What Is a Behaviour of Concern Record Under the NDIS?
A behaviour of concern record is a contemporaneous written account that a support worker or supervisor completes each time a participant displays behaviour that causes harm, risk of harm, or significant disruption. Under the NDIS Practice Standards and the strengthened framework taking effect in 2026, registered SIL providers must maintain these records as part of their obligations around behaviour support, restrictive practice, and incident management.
The record serves three distinct regulatory purposes. First, it provides the raw data that a Behaviour Support Practitioner (BSP) needs to analyse patterns and update a participant's Behaviour Support Plan (BSP). Second, it forms the paper trail that demonstrates a provider is implementing approved strategies rather than resorting to unauthorised restrictive practices. Third, it feeds directly into the provider's incident reporting obligations to the NDIS Commission where threshold criteria are met.
What the NDIS Commission Expects in Every Record
The NDIS Practice Standards (Core Module: Support Provision Environment and the Behaviour Support module) do not prescribe a single mandatory form, but they do require that records are sufficient to demonstrate the provider's compliance with approved behaviour support plans. Quality auditors assess whether records capture enough information to:
- Identify the antecedent (what happened immediately before the behaviour)
- Describe the behaviour specifically and objectively, not in judgmental language
- Record the consequence or outcome of the behaviour
- Confirm which, if any, behaviour support strategies were applied
- Note whether any regulated restrictive practice was used and, if so, whether it was authorised
- Identify who was present and who completed the record
- Establish the time and duration so patterns can be tracked
Failing to capture any of these elements is among the most common non-conformances identified in NDIS audits, and it can trigger a reportable incident investigation if a restrictive practice was involved.
Realistic Filled-In Sample Record
The following is a realistic example of a completed behaviour of concern record. This is an illustrative template — adapt it to your organisation's approved behaviour support plans and any state or territory authorisation requirements.
| Field | Example Entry |
|---|---|
| Participant name | Jordan T. (use participant ID on shared systems) |
| NDIS number | 430XXXXXXX |
| Date and time of incident | 12 June 2026, 09:15 AEST |
| Location | Participant's bedroom, SIL house — 14 Example Street, Suburb, VIC |
| Staff member present | Maria S. (Support Worker, Staff ID: SW-0042) |
| Antecedent (what happened immediately before) | Jordan was asked to get dressed for a scheduled community access activity at 09:00. Jordan had not slept well and had refused breakfast. After the second prompt at 09:10, Jordan became visibly distressed. |
| Behaviour description (objective, specific) | Jordan threw a ceramic mug against the bedroom wall, breaking it. Jordan then stood in the doorway shouting "leave me alone" for approximately four minutes. Jordan did not strike staff or other participants. |
| Duration | Approximately 6 minutes from first outburst to return to baseline calm. |
| Intensity (scale per BSP) | 3 out of 5 (BSP scale) — verbal aggression and property damage, no physical aggression toward persons. |
| Strategies applied (from approved BSP) | Staff used low-arousal approach as documented in section 4.2 of Jordan's BSP: reduced verbal interaction, maintained safe distance of approximately 2 metres, offered a comfort item (fidget tool from beside table). |
| Regulated restrictive practice used? | No. No physical, mechanical, chemical, environmental or seclusion-based restrictive practice was applied. |
| Outcome / consequence | Jordan self-regulated after approximately 6 minutes. Jordan apologised and agreed to delay community access by one hour. No injuries sustained by Jordan or staff. Broken mug secured and disposed of safely. |
| Was anyone injured? | No |
| Immediate actions taken | Scene made safe (broken ceramic removed). Supervisor notified by phone at 09:25. Entry made in house communication book. |
| Does this meet reportable incident threshold? | No — no injury, no unauthorised restrictive practice, no serious risk event as defined by the NDIS Commission. |
| BSP review required? | Yes — this is Jordan's third episode this fortnight involving a refusal trigger in the morning routine. Flag for BSP practitioner review at next scheduled check-in (19 June 2026). |
| Record completed by | Maria S. — Support Worker |
| Date/time completed | 12 June 2026, 09:45 AEST (within 30 minutes of incident) |
| Supervisor signature / review | Chris R. — House Coordinator — reviewed 12 June 2026, 10:30 AEST |
Key Principles Behind This Example
Objective language is mandatory
Auditors and behaviour support practitioners flag records that use interpretive or derogatory language — for example, "Jordan was being difficult" tells reviewers nothing useful and may indicate a culture problem. Every behaviour description should answer: what did the person do, with what, toward whom, for how long?
