Newbery’s Audit Guide – Clause 3.4


What the clause requires:

3.4 Records of learner AQF certification documentation are maintained by the RTO in accordance with the requirements of Schedule 5 and are accessible to current and past learners.


What is this clause about:

This clause is about ensuring that as an RTO you can provide current learners with access to their AQF records which includes details of their current progression in the course they are enrolled. It also requires that past learner can request and receive a re-issued or replacement certificate based on the course which they have completed. Schedule 5 of the RTO standards also requires that the RTO maintain a register of all qualifications and statements of attainment issued. In reality, this register is the RTO’s student management system which should be capable of producing a report over any given timeframe of statements of attainment and qualifications it has issued. Some auditors tend to apply their personal preferences about what shape and form this “register’ should take. There is no definition or specification in the RTO standards or the AQF so this requirement is quite subjective. I recommend that it be detailed and able to be printed in a hard copy format. The critical information is the learner’s details, the qualification or units of competency they achieved and the date of achievement.

A good question to ask in considering this clause is how you would issue a learner who is currently enrolled with a report on the outcomes they have achieved and they are enrolled in. RTO’s have many and varied answers to this question and in their arrangements to report this information. There is technically no guidance to specify how this should occur. The best advice that I can provide and what has been a successful approach for over a decade is to issue the currently enrolled learner with a record of results. The record of results is recognised within the AQF but when issued independently from the qualification it is not an official AQF certificate but is more an administrative record that reports the current stage of the learner’s progression. Most student management systems have the capability to produce a record of results for are currently enrolled learner.


You must be able to demonstrate that:

You maintain a register of all statements of attainment and qualifications issued

You retain records of AQF outcomes issued for a period of 30 years.

You can issue current learners with a record of their results or transcript

You can issue past learners with a replacement AQF certificate

you manage AQF records with integrity and accuracy


Evidence to prepare:

Access to learner records relating to AQF outcomes issued.

Access to the student management system to verify outcomes appearing on sampled AQF certificates.

A register of all statements of attainments issued

A register of AQF qualifications issued

Can verify that all AQF outcome records are retained for a period of 30 years. The auditor may choose to request records of outcomes the RTO issued in the first year of the registration to verify this.

Evidence of the arrangements to issue a past or current learner with a replacement certificate or a record of results detailing the learner’s current progression.


You should prepare for these types of questions:

Can you show me in your student management system how you can produce a register of all statements of attainment and qualification is issued?

I see that you were initially registered in 2003. Are you able to access the data of your issued AQF outcomes from this period?

Do you have any policy and procedure around record management relating to the retention of your AQF records for 30 years?

Are you able to provide me an example of how you have reissued an AQF certificate to a past learner?

If a learner’s employer requested that the learner obtain a record from the RTO that details their current stage of progression, how would you report this?


Published by: Joe Newbery, released 2nd May 2017

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