RTO Registration Checklist

Registering an RTO is a complex undertaking. There are many requirements in the application evidence which rely on in-depth knowledge and experience in RTO compliance for a successful RTO registration. My strong recommendation is to get some experienced advice, keep your application as simple as possible and be prepared to provide evidence of your readiness to deliver your nominated courses on request. Do not submit the application until you are ready. We have prepared this checklist to provide you a guide in navigating the RTO Registration process from start to finish. We hope this information is helpful and would ask that you consider our various products and services in the registration of your RTO.

  1. Familiarise yourself with the ASQA Application requirements.

Take the time in the beginning to familiarise yourself with the ASQA application requirements, including the ASQA Application Guide (click), the ASQA Self-assessment for initial RTO registration (click) and the General Direction for Resource requirements for Initial Registration (click). Reading these documents early gives you valuable context for everything else that will follow. You may also like to review some other articles on our website including RTO Setup Cost (click) and RTO Application Evidence Requirements (click). If you get through all of this information and you are still keen, that is a good sign.

  1. Undertake market research.

Research the market to identify the opportunity and viability of commencing a business as an RTO. This should include the identification of your target learner, specific training products and your preferred mode of delivery. Checkout this article provided by Business Queensland on methods for market research (click). Some useful information sources include the national training register to identify training products and current RTOs (click), the NCVER Visualisation Gallery to identify trends and opportunities in current RTO activity and VET data (click), Job Outlook to identify statistics on current occupations (click), the Labour Market Portal to identify current labour market trends (click), the My Skills website to research information on current providers (click) and of course, some good old fashioned Googling. What are you looking for? You are looking for under-serviced markets, opportunities that present from changing regulation, changes in work requirements, local training market opportunities or markets that are ripe for disruption. Try not to be all things to everyone. Work hard to identify a very specific market to enable you to concentrate your effort.

  1. Identify options for Learning and Assessment Material.

Research online and request samples from commercial suppliers of learning and assessment resources to evaluate the quality and format of available learning and assessment materials. Do not make the mistake of buying these too early. Just confirm your available options and evaluate the quality. Do not believe the supplier that their materials are fully compliant. Buyer beware! Get them evaluated by someone who is experienced at auditing learning and assessment materials and is independent. I would recommend you look for learning and assessment resources that are supplied in a digital or Word format. This enables you to customise these to your own mode of delivery and easily make improvements for compliance. Be aware that there are some resource suppliers that operate offshore and seem to offer every qualification possible at very low cost. You are seriously wasting your money with these suppliers. They are all form and no substance. This will be one of your major purchases in the registration of your RTO so take your time and do your research.

  1. Consider your statutory eligibility.

Review the Fit and Proper Person Requirements (click) to identify any issue that is going to exclude you as a fit and proper person. It’s good to identify this early. This can include criminal convictions, current bankruptcy, etc. We have seen ASQA accept the Fit and Proper Person status of an applicant where a criminal conviction is spent or the past bankruptcy is unencumbered. It is a matter of declaring these things very clearly.

  1. Prepare a Cash Flow Forecast.

To help you anticipate your expected revenue and operating costs, prepare a cash flow forecast for your planned RTO. Use the information you gathered during market research to make conservative estimates. This is a critical step in determining your business viability. The following tool is very useful for preparing a cash flow forecast (click). You are ultimately trying to establish that your proposed business will be profitable and you can maintain more asset than liability. Be conservative with your revenue estimates and a little generous with your cost estimates. Everything costs more that you first considered and you never quite get the student numbers that you initially thought possible.

  1. Consider the Financial Viability.

Investigate the financial viability requirements to register an RTO (click). This needs to consider if the business will be profitable, has sufficient cash asset to operate and more equity than debt. Keep in mind that financial viability is not about your personal finances. It is about the finances of the business entity that will apply to become an RTO. It is a good idea to talk with an experienced accountant early to consider the financial viability requirements. There seems to be a common myth that you need $50k in the bank to register an RTO. Seriously, this is total BS. The amount of cash (asset) you need at any time needs to be greater that your operating costs (liability). So if your operating costs over a given period will exceed your incoming revenue, then you will need to have enough cash to cover this cost, and then some. The amount of money you need as a start up will depend on your forecast operating cost. Hence the reason for the cash flow forecast at item 5.

