The most recent of these trends is the regulatory focus on fees paid in advance for services being delivered. In the past three or four months, I have noticed a spike in audit outcomes that include findings in relation to fees paid in advance. I have also received an increased number of questions from clients about the rules relating to students paying fees in advance for services being delivered particularly in relation to the shift toward virtual service delivery. Clause 7.3 of the Standards for Registered Training Organisations (RTOs) 2015, specifically says the following:

“7.3. Where the RTO requires, either directly or through a third party, a prospective or current learner to prepay fees in excess of a total of $1500 (being the threshold prepaid fee amount), the RTO must meet the requirements set out in the Requirements for Fee Protection in Schedule 6.”


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