The 2023 NDIS Review: What It Found
In October 2023, Professor Bruce Bonyhady AO and Lisa Paul AO delivered the final report of the independent NDIS Review to the Australian Government. The review — the most comprehensive examination of the NDIS since its creation — found that while the scheme had transformed the lives of many Australians with disability, it also faced serious challenges:
- Unsustainable cost growth — scheme costs were growing at approximately 14% annually, far exceeding the 8% growth rate needed for long-term sustainability
- Quality and safety gaps — the current registration framework left a significant proportion of providers (particularly those serving self-managed participants) outside regulatory oversight
- Market failures — thin markets in regional and remote areas meant some participants could not access supports, while metropolitan areas had oversupply of some support types
- Complexity and bureaucracy — the system was too complex for participants and providers to navigate, with inconsistent planning decisions and excessive paperwork
- Workforce challenges — the disability workforce was under-trained, under-paid, and experiencing high turnover
- Fraud and non-compliance — the absence of universal provider registration created vulnerabilities to fraud and poor-quality service delivery
The review made 26 recommendations across five reform areas. The Australian Government accepted most recommendations "in principle" and has been progressively implementing them through legislative amendments and regulatory changes.
Legislative Changes
The NDIS reforms are being enacted through amendments to the NDIS Act 2013 and associated Rules. Key legislative changes include:
NDIS Amendment (Getting the NDIS Back on Track No. 1) Act 2024
This Act (passed in 2024) introduced several foundational changes:
- New "NDIS supports" definition — replacing the broad "reasonable and necessary" test with clearer criteria for what the NDIS will and will not fund
- Framework for needs assessments — moving from planner-based assessments to more independent, consistent assessment processes
- Provider registration amendments — enabling the new tiered registration framework through changes to the registration provisions of the Act
- Enhanced enforcement powers — giving the NDIS Commission stronger powers to take action against non-compliant providers
- Co-design requirements — embedding participant co-design in the development of NDIS policies and processes
Subsequent NDIS Rules amendments
The operational details of the reforms are being implemented through amendments to various NDIS Rules, including the Provider Registration and Practice Standards Rules, the Incident Management Rules, and the Worker Screening Rules. These amendments are being rolled out progressively through 2025 and 2026.
The New Registration Framework
The most significant structural change for providers is the new risk-proportionate registration framework. This replaces the current binary model (registered or unregistered) with a tiered system.
The three proposed tiers
| Tier | Who It's For | Requirements |
|---|---|---|
| Enrolled | Lower-risk supports (e.g., community participation, transport, household tasks) | Basic registration with declaration of compliance. No audit required. Subject to Code of Conduct and complaints jurisdiction. Worker screening requirements apply. |
| Registered | Medium-risk supports (e.g., personal care, support coordination, therapeutic supports) | Current registration level with verification or certification audit against Practice Standards. Full compliance obligations. |
| Advanced registered | Highest-risk supports (SIL, SDA, behaviour support, restrictive practices) | Enhanced registration with additional requirements — more frequent audits, enhanced governance requirements, stricter worker qualification standards. |
What this means for currently unregistered providers
Under the new framework, all providers delivering NDIS supports will need to be at least enrolled. The era of operating as a completely unregistered provider is ending. However, enrolment is designed to be simpler and less costly than full registration — a declaration of compliance rather than an audit.
For more detail on the registration decision, see our guide on NDIS registered vs unregistered providers.
SIL Registration Mandate
The mandatory registration requirement for SIL providers is the most immediately impactful reform for providers in 2026.
What's changing
- From 1 July 2026, all providers delivering any form of Supported Independent Living (SIL) must be registered with the NDIS Commission
- This applies regardless of the participant's plan management type — even providers who previously delivered SIL to self-managed participants without registration must now register
- Registration for SIL requires a certification audit (the more comprehensive audit type)
- There are no transitional arrangements, no grandfathering, and no extensions
Why the mandate exists
SIL is classified as an inherently high-risk support because:
- Participants live in SIL arrangements 24 hours a day, 7 days a week
- SIL participants often have complex support needs and may be unable to self-advocate
- The power imbalance between providers and participants is particularly acute in a person's own home
- Historical incidents of abuse, neglect, and poor-quality care in residential disability settings
- The NDIS Commission found that a disproportionate number of complaints and reportable incidents originated from SIL settings
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Get the SIL Rescue KitPractice Standards Updates
The NDIS Practice Standards are being reviewed and updated as part of the reform program. While the core structure of the Practice Standards remains, several areas are being strengthened:
Areas of focus
- Governance and operational management — enhanced requirements for organisational governance, financial management, and key personnel suitability
- Incident management — strengthened requirements for incident prevention, not just incident response
- Worker qualifications and training — clearer minimum qualification requirements for certain support types, and enhanced training requirements across all support types
- Participant outcomes measurement — greater emphasis on demonstrating measurable outcomes for participants, not just delivering hours of support
- Cultural safety — enhanced requirements for culturally safe service delivery, particularly for Aboriginal and Torres Strait Islander participants
- Restrictive practices reduction — strengthened requirements for reducing and eliminating restrictive practices, with clearer reporting obligations
What providers should do
If you have existing policies and procedures mapped to the current Practice Standards, you will need to review and update them as the updated standards are published. Key areas to watch are governance documentation, incident management procedures, staff training plans, and outcome measurement frameworks.
