maintain registration in Victoria, schools must meet the Minimum Standards and other requirements for registration as set in Schedule 4 of the Education and Training Reform Regulations 2017 (Vic)(2017 Regulations). The 2019 Guidelines outline requirements that non-Catholic non-government schools must fulfil in order to meet the Minimum Standards for registration by 1 July 2019. Catholic schools must already be complying with the 2019 Guidelines.

For the first time, the VRQA has provided a useful factsheet summarising the changes introduced by the 2019 Guidelines, available here . CompliSpace has also created a briefing paper  describing the changes contained in the 2019 Guidelines and how schools can meet these new requirements. This article discusses some of the changes described in those two resources in more detail.

Key Changes in the 2019 Guidelines: School Governance & Care, Safety and Welfare of Students

The 2019 Guidelines have broadly retained the same structure as the 2018 Guidelines, with the exception of updating the titles of a number of subsections to better reflect the language of the Minimum Standards. The more substantial changes are in the evidentiary requirements schools must meet to demonstrate compliance with the Standards.

School Governance


Schools must now maintain a ‘conflict of interest register’ for all “responsible persons”, as well as provide an explanation of how a conflict would be managed. Responsible persons is a defined term in the 2017 Regulations and a school must be able to identify who their RPs’’ are in order to effectively identify and manage any conflicts of interest that may arise.

The 2019 Guidelines additionally require that schools must have evidence of:

  • details of the member(s) of the company, if the school is a company limited by guarantee
  • copies of all delegations from the school’s governing body.

Not-for-Profit Status

The 2019 Guidelines have increased the requirements that schools must meet to demonstrate their not-for-profit status. New requirements include maintaining:

  • copies of contracts or arrangements with third parties
  • copies of loan agreements, guarantees and the like to or from third parties including related entities and/or affiliated organisations
  • details of the related entity and/or affiliated organisation and the relationship between the school and that entity.

Schools musts also ensure that there is a legally binding written agreement for any loans or arrangements for the delivery of services to the school, including for administrative, management and financial services.


Schools must now maintain a list of each responsible person, their role and a summary of their qualifications and experience.


The 2019 Guidelines require schools to be able to show exactly how their philosophy is enacted.

Care, Safety and Welfare of Students

The 2019 Guidelines now include a requirement for schools to have policies and procedures in place for when it may be necessary to use restrictive interventions’’ to protect the safety of a student and members of the school community. Unfortunately, the VRQA does not define what restrictive interventions’’ are. That term has licensing obligations when used in the disability context and the Department of Health and Human Services has more information on this area. In the school context, it is understood that the term ‘’restrictive interventions’’ is intended to mean restraint practices however if a school is a recognised disability service provider they may have the authority to also use restrictive interventions as recognised by the Disability Act 2006 (Vic).

Schools are now also required to have policies and procedures in place for managing complaints and grievances, and detail how these policies and procedures are made accessible to the school community. Refer to CompliSpace’s briefing paper for more information about how to implement a complaints handling program.

Student Behaviour Management (Discipline)

The 2019 Guidelines require schools to evidence their approach to behaviour management, including the school’s steps for managing suspensions and expulsions for students. While government schools must meet a Ministerial Order (No. 1125 – Procedures for Suspension and Expulsion of Students in Government Schools) as part of managing suspensions and expulsions, the Ministerial Order does not apply to non-government schools. That said, the Ministerial Order may provide useful guidance for non-government schools in developing behaviour management policies and procedures.

Attendance Monitoring

Schools must now provide evidence of their attendance monitoring procedures including how they:

  • identify the person(s) with responsibility for monitoring daily attendance
  • follow up unexplained absences on the day of a student’s absence
  • accurately record attendance on student files.

Curriculum and Student Learning

Curriculum Framework

Schools must now have a curriculum plan in place that shows how:

  • learning areas will be addressed
  • the school’s curriculum will be organised and implemented.

Student Learning and Outcomes

The 2019 Guidelines now require schools to ensure that their documented strategy for improving student learning outcomes addresses the following:

  • policies and procedures for reviewing the curriculum and teaching practices
  • the processes that the school will use to set goals and targets for outcomes including students at risk.

In order to achieve the above, schools will need to develop strong frameworks so that different stakeholders in the school community can collaboratively provide an improved learning environment and outcomes for students. One method that schools can employ to identify and effectively manage areas for improvement is the collection and interpretation of data.

For Schools Offering a Senior Secondary Course

The following updates in the 2019 Guidelines are relevant for schools offering, or applying to offer, senior secondary qualifications such as VCE, VCAL and the IB Diploma.

Governance and Probity

Schools are now required to prove that they have adequate risk management procedures in place to ensure that senior students in their final year of study will not have their studies affected by financial mismanagement or teacher inexperienced. This requires schools to evidence that:

  • the physical environment is sufficient to support the delivery of the course
  • teachers are suitably qualified and experienced
  • there are procedures to support students to undertake a course best suited to their abilities
  • there are sufficient financial resources to deliver the courses to the standards of the awarding body.

Teaching and Learning

The 2019 Guidelines now requires schools offering senior secondary qualifications to evidence that their teaching and assessment of the relevant qualification is valid. This requires proof of expanded policies and procedures to:

  • ensure the assessment of senior secondary courses is fair, valid and reliable
  • address cheating including plagiarism
  • conduct investigations and hearings and if necessary amend or cancel assessments.

The 2019 Guidelines now also require schools to provide evidence that a student handbook and resources containing the senior secondary course rules and assessment procedures are made available to students and relevant school community members.

What Should Schools Do Now?

All registered non-government schools must comply with the 2019 Guidelines by 1 July 2019. Schools should be proactive and start to update their policies and procedures now to ensure that they are ready by that deadline. The fact that the VRQA has helpfully issued a fact sheet helping schools to identify the changes in the 2019 Guidelines suggests that schools should not delay in ensuring that they are compliant.

Soo Choi

Soo Choi is a Legal Research Assistant at CompliSpace. She is currently studying a Bachelor of Arts and Bachelor of Laws at the University of Sydney.