Why SIL providers need a complaints register in 2026

Under the NDIS (Complaints Management and Resolution) Rules 2018 and the NDIS Practice Standards, every registered NDIS provider — including all Supported Independent Living (SIL) providers — must have a documented system for receiving, acknowledging, managing, and resolving complaints and feedback. The strengthened framework being progressively implemented through 2025–2026 places even greater emphasis on participant voice, transparent records, and demonstrable learning from complaints.

An approved quality auditor assessing your organisation against the Core Module (specifically the Feedback and Complaints Management quality indicator) will look for a live, up-to-date register as primary evidence. Absence of a register — or a register with incomplete entries — is one of the most common non-conformances raised against SIL providers at audit.

Beyond audit obligations, a well-maintained register is a governance tool. It allows leaders to spot patterns, respond quickly when a participant's safety or rights are at risk, and demonstrate to the NDIS Commission that the organisation takes quality improvement seriously.

What the NDIS Practice Standards require

The Core Module of the NDIS Practice Standards sets out that providers must:

The NDIS Commission can also receive complaints directly and may require your register as part of a compliance investigation. Providers who cannot produce a register risk compliance notices, conditions on registration, or in serious cases, suspension.

Step-by-step: how to build your complaints register

  1. Choose your format. A register can be a spreadsheet, a database field in your care management software, or a dedicated paper log. Whatever the format, it must be securely stored, backed up, and accessible only to authorised staff. Digital is strongly preferred for SIL because multiple support workers and managers may need to update or view entries.
  2. Define your mandatory fields. Every entry must capture the information listed in the next section below. Build these as column headers or form fields before your first entry so nothing is missed retrospectively.
  3. Create an intake procedure. Staff need a clear, single-page protocol for what to do the moment they receive a complaint or piece of feedback — in person, by phone, in writing, or via a third party. The protocol should specify who records the entry, within what timeframe (many providers set a same-business-day rule), and who must be notified (e.g., the house supervisor, operations manager, or safeguarding lead depending on severity).
  4. Assign a unique reference number. A simple format such as CPL-2026-001 (CPL = complaint, year, sequential number) allows you to track correspondence, link documents, and reference cases in meeting minutes without identifying participants in non-secure settings.
  5. Record initial acknowledgement. Log the date and method by which you acknowledged the complaint to the complainant. Under the Practice Standards, acknowledgement should occur promptly — most providers commit to one to two business days in their complaints policy.
  6. Document the investigation. Record who investigated the matter, what steps were taken (interviews, file reviews, observation), any interim protective actions (e.g., rostering changes), and findings. This does not need to be a lengthy narrative in the register itself — a brief summary with a reference to the investigation report is sufficient.
  7. Record the outcome and any improvement actions. Note how the complaint was resolved, whether the complainant was satisfied, and what systemic changes (if any) resulted. Link to the relevant quality improvement log or continuous improvement plan.
  8. Close and sign off. Record the closure date and the name/role of the person who authorised closure. Complaints that cannot be fully resolved internally must be referred to the NDIS Commission — note this in the register.
  9. Review the register regularly. Schedule a monthly or quarterly management review to identify trends: recurring themes, specific support workers, particular times of day, or certain participant cohorts. Document this review so auditors can see complaints are informing continuous improvement.

Mandatory fields: what every entry must include

Field Notes
Unique reference numbere.g., CPL-2026-007
Date receivedDate complaint or feedback was first received
Received by (staff name/role)Who took the initial record
Complainant typeParticipant, family/carer, support worker, third party, anonymous
Method receivedIn person, phone, email, written, online form
Summary of complaint/feedbackFactual description — avoid opinions or judgements
Participant involved (de-identified where needed)Use participant ID if the register is not fully secured
Categorye.g., support delivery, behaviour support, communication, accommodation, staff conduct
Severity/risk ratingLow / Medium / High — escalate High-risk immediately
Date acknowledged to complainantMust occur promptly per your complaints policy
Investigator assignedName and role
Investigation summaryBrief notes or reference to full investigation report
Outcome / resolutionSubstantiated / not substantiated / partially substantiated / referred
Improvement actions takenLink to continuous improvement plan or corrective action
Referred to NDIS Commission?Yes / No — if yes, record Commission reference number
Date closedDate resolution communicated and file closed
Authorised byManager name and role

Example register entry

The following is a realistic, illustrative example of a completed register entry. All names are fictitious.

ReferenceCPL-2026-014
Date received3 June 2026
Received byJ. Nguyen, House Supervisor
Complainant typeFamily member (mother of participant)
MethodPhone call
SummaryComplainant stated that her son (Participant ID: SIL-042) was not assisted with his evening meal on two occasions (28 and 30 May 2026) and that staff did not call her as agreed in the support plan when he refused meals.
CategorySupport delivery / communication
SeverityMedium
Date acknowledged3 June 2026 (same day, phone callback)
InvestigatorM. Okafor, Operations Manager
Investigation summaryReviewed daily progress notes for 28 and 30 May. Notes confirm meal prompting was attempted but no call to family was made. Two staff members interviewed — neither was aware of the communication protocol in the support plan. Full investigation report: INV-2026-014.
OutcomeSubstantiated — support plan communication protocol not followed.
Improvement actionsAll SIL-042 house staff briefed on support plan (4 June 2026). Support plan communication section highlighted in handover folder. Added as agenda item to next staff meeting. Linked to CI-2026-031.
Referred to CommissionNo
Date closed10 June 2026
Authorised byM. Okafor, Operations Manager

Common audit failures and how to avoid them

Connecting complaints to continuous improvement

A register that ends at "closed" misses half its value. At each management review, analyse your complaints data to answer: Are there repeat themes? Are certain support workers named repeatedly? Is there a specific house or time of day with elevated complaints? Use this analysis to update policies, amend training calendars, or revise support plans.

Document your analysis in a continuous improvement log — this is a separate but linked record that auditors expect to see alongside the complaints register. Together, the two documents show that your organisation does not just manage individual complaints but learns from them systematically.

If you are building your SIL compliance documentation from scratch or preparing for a verification or certification audit, the 74-document audit-ready SIL compliance kit available at ndiscompliant.com.au includes a pre-formatted complaints and feedback register, a complaints policy and procedure, an investigation report template, and a continuous improvement log — aligned to the 2026 Practice Standards.

Quick-reference checklist

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.