  1. Establish your business entity (not applicable if an existing business).

We would typically recommend a Pty Ltd company to enable smoother change of ownership in the future. Also register for an ABN. Get advice from your accountant when selecting and establishing your business entity. Keep in mind that you can easily register a company yourself via the ASIC web-services (click).

  1. Select and register a business name (not applicable if an existing business).

Research and identify a business name that is available and register a website domain address to ensure these are secured early. Also consider registering any social media handles if this is a desired marketing channel. When you think of a business name, consider if your short, medium and long term goals or even the possibilities. I see client choose business names that immediately limit their geographic area of relevance or limit them to a narrow industry skill domain. Are you going to target a specific segment of the market with your business name or do you want to have the opportunity to be more universally relevant? You can also register your business name on the ASIC web-service (click). Make sure the business name is owned by the business entity and not by you personally. Don’t forget the domain name!

  1. Set up the Business Bank Account (not applicable if an existing business).

Establish a business bank account in the name of the business. Make an initial deposit in accordance with the owner equity (shares issued and value). Consider issuing additional shares in the company to deposit additional asset (cash) to meet start-up and early operating expenses. Seek advise from your qualified Accountant when making decisions about owner equity. Be aware that simply depositing your own personal funds into the business will technically act as a shareholder loan and can have the negative effect of blowing out your debt ratio in the financial viability risk assessment. The debt ratio requires that you have more equity than debt. So, if you drop 20k into the business as a personal deposit, you may have just given the business a debt of 20k. Talk to your Accountant about this.

  1. Understand your RTO obligations.

You seriously need to take some time to understand the requirements that apply to operating an RTO. I would strongly recommend reading the guidance at the following destinations:

  • RTO Requirements and responsibilities (click)
  • Users’ guide to the Standards for RTOs 2015 (click)
  • Newbery’s Audit Guide – Standards for RTOs 2015 (click)
  • ASQA Frequently Asked Questions (click)
  • ASQA Fact sheets (click)
  • ASQA Guides and tools (click)

If you are going to operate an RTO, you need to educate yourself. ASQA do not tolerate ignorance. I learnt as a very young soldier that knowledge dispels fear. The deeper and wider your knowledge and understanding of the requirements to operate an RTO, the greater control you will have over the process and the outcomes. You might be a really busy person and think that this information is more relevant for your RTO manager or your consultant. Listen to me! Carve out about 4 hours in your life and take the time to educate yourself about these obligations. You will thank me down the track.

  1. Find an RTO Consultant.

Engage an RTO consultant that knows what they are doing, will guide you through the application process and will teach you how to operate your RTO and about the RTO obligations. Be prepared to get your hands dirty and do not pay too much (click) 😊. We would be pleased to talk with you about how we can assist with your RTO registration.

  1. Develop your Training and Assessment Strategies.

For each of the courses that you intend to deliver, develop a training and assessment strategy that details the course delivery arrangements. Checkout our articles on the minimum requirements for developing a training and assessment strategy (click) which includes a free template to download. I would also strongly recommend a series of articles that we published on the requirements relating to the amount of training. Seriously, I know these are a mission to read but, if you can understand the requirements relating to the amount of training and volume of learning early, it will pay significant dividends in your RTO journey. You can access the articles on the following pages, Amount of Training – Part OnePart Two and Part Three. You will need to refine or complete your training and assessment strategies after you have completed your industry consultation and finalised your learning and assessment resources. The strategy is very much a live document that will continue to evolve right up to your application and beyond.

  1. Develop a course schedule.

To aid in planning the number of enrolments / courses for delivery in the first two years, prepare a detailed course schedule. Consider your available number of trainers and budgeted wages, the available equipment, the capacity of your training premises and the number of planned students per course. This planning will feed directly into your financial viability risk assessment and will help you to forecast student numbers within your capacity to deliver. The course schedule should show how your courses will be allocated to your classrooms or when your on-site course are to be delivered. This will be submitted with the application evidence so, make sure it is easy to understand and looks professional. Word doc or spreadsheet is fine. It is super important that your course schedule aligns with your forecast student numbers in the financial viability risk assessment.

