Is Your Organisation Child Safe?

The Law Has Changed: What You Need to Know 

Queensland’s Child Safe Organisations Act 2024 came into effect from 1 October 2025. It is the most significant overhaul of child safeguarding obligations for employers and organisations in Queensland’s history — and it applies to approximately 40,000 organisations across the state. 

The Act creates two distinct but complementary obligations that work together to protect children: 

• The 10 Child Safe Standards — mandatory for all organisations that provide services or spaces specifically for children 
• The Reportable Conduct Scheme — a legal duty to report and investigate allegations of child abuse or misconduct by staff and volunteers, which came into effect on 1 July 2026 

The Queensland Family and Child Commission (QFCC) is the independent oversight body responsible for administering and enforcing the system. For authoritative information, including self-assessment tools and implementation guidelines, visit qfcc.qld.gov.au/childsafe. 

Does This Apply to Your Organisation? 

The Act applies to organisations that provide services or spaces specifically for children — meaning some or all of their services, activities or programs are aimed at children, or have a special application for children in the way they are delivered. 

If your organisation falls into any of the following categories, you are in scope: 

• Local government and councils — particularly where you operate aquatic centres, sport and recreation facilities, libraries, youth services or community programs 
• Early childhood education and care (ECEC) — long day care, family day care, kindergartens, out-of-school-hours care (OSHC), nannies and in-home carers 
• Schools — state, independent and private, including international secondary exchange programs 
• Universities, TAFEs and registered training organisations (RTOs) 
• Health service providers — including allied health, pathology, speech pathology and community health services 
• Disability service providers 
• Sporting clubs and recreation organisations — including swim clubs, tennis centres, gyms and out-of-school activity providers 
• Religious and faith-based organisations 
• Youth, community and not-for-profit organisations 
• Queensland Government departments and statutory authorities 
• Tutoring businesses, play centres and other commercial services for children 
• Transport providers specifically serving children 

One important clarification: if your organisation provides services for both adults and children, you may still be a child safe entity — the Act applies to the whole organisation, not just the child-facing parts of your operation. 

The 10 Child Safe Standards: What They Mean for Employers 

The 10 Child Safe Standards set out what your organisation must do — systemically and demonstrably — to create environments that prioritise children’s safety and wellbeing. These are not aspirational values or policy statements. They are legal obligations that require documented evidence, functioning systems and embedded practice. 

Standard 1 — Leadership and Culture 

Child safety and wellbeing must be embedded in your organisation’s leadership, governance and culture. This means a named accountable leader, board or executive-level risk reporting on child safety, a public commitment to child safety, and a culture where child safety is a genuine organisational value — not a compliance checkbox. 

Standard 2 — Voice of Children 

Children must be informed about their rights, given opportunities to participate in decisions that affect them, and taken seriously when they raise concerns. For HR and people teams, this has direct implications for how complaint-handling processes are designed and how children’s disclosures are treated. 

Standard 3 — Families and Communities 

Families and communities must be informed and involved in the organisation’s approach to child safety. This includes transparent communication, accessible grievance pathways, and culturally appropriate engagement. 

Standard 4 — Equity and Diversity 

The organisation must actively uphold children’s equity and respect their diverse needs — including children with disability, children from culturally and linguistically diverse backgrounds, and children at heightened risk. 

Standard 5 — Suitability of People Working with Children 

This is one of the most significant Standards from an HR perspective. Organisations must ensure that everyone who works with children is suitable, properly supported and appropriately supervised. In practice, this means: 

• Blue card verification built into every recruitment process 
• Child safety requirements written into position descriptions and performance frameworks 
• Structured induction covering child safe obligations 
• Ongoing supervision and monitoring 
• Clear processes for managing conduct concerns involving staff or volunteers 

Standard 6 — Complaints and Concerns 

Your organisation must have a child-focused, accessible and clearly communicated process for raising concerns or complaints about child safety. Staff, volunteers, children and families all need to know what it is and how to use it. 

Standard 7 — Staff Equipped Through Education and Training 

All staff and volunteers must receive role-appropriate, ongoing education and training on child safety. Not a once-and-done induction module — ongoing, evidenced and fit for purpose. Training must cover child safe behaviours, responding to disclosures, and each person’s obligations under the law. 

Standard 8 — Safe Physical and Online Environments 

Your physical environments and digital spaces must be designed and managed to minimise the opportunity for harm. This includes site design, supervision ratios, device and technology policies, and social media governance. 

Standard 9 — Continuous Improvement 

Your organisation must review and improve its child safety practices on a regular, documented basis. The QFCC can direct the head of an entity to complete a self-assessment and provide a report — so this is an audit-readiness obligation, not just good practice. 

Standard 10 — Documented Policies and Procedures 

Your policies and procedures must document how your organisation keeps children safe — and they must be current, accessible and actually used. This is where many organisations find their biggest gap: having some documents is not the same as having a compliant, coherent policy suite. 

The Universal Principle: Cultural Safety for Aboriginal and Torres Strait Islander Children 

Running through all 10 Standards is the Universal Principle, which requires organisations to actively promote and uphold the right to cultural safety for Aboriginal and Torres Strait Islander children. This means creating environments where First Nations children feel welcome, safe, valued, included and respected — not just protected from harm. 

A lack of cultural safety is itself a form of harm under the Act. This principle must be embedded throughout your approach to child safety, not addressed as a standalone initiative. 

The Reportable Conduct Scheme: The 1 July 2026 Obligation 

While the 10 Standards have been in force since late 2025, the Reportable Conduct Scheme is now live as of 1 July 2026 for organisations with a high degree of responsibility for children — including councils, early childhood and care services, schools, disability services, youth services, health providers, sporting clubs, religious organisations and community organisations. 

Under the Scheme, the head of the organisation — typically the CEO, Principal Officer or equivalent — is personally and legally responsible for: 

• Having systems in place that allow concerns about a worker’s conduct to be raised internally 
• Notifying the QFCC within three business days of becoming aware of a reportable allegation or conviction 
• Commencing an internal investigation as soon as practicable 
• Providing interim and final reports to the QFCC, including investigation findings 
• Managing interim risk to children while an investigation is underway 
• Referring matters to police promptly where conduct may be criminal