Why every registered SIL provider needs a restrictive practices policy
Under the NDIS (Restrictive Practices and Behaviour Support) Rules 2018, any NDIS registered provider that implements a regulated restrictive practice must have a written policy governing its use. This requirement sits squarely inside the NDIS Practice Standards — specifically the Behaviour Support module — and is one of the first things an approved quality auditor will request during a certification or verification audit.
The strengthened Practice Standards framework, progressively taking effect from 2026, places even greater emphasis on person-centred, rights-based documentation. A generic policy lifted from a template without local context is unlikely to satisfy an auditor who is looking for evidence that your team understands and applies these requirements day to day.
Below is a realistic filled-in sample policy excerpt. It is structured around the sections auditors commonly check. Use it as a starting point, then adapt every field to your organisation's actual practices, staff, and participant cohort.
Sample filled-in restrictive practices policy
| Policy title | Restrictive Practices Policy and Procedure |
| Organisation | Sunrise Community Support Pty Ltd |
| Policy number | SCS-POL-012 |
| Version | 3.1 |
| Approved by | Chief Executive Officer |
| Review date | June 2027 (or earlier if legislation changes) |
| Related documents | Behaviour Support Plan template, Incident Management Policy, Consent Policy, Complaints Policy |
1. Purpose
Sunrise Community Support Pty Ltd is committed to providing supports that uphold the rights, dignity, and safety of every participant. This policy establishes how the organisation:
- identifies and categorises regulated restrictive practices;
- ensures that only authorised restrictive practices are implemented;
- requires a behaviour support plan (BSP) developed by a suitably qualified positive behaviour support (PBS) practitioner for any participant for whom a restrictive practice is proposed;
- monitors, reports, and works to reduce and eliminate restrictive practice use over time.
2. Scope
This policy applies to all employees, contractors, and volunteers involved in the delivery of Supported Independent Living (SIL) and Short Term Accommodation (STA) services. It extends to all settings in which Sunrise Community Support provides funded supports.
3. Definitions
Regulated restrictive practice means any of the five practices defined in the NDIS (Restrictive Practices and Behaviour Support) Rules 2018:
- Seclusion — involuntary confinement of a participant alone in a room or area from which they cannot freely exit.
- Chemical restraint — use of medication for the primary purpose of influencing a participant's behaviour, not for a diagnosed mental health condition.
- Mechanical restraint — use of a device to prevent, restrict, or subdue a participant's movement.
- Physical restraint — direct physical force to prevent, restrict, or subdue a participant's movement.
- Environmental restraint — restricting a participant's free access to all parts of their environment, objects, or activities.
4. Authorisation requirements
No regulated restrictive practice may be implemented by Sunrise Community Support staff unless all of the following conditions are met:
- A current, written behaviour support plan prepared by a PBS practitioner registered with the NDIS Commission is in place for the participant.
- The relevant state or territory authorisation body (as applicable to the participant's location) has approved the restrictive practice.
- The participant and/or their authorised representative has been consulted and, where possible, has provided informed consent.
- The Practice Leader — Behaviour Support has reviewed and signed off the implementation plan.
Emergency use of physical restraint may only occur where there is an immediate risk of harm to the participant or others, must be the least restrictive option available, and must be reported as a reportable incident to the NDIS Commission within the required timeframe.
5. Responsibilities
| Role | Responsibility |
|---|---|
| Chief Executive Officer | Policy approval; ensuring adequate resources for implementation |
| Practice Leader — Behaviour Support | Oversight of all BSPs; liaison with PBS practitioners; monitoring reduction data |
| SIL Team Leader | Day-to-day compliance; staff briefings; incident documentation |
| All Support Workers | Following approved BSPs only; recording every use; reporting incidents promptly |
| Registered PBS Practitioner (contracted) | Developing, reviewing, and updating behaviour support plans |
6. Mandatory reporting
Every use of a regulated restrictive practice must be recorded in the participant's file on the day of use, including the type of practice, duration, staff present, and the behaviour of concern that preceded it. The Practice Leader — Behaviour Support collates these records monthly to identify trends and progress toward reduction.
Where a restrictive practice use constitutes a reportable incident under the NDIS Commission Rules, the SIL Team Leader must notify the NDIS Commission through the myplace provider portal within the prescribed timeframe. Staff are trained on what constitutes a reportable incident during induction and in annual refresher training.
7. Reduction and elimination goal
Sunrise Community Support is committed to reducing and ultimately eliminating restrictive practices. The Practice Leader — Behaviour Support presents a quarterly report to the leadership team showing:
- the number and type of restrictive practice uses per participant;
- progress against each participant's individualised reduction plan;
- any barriers encountered and the steps taken to address them.
All BSPs must include an explicit goal and timeframe for reducing restrictive practice use, updated at each plan review.
8. Staff training
All staff who may implement a regulated restrictive practice must complete:
- NDIS Commission-recognised positive behaviour support training before commencing a role that involves a participant with a BSP;
- annual refresher training aligned to the PBS Capability Framework;
- organisation-specific scenario training conducted by the Practice Leader — Behaviour Support.
Training completion is recorded in the HR system and is reviewed as part of each staff member's annual performance discussion.
9. Policy review
This policy is reviewed annually, or sooner if:
- relevant legislation or NDIS Commission guidance changes;
- an audit finding or internal incident review identifies a gap;
- a participant's circumstances change materially.
Key elements auditors look for in this policy
When an approved quality auditor assesses your restrictive practices policy against the NDIS Practice Standards (Behaviour Support module), they typically confirm:
- the five regulated practices are correctly defined;
- authorisation requirements reference state/territory processes (not just internal approval);
- PBS practitioner involvement is mandatory, not optional;
- reporting obligations are explicit and timeframes are referenced;
- there is a genuine commitment to reduction, not just management;
- training requirements name a recognised framework (PBS Capability Framework).
A common non-conformance is a policy that lists the five practices but does not explain what staff must do before, during, and after each use. The filled-in sample above addresses all three phases.
Integrating this policy with your broader compliance documents
A restrictive practices policy does not stand alone. Auditors will trace references across your Incident Management Policy, Consent Policy, and individual behaviour support plans. Any inconsistency — for example, different reporting timeframes across documents — is flagged as a non-conformance.
If you are building or refreshing your SIL compliance suite ahead of the 2026 strengthened standards, ndiscompliant.com.au offers a 74-document audit-ready SIL compliance kit that includes this policy, all cross-referenced documents, and a pre-audit checklist aligned to current NDIS Commission requirements.
Regardless of which documents you use, always have your PBS practitioner and legal adviser review the final versions before your next audit cycle. Legislation can change, and your policy must reflect the version currently in force.
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.