  1. Develop your Business and Financial Plan.

These are important documents that will feed into your financial viability risk assessment. It will communicate your planned RTO operation (click). It is important to ensure that your business plan is consistent with all other documents submitted in the application. You do not want any contradictions, as an example, training and assessment strategies, fee schedules, course brochures, number of trainers, course schedule, et cetera. The following article provides some more detail on the type of information that the regulator will expect to see in you business plan (click).

  1. Undertake Industry Consultation.

Consult with employers to identify opportunities to customise your training and assessment to be relevant to industry requirements. Keep a detailed record of this consultation and the outcomes that informed your course development. Focus you industry consultation on the skills needed in the workplace, workplace operating procedures, equipment requirements, workplace documentation, et ectara. You need to submit evidence of your consultation so make sure it is presented professionally. Just a tip here. Letters of endorsement from industry are not relevant or valid evidence of industry consultation. It’s not about that. It is about you investigating the skills needs and work requirements in your target industry and showing how you have customised your proposed course to meet that need. Demonstrating outcomes of this investigation and development process is key.

  1. Acquire or Develop your Learning and Assessment Resources.

You will need learning and assessment resources that align with your training and assessment strategy and the requirements of the training package for each unit of competency. Take the time to customise these to your delivery model and organisation. Check and double check the mapping information and fix any gaps you find in the meeting of the unit of competency requirements. If applying for a qualification, you will need to submit a list of learning and assessment tools for each unit of competency within the qualification. I would always recommend purchasing materials supplied in Word under a licence. This allows the material to be properly customised. We strongly recommend getting a sample first before proceeding to purchase to properly evaluate the quality. If you don’t know what you are looking for, get some advice. You are particularly looking for assessments that have been designed. If you are looking at a sample assessment and the practical assessment instructions are basically the copied performance evidence statement from the unit and the observation record is comprised of copied performance criteria, forget about it! Keep looking for something that has been designed properly.

  1. Recruit your Trainers.

You will need sufficient trainers to support your initial cohort of students. You will need to submit evidence that trainers are competent in TAE40116, are current and competent in the units to be delivered and are engaged in ongoing PD. Checkout this helpful article on equivalent vocational competency (click). It is desirable that your nominated trainers complete some professional development specifically relating to delivering training and undertaking assessment. Evidence of this professional development should be submitted with the application. We offer the following professional development webinars which are pre-recorded and can be undertaken at anytime (click). Remember to submit complete evidence of your nominated trainer’s currency and competency including relevant qualifications, statements of attainment, CV/resume, recent professional development evidence and evidence of current industry skills and knowledge.

  1. Establish your Delivery Sites.

Organise your delivery sites according to your planned mode of delivery and training and assessment strategies. This may be evidenced by premises ownership, current lease, written agreement to rent or plans to hire premises as required. We recommend submitting a site plan, photos, completed WHS checklist and evidence of local government approval (if applicable) to demonstrate the site suitability. Your course schedule we discussed earlier will also be required to show how this site will be utilised. If you are not planning on having permanent delivery sites and intend to delivery training and assessment at your client’s premises (as an example a short course on working at heights), you will need a comprehensive checklist for each course to confirm the site suitability and access to the required equipment and resources on-site. You are basically outsourcing the premises cost to your client, so it comes with the obligation to verify the site suitability each time. The checklist will need to make sure that you have access to suitable space, facilities and equipment in accordance with the requirements of the training and assessment to be delivered. Just a tip here, keep an eye on the assessment conditions within your nominated units of competency.

  1. Establish Trainer Agreements.

You need to submit with the application evidence of each trainer’s agreement in the form of an employment agreement, or contract agreement, or letter of acceptance for employment once registration has been granted. Check out the guidance on evidence required in relation to nominated trainer engagement (click).

  1. Prepare your access to Equipment and Resources.

Acquire equipment and resources to support the delivery of your training and assessment in accordance with your developed training and assessment strategies and the requirements of the relevant training package. Make sure this list shows the quantities relevant to your planned number of learners and it complies with the requirements of the assessment conditions. Also refer to item 18 in regards to verifying equipment and resources when delivering training and assessment on-site.

