Fit and Proper Person Requirements: What RTO Owners and Managers Should Know

If you own, direct or manage a Registered Training Organisation, the Fit and Proper Person Requirements are no longer a box you tick once at registration and forget. Under the 2025 Standards for RTOs — in full effect since 1 July 2025 — they are an ongoing, active obligation that sits at the centre of how your RTO is governed. This guide explains what the Fit and Proper Person Requirements mean for RTO leadership and ownership, who they apply to, and the practical steps you should be taking now.

What Are the Fit and Proper Person Requirements?

The Fit and Proper Person Requirements (FPPRs) set out the character, conduct and integrity expectations for the people who control and influence an RTO. They exist so that learners, employers and the wider community can have confidence in the people running vocational education and training providers.

Under the 2025 Standards, the requirements appear in two connected places: Schedule 1 of the Compliance Standards, which contains the Fit and Proper Person Requirements themselves, and Part 4 of the Outcome Standards, which deals with the governance and accountability of an RTO's key people. Read together, they link individual suitability, organisational governance and the quality outcomes your RTO is expected to deliver.

Importantly, ASQA treats the FPPRs as a positive obligation. That means your RTO is expected to actively educate and monitor its people on an ongoing basis — not simply assume everyone remains fit and proper because they were assessed once.

Who the Fit and Proper Person Requirements Apply To

A common and costly mistake is assuming the requirements apply only to the CEO. They don't. The FPPRs apply to every "governing person" — defined as any person responsible for overseeing, directing, or exercising a degree of control or influence over the management or operation of the RTO.

In practice, that can include:

• Owners and shareholders with control or influence

• Directors and board members, including non-executive directors

• The CEO and senior managers

• Any other person who genuinely steers decisions, even without a formal title

Your first job is to correctly identify all of your governing persons. Missing one is one of the most frequent compliance failures ASQA sees in this area.

What ASQA Considers When Assessing Fitness and Propriety

When the regulator assesses whether someone meets the Fit and Proper Person Requirements, it looks at more than a single event. Key considerations include:

• Compliance with the law. Whether the person has been found guilty of an offence or ordered to pay a penalty under Commonwealth, state or territory law — regardless of whether a conviction was recorded — along with the seriousness of the matter and how much time has passed.

• History in vocational education. Whether the person has previously been found not to be fit and proper, or has a pattern of conduct raising concern.

• Broader conduct and integrity. Any deliberate or ongoing pattern of unethical behaviour, even where individual incidents seem limited.

• Public confidence. How the person's involvement in the RTO is likely to be viewed by learners, industry and the community.

• Conflicts of interest. Real or apparent conflicts must be identified, managed and disclosed.

Your Ongoing Obligations Under the Fit and Proper Person Requirements

Meeting the Fit and Proper Person Requirements is a continuous process, not a one-off declaration. RTO owners and managers should be across the following.

The Fit and Proper Person Declaration

Every governing person must submit a full and frank Fit and Proper Person Declaration to ASQA when they commence, and again whenever there is a change in circumstance that could affect their fitness and propriety. Silence, delay or partial disclosure is often treated as a bigger risk than the underlying issue itself — openness and timeliness matter.

RTOs are also asked to confirm their position through ASQA's annual declaration process; in March 2026, for example, ASQA emailed RTO CEOs a unique link to complete an online declaration. Keeping registration details and key-people information current is part of the obligation.

Due Diligence and Monitoring

Because this is a positive obligation, you need evidence that you actively check and monitor your people. Reasonable due diligence includes referee checks and police checks, built into recruitment and performance management. Where you use third parties to deliver training on your behalf, you are expected to apply the same scrutiny to their staff — "person" under the Standards includes both individuals and organisations.

Education and Escalation

You should be able to demonstrate how you educate governing persons about their legal duty to declare changes in circumstance, and how staff are supported to raise concerns about a colleague's fitness or propriety. A clear escalation process — including how and when you would report to ASQA if a governing person may no longer meet the FPPRs — is essential.

Why the Fit and Proper Person Requirements Matter for RTO Owners

Providers that fail to comply with the Fit and Proper Person Requirements and the obligation to notify ASQA of material changes will be found non-compliant with the 2025 Standards. For owners and managers, that is a direct threat to registration — and to the reputation, learner outcomes and long-term viability that depend on it.

Treating the FPPRs as a living governance system, rather than a form, is what separates RTOs that pass performance assessments confidently from those caught off guard.

How Bluedge Helps You Meet the Fit and Proper Person Requirements

At Bluedge RTO Consulting, we help RTO owners and managers turn the Fit and Proper Person Requirements into a practical, defensible governance system. That includes identifying every governing person, building due-diligence and monitoring processes, preparing declarations and evidence, and creating clear escalation and reporting pathways that stand up to an ASQA performance assessment.

If you are unsure whether your RTO's governance would satisfy the current requirements, a structured review is the fastest way to find out before ASQA does.

Book a short call today!