Why SIL providers need a compliant HR policy in 2026
The NDIS Quality and Safeguards Commission requires all registered NDIS providers to maintain documented human resources (HR) policies and procedures as part of the NDIS Practice Standards. For Supported Independent Living (SIL) providers, this requirement sits under the Support Provision Environment and Human Resources core modules of the Practice Standards. The strengthened framework rolling out through 2026 places even greater weight on demonstrating that your workforce is safe, supervised, and continuously developed.
Failing to produce an HR policy at audit — or producing one that does not reflect actual practice — is one of the most common reasons providers receive non-conformances. A robust policy protects participants, protects your workers, and protects your registration.
What must an NDIS HR policy cover?
The NDIS Practice Standards (Human Resources) specify that registered providers must demonstrate evidence of systems and processes in the following areas:
- Recruitment and selection — processes for attracting and selecting workers who are safe and suitably qualified
- NDIS Worker Screening — mandatory screening checks for all workers in risk-assessed roles, and a process for managing cleared and excluded workers
- Induction — orientation to the role, the organisation, and participant support needs before unsupervised work commences
- Training and professional development — ongoing learning including the NDIS Code of Conduct, mandatory reporter obligations, and disability-specific competencies
- Supervision and performance management — regular, documented supervision; a process for managing underperformance and conduct concerns
- Code of Conduct obligations — how workers are made aware of, and held accountable to, the NDIS Code of Conduct
- Incident and complaint response — worker responsibilities when incidents occur, including mandatory reportable incident obligations
- Workforce records — what records are kept, how long they are retained, and how they are secured
Step-by-step: how to write your NDIS HR policy
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Define scope and ownership
State which workers the policy applies to (employees, contractors, volunteers, students on placement). Name the role responsible for maintaining and reviewing the policy — typically the Registered Manager or People and Culture lead. Include the review cycle; annually is a minimum, with triggered reviews when legislation or Practice Standards change.
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Map the policy to the Practice Standards
At the top of the document, list the relevant Practice Standards indicators the policy addresses. This makes it immediately usable during a quality audit and signals to the auditor that your policy is intentional, not generic. For SIL providers, the core reference is the NDIS Practice Standards — Core Module, Human Resources indicators.
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Write your recruitment and screening section
Describe how you advertise roles, assess candidates, conduct reference checks, and verify qualifications. Critically, detail your NDIS Worker Screening process: which roles are risk-assessed roles, how clearances are verified before commencement, how you record and monitor clearance status, and what happens if a worker receives an exclusion or interim bar. Under the strengthened framework, providers must not allow a worker with an exclusion to provide NDIS supports.
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Document your induction process
Set out what every new worker receives before commencing unsupported work: orientation to the organisation's values and policies, introduction to the NDIS Code of Conduct, participant-specific support needs briefing, and mandatory training (first aid, manual handling, restrictive practice awareness if applicable). Note the timeframe — most providers require core induction to be completed within the first week and documented.
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Describe training and competency requirements
List mandatory training topics and their renewal intervals. Common inclusions for SIL providers are: NDIS Code of Conduct, manual handling, medication administration (where applicable), positive behaviour support and restrictive practice awareness, infection control, emergency procedures, and disability-specific supports. Link each training requirement to evidence of completion and how records are stored.
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Set out supervision and performance management
Specify the minimum frequency of individual supervision (many providers use at least monthly for frontline SIL workers), how supervision is recorded, and what topics must be covered. Include your process for informal and formal performance management, the steps between informal feedback and formal disciplinary action, and how outcomes are documented. Under the Code of Conduct, providers must take reasonable steps to prevent workers from breaching the Code — documented supervision is one of the clearest ways to demonstrate this.
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Address Code of Conduct and misconduct
Explain how all workers are made aware of the NDIS Code of Conduct (typically via induction and annual acknowledgement). Describe your process for investigating alleged breaches, what constitutes reportable conduct, and how you meet the Commission's requirement to notify the NDIS Commission of certain worker misconduct matters. Reference your separate Complaints and Incident Management policies here rather than duplicating them.
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State records management obligations
Specify what HR records are retained (employment contracts, screening clearances, training records, supervision notes, performance management records), the retention period, storage location, access controls, and disposal process. Australian privacy law and the NDIS Commission's record-keeping requirements both apply.
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Review, approve, and communicate
Have the policy reviewed by a senior leader and, where appropriate, legal or HR advisory input. Obtain formal sign-off. Communicate it to all workers — obtain a signed acknowledgement that it has been read. Keep the signed acknowledgements on file as audit evidence.
Example: HR policy excerpt (template block)
| Section | Example policy statement |
|---|---|
| NDIS Worker Screening | All workers in risk-assessed roles must hold a current NDIS Worker Screening Clearance before commencing unsupported work with NDIS participants. The People and Culture team verifies clearance status via the Worker Screening Database prior to commencement and at each annual review. A worker who receives an exclusion or interim bar must not provide NDIS supports and will be immediately stood down from participant-facing duties pending further review. |
| Induction | All new workers complete a structured induction within five (5) business days of commencement. Induction covers: the NDIS Code of Conduct; the organisation's values, policies and procedures; participant rights and the concept of supported decision-making; mandatory reporting obligations; and emergency and incident response procedures. Induction completion is documented on the worker's personnel file. |
| Supervision frequency | Frontline support workers receive formal documented supervision at least once per month during the probationary period and at least once every six (6) weeks thereafter. Supervision records are retained on the worker's personnel file for a minimum of seven (7) years. |
| Code of Conduct acknowledgement | All workers sign a Code of Conduct Acknowledgement Form at induction and at each annual performance review. Completed forms are retained on the worker's personnel file. |
Common audit non-conformances to avoid
- Generic HR policy not tailored to NDIS — a standard business HR policy that does not reference worker screening, the Code of Conduct, or Practice Standards will not satisfy the audit.
- Policy exists but is not practised — auditors look for evidence (supervision records, training logs, signed acknowledgements). If the file is empty, the policy is irrelevant.
- Screening records not maintained — clearance numbers and expiry dates must be on file. A worker who began with a clearance but whose clearance has since lapsed is a critical non-conformance.
- No process for excluded workers — the policy must state what happens if a worker receives an exclusion, not just how clearances are obtained.
- Training records not retained — certificates and completion records must be stored and retrievable. Verbal training with no documentation does not satisfy the standard.
Pulling it all together for 2026
The NDIS Practice Standards audit against evidence, not intention. Your HR policy is the foundation document that demonstrates your organisation takes workforce safety and competency seriously. Pair it with a training register, supervision log template, screening register, and Code of Conduct acknowledgement form to give your auditor a complete evidence package.
If you are preparing your full SIL compliance documentation suite, the 74-document audit-ready SIL compliance kit at ndiscompliant.com.au includes a completed HR policy template, all supporting registers, and the other core Practice Standards documents in one package — designed specifically for the 2026 strengthened framework.
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.