  1. Establish your Learner Support arrangements.

Prepare evidence of your learner support arrangements including your arrangements to confirm a learner’s core skills to identify support needs and to provide learner support services such as additional learning support, access support, admin support, et cetera. Provide evidence of these arrangements including any policy and procedure, LLN assessment tools, intake forms, et cetera.

  1. Develop Marketing Material.

Create your marketing material such as course brochures to advertise your intended course. This marketing material should align with course delivery arrangements outlined within your training and assessment strategy and business plan. Checkout this fact sheet (click).

  1. Develop Pre-enrolment Documentation.

Establish your pre-enrolment information documents to inform learners about their rights and obligations prior to their enrolment including a Student Handbook. The Student Handbook will complement the marketing material and fee information. You should also include evidence of your enrolment procedure and tools that shows how learners are engaged prior to their enrolment of commencement.

  1. Develop your Fee Schedule.

The Fee Schedule is required to advise the learner of their consumer rights and fee payment requirements. The fees must align with you business and financial plan and fee protection requirements. Make sure that your schedule of payments complies with the fee protection requirements that apply to payments in advance of services being delivered. Check out this article (click).

  1. Set-up your Student Management Software.

Subscribe to a student management software to enable you to report your AVETMISS activity data and manage your learner enrolments and training operation. You must submit evidence of having a subscription to an AVETMISS compliant software. We have provided a leading student management software since 2009. Request a free trial and orientation session of RTO Data Cloud (click).

  1. Produce your AQF Certificates.

Prepare an example of your Qualification Certificate and Statement of Attainment to be submitted with the application to demonstrate your compliance with the required certificate format. Checkout the guidance available at the following page (click). We would also recommend that you submit with the application a certificate issuance policy and procedure.

  1. Develop RTO Policy and Procedure.

Develop or customise your RTO Policy and Procedure to demonstrate your arrangements to comply with the Standards for RTOs. Submit policies with your application such as enrolment, certification, fee collection, marketing, assessment, trainer management, mandatory reporting, et cetera. Check out (click).

  1. Complete Financial Viability Risk Assessment.

Finalise your Financial Viability Risk Assessment with your Accountant. The evidence to be submitted in one zip folder includes the completed Financial Viability Risk Assessment Tool (click), business plan, signed accountant certificate and supporting evidence such as bank statements, ATO integrated client account statement, financial statements, et cetera.

  1. Prepare your Business Entity Documents.

Prepare your Business Entity Documents to be submitted with the application including details of ABN registration, company certificate, company historical extract, trust deed (if applicable). If your applicant entity is owned by another entity such as another company, you will also be asked to upload the company historical extract for the owner entity as well.

  1. Complete Declarations for submission.

Complete Declarations for submission with the application including a Fit and Proper Person Declarations (click) by all owners and the nominated CEO and the CEO Declaration which is accessed on ASQAnet when preparing the application.

  1. Organise and Upload your Application Evidence.

Organise and Upload your Application Evidence with the application by creating a series of zip folders numbered according to the sections of the self-assessment (click). You can upload as many zip folders as required and keep each zip folder less than 12-13 MB otherwise it will not upload. I recommend that you PDF all Word documents to ensure that the files are stable when opened. Make sure you logically and professionally name each folder and file. Presenting evidence in a professional way makes a big difference to how these documents are received.

  1. Complete the Self-assessment for Registration as an RTO.

Complete the Self-assessment for Registration as an RTO (click). Complete each section very carefully including sections that start with “Provide information to support your compliance” where you should list all documents being submitted for each section. Getting an external Desk Audit (click) is not a bad strategy to identify any significant issues, so these can be addressed prior to your submission. This may identify issues in your learning and assessment resources which you can work on whilst waiting for ASQA to respond to the application.

