Why SIL providers must have a written restrictive practices policy
A restrictive practices policy is not optional for registered NDIS providers who deliver Supported Independent Living or any supports where a regulated restrictive practice may be used. The NDIS Quality and Safeguards Commission requires registered providers to have documented systems that demonstrate compliance with the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 and the strengthened NDIS Practice Standards effective from 2026.
Without a compliant written policy, your organisation faces:
- Non-conformance findings during an NDIS quality audit
- Regulatory action from the NDIS Commission, including compliance notices or conditions on registration
- Inability to lawfully use or authorise any regulated restrictive practice
- Increased risk of harm to participants and workers
The policy is also the anchor document for your behaviour support procedures, staff training, incident reporting, and authorisation workflow. Getting it right from the beginning saves significant remediation work later.
What counts as a regulated restrictive practice
Before drafting your policy, ensure every relevant staff member understands the five categories of regulated restrictive practices defined in the Rules:
| Category | Brief description |
|---|---|
| Seclusion | Involuntary confinement of a person in a room or area they cannot freely leave |
| Chemical restraint | Use of medication to influence behaviour (not for a diagnosed medical condition) |
| Mechanical restraint | Use of a device to restrict movement (excluding therapeutic or medical use) |
| Physical restraint | Use of bodily force to restrict freedom of movement |
| Environmental restraint | Restricting access to space, objects, or activities |
Your policy must name each category and make clear that any use must be authorised through the proper state or territory mechanism and supported by a behaviour support plan developed by a registered Specialist Behaviour Support Provider.
Step-by-step: how to write the policy
Step 1 — State your organisation's commitment and purpose
Open the policy with an explicit commitment to the rights, dignity, and safety of participants. State that the organisation's goal is the reduction and elimination of regulated restrictive practices over time — this is a requirement of the Practice Standards, not merely aspirational language. Name the legislative instruments that govern the policy: the National Disability Insurance Scheme Act 2013, the NDIS Practice Standards, and the NDIS (Restrictive Practices and Behaviour Support) Rules 2018.
Step 2 — Define scope and who the policy applies to
Specify which services, registration groups, and staff roles this policy covers. For SIL providers, this will include support workers, team leaders, house supervisors, and behaviour support staff. Also clarify which participants may be affected — typically those with a behaviour support plan that authorises a regulated restrictive practice.
Step 3 — Define each regulated restrictive practice
Reproduce the five regulated categories in plain language. Add practical examples relevant to your service context (for example, what environmental restraint looks like in a shared living home). Staff must be able to recognise these practices in their daily work.
Step 4 — Describe the authorisation and approval process
This is the most critical operational section. Your policy must explain:
- That no regulated restrictive practice can be used without prior authorisation from the relevant state or territory body (for example, the Senior Practitioner in Victoria or Queensland)
- That a Specialist Behaviour Support Provider must develop or review the behaviour support plan before authorisation is sought
- The role of the NDIS Commission in receiving the behaviour support plan and reviewing usage data
- How authorisation renewals are tracked and who is responsible for initiating them
Step 5 — Set out reporting and record-keeping obligations
The NDIS Commission requires providers to report the use of regulated restrictive practices through the myNDIS provider portal within prescribed timeframes. Your policy must:
- Name the staff member responsible for portal reporting
- Specify the internal process for documenting each use — date, time, duration, type of practice, participant, and circumstances
- Link to your organisation's incident management procedure for any use that causes harm or distress
Step 6 — Outline staff training requirements
The strengthened Practice Standards place greater emphasis on evidence of competency, not just attendance at training. Your policy should specify the minimum training required before a worker may be present during a regulated restrictive practice (for example, an approved positive behaviour support training program), how often refresher training is required, and how records of completion are kept.
Step 7 — Establish reduction and elimination planning
Include a requirement that every participant subject to a regulated restrictive practice has an active plan for reducing reliance on that practice over time. This should link to the behaviour support plan review cycle and be reflected in progress notes and case conferences.
Step 8 — Set review and approval timelines for the policy itself
State how often the policy is reviewed (commonly every one to two years, or following a significant incident, regulatory change, or audit finding). Name the position responsible for approval — typically the CEO, Quality Manager, or Practice Lead. Document the version control process.
Template excerpt — policy commitment and scope section
Policy title: Regulated Restrictive Practices Policy
Version: 2.0 | Effective date: [Insert date] | Next review: [Insert date]
Approved by: Chief Executive Officer
1. Purpose
[Organisation name] is committed to upholding the rights, dignity, and safety of every participant we support. This policy sets out our obligations and procedures regarding the use of regulated restrictive practices as defined under the NDIS (Restrictive Practices and Behaviour Support) Rules 2018. Our primary goal is the reduction and elimination of all regulated restrictive practices through person-centred, evidence-based behaviour support.
2. Scope
This policy applies to all staff, contractors, and volunteers engaged in direct support under registration groups [insert relevant groups, e.g., 0115 – Daily Activities; 0106 – Supported Independent Living]. It applies in all service settings operated by [Organisation name], including shared living homes, day programs, and community access supports.
3. Legislative framework
This policy is developed in accordance with:
– National Disability Insurance Scheme Act 2013
– NDIS (Restrictive Practices and Behaviour Support) Rules 2018
– NDIS Practice Standards (including the strengthened standards effective 2026)
– Relevant state/territory legislation governing authorisation [insert jurisdiction-specific instrument]
Common gaps auditors look for
NDIS quality auditors consistently identify the following non-conformances in restrictive practices policies:
- Policy does not list all five regulated practice types, or uses informal language that obscures what is regulated
- No documented process for obtaining state or territory authorisation before use
- Reporting obligations to the Commission are vague or assign no responsible role
- Staff training requirements are generic — no link to approved positive behaviour support programs
- No reduction and elimination planning language — policy treats practices as permanent rather than transitional
- Policy has not been reviewed since the strengthened Practice Standards came into effect
Connecting the policy to your broader compliance framework
A restrictive practices policy does not stand alone. It must link to:
- Your Incident Management Policy and Procedure
- Your Behaviour Support Procedure (including how behaviour support plans are commissioned and reviewed)
- Your Complaints Management Policy
- Staff induction and training registers
- Participant rights documentation and consent processes
If you are preparing for mandatory registration or a re-registration audit under the strengthened 2026 framework, having these documents consistently cross-referenced and version-controlled is what separates a compliant suite from a collection of standalone documents.
For SIL and disability support providers who want to build this out quickly, ndiscompliant.com.au offers a 74-document audit-ready SIL compliance kit that includes a pre-written Regulated Restrictive Practices Policy aligned to the 2026 Practice Standards, along with all linked procedures, registers, and training records.
Key principles to embed throughout your policy
Regardless of how your policy is structured, the following principles must be evident throughout — these reflect what auditors and the Commission look for:
- Rights-based framing: every reference to restrictive practices must be grounded in participant rights and dignity
- Least restrictive alternative: the policy must require that less restrictive options are considered and documented before any regulated practice is used
- Supported decision-making: participants, their families, and nominees must be involved in behaviour support planning and authorisation decisions
- Transparency: participants must be told what practices are authorised for them and why
- Accountability: clear lines of responsibility must be named for authorisation, reporting, training, and review
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.