This isn’t an area you fix in a panic before an audit, because by then the facts are the facts. It’s an area you keep current quietly, year-round, so that the question never becomes a problem.
Fit and Proper Person: The Check That Ignores Your Training Quality
Compliance Requirements
Fit and Proper Person: The Check That Ignores Your Training Quality
You can run a genuinely good RTO and still be in trouble here. The Fit and Proper Person Requirements operate independently of your training quality — which is exactly why they catch leaders off guard. This is a low-frequency, high-consequence exposure, and it deserves attention precisely because it’s easy to ignore.
Why this one is different
Most compliance findings give you a chance to rectify. Fit and Proper Person issues go to whether you should hold registration at all. It has nothing to do with how well you deliver training — it’s about the integrity and suitability of the people steering the organisation. That disconnect is what makes capable RTOs underestimate it.
From the audit table: the providers who get caught here are rarely the ones doing something obviously wrong. They’re the ones who checked fit-and-proper status once at registration and never again — or who never recognised that the person quietly making the big decisions was a governing person in everything but title.
Where RTOs get exposed
- Shadow directorship. Someone exercises real influence but isn’t recognised as a governing person. Your fit-and-proper assurance has a hole in it.
- Undisclosed interests. Governing persons who don’t properly disclose interests in other organisations create exactly the integrity gap the requirement is designed to surface.
- No ongoing monitoring. Governing persons must remain fit and proper. A one-time check at registration can’t evidence that.
- Ignored conduct. Failing to act on concerning behaviour by staff or governing persons is itself an integrity failure.
What to put in place
- Run declarations on a cycle. Collect fit-and-proper declarations from all governing persons and refresh them on a schedule, not just at registration.
- Maintain a register of interests. Make disclosure routine so conflicts surface early.
- Map real influence. Identify everyone who genuinely influences the RTO and bring them into the process.
- Build a response path. Have a documented way to act on concerning conduct — and use it.
The takeaway
Is your fit-and-proper status current?
The free checklist covers the Compliance Requirements, not just the Outcome Standards.
Frequently asked questions
Who do the Fit and Proper Person Requirements apply to?
The RTO as an organisation and its governing persons — which can include people who exercise genuine influence even if they aren’t formally listed as directors.
Can a fit-and-proper issue affect our registration?
Fit and proper status goes to whether an organisation and its people are suitable to hold registration. Unlike many findings that can be rectified, serious integrity issues here can have consequences for registration itself, independent of training quality.
How often should fit-and-proper status be reviewed?
Because governing persons must remain fit and proper, it should be monitored and refreshed on an ongoing basis rather than checked only at registration — a scheduled declaration cycle and a maintained register of interests are practical ways to do it.
Keep reading
Why your governance binder won’t save you in 2025
“Under direction”: the line RTOs cross without realising
Run the audit-readiness checklist
About the author
Ben Thakkar
15+ yrs experienceCompliance, Training & Business Specialist · VET Advisory Group
Ben Thakkar is a Compliance, Training, and Business specialist in the education industry. He has held senior management roles, including General Manager, with leading Registered Training Organisations (RTOs) and Universities. With over 15 years of experience, Ben brings extensive expertise across audits, funding contracts, VET Student Loans, CRICOS, and the Standards for RTOs 2025.