Pricing Framework Changes
The NDIS pricing framework is also evolving. Key changes include:
- Annual Price Guide updates — the NDIS Pricing Arrangements and Price Limits continue to be updated annually, with adjustments reflecting cost-of-living increases, workforce award changes, and sector feedback
- Pricing reform for SIL — the NDIA has been reviewing the SIL pricing model, with potential changes to how SIL quotes are calculated and approved
- Temporary Transformation Payment (TTP) — the ongoing status of the TTP, which compensated providers for the costs of transitioning to the NDIS, is being reviewed
- Short-notice cancellations — the cancellation policy framework is being reviewed, with potential changes to the terms under which providers can charge for cancelled supports
For providers, the key action is to stay current with the annual Price Guide and ensure your service agreements and claiming practices reflect the latest pricing rules.
Worker Screening Updates
Worker screening requirements are being enhanced as part of the reform program:
- Broader application — the NDIS Worker Screening Check is being extended to cover more worker types and more provider categories, including potentially all enrolled providers
- Portability improvements — efforts to make NDIS Worker Screening Checks more portable across states and territories, reducing the need for workers who move between jurisdictions to obtain new clearances
- Real-time monitoring — development of systems to notify providers if a worker's screening clearance is revoked or suspended, rather than relying on periodic re-checks
- Integration with other checks — work toward integrating NDIS Worker Screening with other worker checks (Working with Children, National Police Checks) to reduce administrative burden
Foundational Supports
One of the major recommendations of the NDIS Review was the creation of foundational supports — a new category of lower-level disability supports available outside an individual NDIS plan. The concept recognises that many people with disability need some level of support but do not meet the threshold for an individualised NDIS plan.
What foundational supports include
- Information and navigational support — helping people with disability understand and access services and systems
- Peer support — connecting people with disability to peer networks and support groups
- Short-term skill building — time-limited programs to build independence and daily living skills
- Community connections — programs that facilitate social participation and community inclusion
How foundational supports affect providers
Foundational supports represent a potential new revenue stream for providers. They are intended to be co-funded by the Commonwealth and state/territory governments (unlike the NDIS, which is Commonwealth-funded). The delivery model, provider requirements, and pricing for foundational supports are still being developed through pilot programs.
What foundational supports are NOT
It is important to understand that foundational supports are not a replacement for individualised NDIS plans. They are designed to complement the NDIS by providing lower-level supports to a broader group of people with disability — including those who do not meet NDIS eligibility criteria. Participants who have an NDIS plan will continue to receive their individualised supports through the scheme. Foundational supports fill the gap for people who need some level of support but do not have a plan.
Provider readiness for foundational supports
If you are interested in delivering foundational supports, consider the following preparation steps:
- Monitor announcements from the Department of Social Services and your state/territory government about pilot programs and procurement opportunities
- Assess your capacity to deliver community-level, group-based supports (which may differ from your current individualised service model)
- Build relationships with your local community — foundational supports are expected to be locally delivered and community-embedded
- Document your experience in delivering lower-level supports, peer programs, or community engagement activities — this will be valuable when tendering for foundational support contracts
Reform Timeline
| Date | Reform | Impact Level |
|---|---|---|
| October 2023 | NDIS Review final report published (26 recommendations) | Strategic |
| 2024 | NDIS Amendment Act passed; legislative framework for reforms established | Legislative |
| 2025 | Progressive NDIS Rules amendments; new registration framework design finalised | Regulatory |
| 1 July 2026 | SIL registration mandate takes effect — all SIL providers must be registered | Critical |
| 2026-2027 | Progressive implementation of tiered registration framework | Operational |
| 2026-2027 | Updated Practice Standards progressively released | Compliance |
| 2026-2028 | Foundational supports pilots and rollout | Opportunity |
Impact on Small Providers
Small providers (1-50 staff) face particular challenges and opportunities from the reforms:
Challenges
- Registration costs — the SIL certification audit alone costs $5,000-$15,000+, a significant expense for a small organisation
- Compliance burden — updated Practice Standards may require policy rewrites, additional training, and new documentation systems
- Administrative capacity — small providers often have limited administrative staff to manage compliance requirements
- Cash flow — the cost of registration, audits, and compliance systems must be funded from existing revenue
Opportunities
- Market access — registration opens access to NDIA-managed participants (approximately 50% of the market)
- Competitive advantage — providers who register early can capture market share from those who delay or fail to register
- Credibility — registration signals quality and trust to participants, families, and support coordinators
- Foundational supports — new revenue opportunities as foundational support programs are rolled out
- Cost-effective compliance — pre-built policy document packs and digital tools can dramatically reduce the cost of compliance preparation
Your Action Plan
Here is a practical action plan for small providers navigating the 2026 reforms:
- If you deliver SIL: Begin your certification audit process immediately if not already registered. The audit takes 3-6 months, and the deadline is absolute.
- Review your policies: Audit your current policies and procedures against the NDIS Practice Standards. Identify gaps and update documentation.
- Worker screening: Ensure all workers in risk-assessed roles hold current NDIS Worker Screening Check clearances. Plan for expanded screening requirements.
- Stay informed: Subscribe to the NDIS Commission provider newsletter and monitor the NDIS Commission website for updates on Practice Standards changes and registration framework implementation.
- Budget for compliance: Set aside funds for audit fees, policy development, and staff training. Factor these costs into your business planning.
- Train your team: Ensure all staff understand the upcoming changes and their role in maintaining compliance. Focus on documentation quality, incident reporting, and participant rights.
- Consider your registration strategy: Determine which tier of the new registration framework your organisation will fall into and prepare accordingly.
- Explore foundational supports: Monitor announcements about foundational support programs and consider whether your organisation could deliver these services.
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Important: This article provides general guidance about NDIS reforms as of April 2026. Reform details are being finalised and may change. Always verify current requirements and timelines with the NDIS Quality and Safeguards Commission and the Department of Social Services before making compliance decisions.