  1. Register for ASQAnet, Load and Submit the Application.

Register for ASQAnet and complete application for RTO registration (click). If you get stuck, call the ASQA info line (1300 701 801). Keep in mind that once you submit Part A, you cannot go back. If you forgot to upload something important, you will need to start over, trust me, I know. In this instance, send an email to ASQA enquires and request them to delete the Part A application. This is the only way to do this. You then select your scope and complete Part B and pay the initial application fee of $500. You can then have a little celebration (not too big). If you have completed the application properly, you will get an email from the ASQA Melbourne crew confirming that the application was accepted and will give you another invoice, this time for $8,000.00. Once this is paid, you can expect to then wait 12-16 weeks for someone from ASQA to get in contact. Most of these initial registration applications are handled by the Darwin office and they are completely under resourced. Use this time to fine tune your learning and assessment tools and resources.

  1. Develop your RTO website.

A good activity to complete in the 3 months you are waiting for ASQA to respond is to develop your website for your proposed RTO. For many RTOs, the website is their shopfront. It is so critical to have a professional online presence that makes the marketing and enrolment process easy. Desirably, your website will integrate with your student management system such as RTO Data Cloud (click) to enable your course information to be displayed in your marketing, a course calendar based on your scheduled courses and to invite and accept online enrolments. It is best to keep your website off the web until your RTO is approved. The challenge with website development is finding a developer that you can trust and will produce a high quality website at a reasonable cost. We can absolutely recommend Debi Hazelden at Noosa Website Design who specialises in RTO website development and integration of RTO Data Cloud (click).

  1. Participate in the Verification Meeting.

ASQA generally do not do initial registration site audits any more. Since about mid 2018, they review all of the application evidence as a desk audit based on the evidence submitted with the application. If you have applied for a qualification, they will request a sample of 2-3 units of competency learning and assessment resources for each qualification as part of the desk audit. The verification meeting will really just focus on anything that they have identified from the desk audit. In our experience, this meeting is typically a phone call or video call and generally goes for about 40-60 minutes. Also be aware that you will only get about 24 hours notice to supply the requested learning and assessment resources, so you need to be ready for this request.

  1. Respond to any non-compliance

Obviously it is possible to have some non-compliances that need to be resolved. It happens. Take the time to understand the non-compliances and manage the process to respond to ASQA. If you do not understand the non-compliances, get some advice. You simply don’t know what you don’t know, so come to terms with your situation quickly and get some advice. Outcomes from the audit can range from:

  • application approved – fully compliant, well done 😊,
  • application approved – with minor deficiencies,
  • application approved – with a Written Direction to rectify,
  • application rejected – with the opportunity to request a Reconsideration of the Decision.

If you find yourself in the position of needing to request a Reconsideration of the Decision, you need to get seriously organised and get some advice. The audit reports are generally very cryptic, report only on exception and only give you examples. If they give you an example, you need to consider the same finding of that example across everything. If you need some help to respond to a non-compliant application outcome, you can consider our service designed to assist you through this process (click).

  1. Registration Approved

Woohoo! Your RTO is approved and you are up on the national training register. Well done. Time to celebrate (this time, go big!). You can make your website public and start the marketing. Don’t forget at this point to get your Public Liability insurance before you commence operating (click). Also, take note of any reporting obligations that you may need to comply with (click). Good luck and stay on top of your administration and compliance. ASQA will be back for your renewal of registration in only 24 months and will do an audit to make sure you are flying straight. After that you can expect a registration period of seven years if ASQA are satisfied with the services you are delivering. Good training!


Wow! I know this is a big list. But, it should provide you sufficient guidance to navigate the process yourself with a little timely advice which of course we are happy to provide (click). If instead you would like more complete support to register your RTO, you may like to review our RTO registration services (Domestic or CRICOS). If you are registering an RTO and would like to adopt RTO Data Cloud (click) as your student management software, get in contact with us and we can let you know about some special offers that we have for businesses that are in the process of navigating RTO registration.

Last point, beware of consultants that try to make it all sound too easy or claim to do everything for you. This is never the reality. You want a consultant that is a partner in the journey, that will be brutally honest with you and can educate you along the way. When your RTO hits Training.gov.au you need to have a fundamental knowledge about your RTO and your compliance obligations. Your consultant should be a teacher, a mentor, a friend and someone you can rely on to tell you when you are heading in the wrong direction. If you are serious about registering an RTO, please get in contact with us and we are happy to have a discussion. I hope this information has been helpful and I wish you well in your journey to become an RTO.

Good training,

Joe Newbery

Published: 22nd March 2021

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