Linking to the approved Behaviour Support Plan
The record above references specific sections of Jordan's BSP. This is deliberate. Under the NDIS Practice Standards, providers must implement behaviour support plans developed or overseen by a qualified Behaviour Support Practitioner. Records that cannot show which BSP strategies were followed raise an immediate question for auditors: was the provider acting in compliance with the approved plan, or making it up on the spot?
Restrictive practice documentation is non-negotiable
The NDIS (Restrictive Practices and Behaviour Support) Rules 2018 require that any use of a regulated restrictive practice be authorised, documented, and reported. If your record shows a restrictive practice was used, you must also have the relevant state or territory authorisation on file. If the answer is "no restrictive practice was used," that must still be stated explicitly — silence on this field is treated as a documentation failure.
Timeliness matters
Records completed hours or days after an incident are unreliable and signal a documentation culture problem. Best practice — reinforced in NDIS audits — is to complete the record as soon as the participant is settled and the environment is safe, generally within 30 to 60 minutes of the behaviour occurring.
Threshold assessment for reportable incidents
After completing a behaviour of concern record, the supervisor must determine whether the incident meets the NDIS Commission's reportable incident threshold. Incidents involving injury, unauthorised restrictive practices, abuse, neglect, or unexplained absence must be reported via the NDIS Commission portal within the required timeframes. Not all behaviours of concern reach this threshold, but the assessment must be documented.
How to Build a Compliant System Around This Record
- Standardise your template — use the same fields across all participants and all houses. Inconsistency is the most common audit gap.
- Train staff to write objectively — run a short in-service showing the difference between interpretive and factual language.
- Integrate with your incident management system — every behaviour of concern record should automatically prompt a threshold check, so no reportable incident slips through.
- Connect records to BSP review cycles — define a frequency trigger (e.g., three incidents of the same type within a fortnight) that automatically flags the BSP for practitioner review.
- Store securely and accessibly — records must be retrievable by your BSP, your quality auditor, and, where appropriate, the participant and their nominee. Apply your privacy obligations under the Privacy Act 1988.
- Conduct regular internal audits — sample completed records monthly to check for missing fields, vague language, and incomplete threshold assessments before an external auditor does.
Preparing for the 2026 Strengthened Practice Standards
The NDIS Commission's strengthened Practice Standards place heightened emphasis on evidence of good outcomes for participants, not just process compliance. Behaviour of concern records are increasingly scrutinised not only for completeness but for what they reveal about whether the provider's culture is genuinely person-centred. Auditors will look at a sample of records together to identify patterns: are strategies being followed consistently, are restrictive practices declining over time, and is the BSP being updated when patterns change?
Providers preparing for registration renewal or initial registration under the 2026 framework should treat their behaviour support documentation system as a strategic asset, not a paperwork obligation. If your current records are incomplete or inconsistent, remediation before audit is far less costly than a non-conformance finding.
For SIL providers who want a ready-made system, the ndiscompliant.com.au 74-document audit-ready SIL compliance kit includes behaviour of concern record templates, BSP linking registers, restrictive practice authorisation checklists, and the internal audit sampling tools that make pre-audit remediation systematic.
Important: This article provides general guidance about NDIS compliance requirements. It is not legal or professional advice. Requirements may change as the NDIS Commission updates its policies and Practice Standards. Always verify current requirements with the NDIS Quality and Safeguards Commission or a registered NDIS consultant before making compliance decisions.