Is a Restrictive Practice Reportable to the NDIS Commission?

The short answer: authorised versus unauthorised is everything

Under the NDIS (Restrictive Practices and Behaviour Support) Rules 2018, the NDIS Quality and Safeguards Commission regulates five types of regulated restrictive practices:

• Chemical restraint — medication used primarily to control a person's behaviour, not to treat a diagnosed condition
• Mechanical restraint — using a device to restrict a person's free movement (for example, lap belts used to restrict movement rather than for postural support)
• Physical restraint — using part of your body to restrict a person's movement
• Seclusion — restricting a person's freedom of movement by confining them to a space alone
• Environmental restraint — restricting a person's access to parts of their environment, such as locking a cupboard or room

Whether a regulated restrictive practice is authorised or unauthorised determines which reporting pathway applies — and getting this wrong is one of the most common enforcement findings the Commission records against SIL and community-care providers.

What makes a restrictive practice "authorised"?

A regulated restrictive practice is authorised when all three of the following conditions are met:

1. A registered NDIS behaviour support practitioner has developed a Behaviour Support Plan (BSP) for the participant that includes the practice.
2. The relevant state or territory body has authorised the use of that specific practice for that specific participant. Note: the NDIS Commission does not authorise restrictive practices — authorisation is a state and territory function.
3. Evidence of the authorisation has been uploaded to the NDIS Commission Portal by the implementing provider.

If any one of those three steps is missing, the practice is unauthorised — even if support workers believed they were acting in the participant's best interests, and even if a BSP exists but has not yet been formally authorised by the state or territory body.

Reportable incident obligations: the two-track system

The monthly reporting obligation applies to every regulated restrictive practice listed in a participant's BSP, regardless of whether it was actually used. Implementing providers access this through the Commission Portal using their PRODA account.

Why this matters for SIL providers heading into July 2026

From 1 July 2026, mandatory registration applies to all Supported Independent Living (SIL) providers. Providers who have not commenced a registration application by that date must stop delivering SIL. Providers who have not applied at all by 1 October 2026 must cease services.

The new SIL Practice Standards that accompany mandatory registration include specific obligations around restrictive practices: embedding positive behaviour support into daily routines, ensuring workers are trained and supervised to implement BSPs safely, and actively working to reduce the use of restrictive practices over time. During SIL audits, auditors will check for evidence across all of these areas.

If your organisation is currently unregistered and using any regulated restrictive practice, you are by definition using it without the full authorisation chain — and those incidents should have been reported as reportable incidents. Addressing this before you lodge a registration application is strongly advisable.

Worked example: what an auditor looks for

Consider this scenario: a SIL house uses a cupboard lock to prevent a participant from accessing kitchen knives unsupervised. The house manager considers this a safety measure, not a restriction.

Is it a regulated restrictive practice? Yes. Locking a cupboard to restrict access to part of the environment is environmental restraint — one of the five regulated types.

Is it authorised? That depends entirely on whether a BSP developed by a registered behaviour support practitioner includes this practice, and whether the relevant state or territory body has formally authorised it. Believing it is "just a safety measure" does not make it authorised.

What an auditor checks:

• Is the practice documented in a current, approved BSP?
• Is there evidence of state/territory authorisation uploaded in the Commission Portal?
• Have monthly reports been submitted on time for every month the participant was supported?
• Are incident reports filed for any period where the practice was used before authorisation was in place?
• Is there a documented reduction plan — evidence that the provider is actively working to eliminate or reduce the practice?
• Are support workers trained in the BSP and the specific conditions under which the practice may be used?

Quick-reference checklist for implementing providers

• Identify every regulated restrictive practice used across all participants in your service
• Confirm each has a current BSP authored by a registered behaviour support practitioner
• Confirm state/territory authorisation is current and uploaded to the Commission Portal
• Set a calendar reminder for monthly reporting (due within 5 business days of month-end)
• Review your incident register: any unauthorised use that was not reported should be addressed with your compliance lead
• Document worker training on each BSP and keep records available for audit
• Review your reduction plans and document progress

Get your SIL Readiness Pack

If you are preparing for SIL registration or your first audit under the new Practice Standards, our free SIL Readiness Pack sets out in plain English what the Commission expects from implementing providers — covering behaviour support documentation, restrictive practice authorisation, incident reporting, and worker training evidence. This is general information, not legal advice; for complex compliance questions, speak with a registered behaviour support practitioner or a compliance specialist.