Key Takeaways
- In December 2025, Minister McAllister confirmed that mandatory registration for SIL providers and platform providers would proceed from 1 July 2026. Standard support coordinators (group 0106) were explicitly excluded, with mandatory registration for that group paused while the government considers broader reform.
- The pause reflects a change in reform design, not reduced oversight intent. The government is replacing the open-market model for support coordination with a commissioned model from 1 July 2028, and mandatory registration requirements will be aligned with that new structure.
- Specialist Support Coordinators (group 0132) were already required to hold registration and are not affected by the pause. They must continue to hold registration, complete certification audits against the Core Module and Specialist Module 4, and complete mid-term audits at approximately 18 months into each three-year cycle.
- The NDIS Code of Conduct applies to every support coordinator, registered or not. Breaches carry civil penalties up to $82,500 per incident for individuals, and up to $3.3 million for serious contraventions under the NDIS Amendment (Integrity and Safeguarding) Act 2025.
- Unregistered standard support coordinators have no mandatory incident reporting obligation, but participants can still complain to the Commission about unregistered providers and the Commission will investigate and act on those complaints.
- NDIS Worker Screening is not legally mandated for most unregistered support coordinators, but sole traders delivering supports directly must hold a clearance for themselves, and participants may require it as a condition of engagement.
- The commissioned model launching in July 2028 will use a curated panel of approved providers. Providers who build compliance foundations now will be better positioned for panel inclusion than those who wait until the criteria are confirmed.
In December 2025, the government drew a clear line. SIL providers and platform providers face mandatory registration from 1 July 2026. Standard support coordinators do not, at least not yet. Mandatory registration for group 0106 is paused while the government finalises a deeper structural change: replacing the open-market model with a commissioned support coordination function, due to begin from 1 July 2028, involving a curated panel of approved providers meeting defined quality and integrity standards.
The pause is not a reprieve. It is a decision to redesign the oversight mechanism before requiring compliance with it. The compliance obligations that already apply to all support coordinators remain in full force.
This guide explains the difference between standard and specialist support coordination for registration purposes, what unregistered support coordinators must still do right now, and what providers should be building while they wait for the commissioned model details.
What Was Announced and What Changed
Standard Support Coordination (Group 0106): Mandatory Registration Paused
Standard support coordinators help NDIS participants understand their plans, connect with services, and build capacity to manage their plan over time. Group 0106 sits on the verification pathway, so providers who are registered face a document-based audit covering qualifications, insurance, and operational policies, with no site visit.
In September 2024, the then-Minister announced mandatory registration for SIL providers, platform providers, and support coordinators. By December 2025, the government had changed course. Support coordinators were removed from the first wave.
The reason is structural. The government is not simply mandating registration under the current framework. It is redesigning how support coordination operates. From 1 July 2028, coordination will move to a commissioned model: an approved panel of providers meeting defined quality and integrity standards. Aligning mandatory registration with that structure makes more sense than requiring compliance with a framework that is about to change significantly.
Until the commissioned model launches and its requirements are confirmed, standard support coordinators remain in the same regulatory position they were in before the September 2024 announcement. Unregistered providers can deliver coordination for self-managed and plan-managed participants, but all the obligations below still apply.
Specialist Support Coordination (Group 0132): Already Mandatory, Nothing Changed
Specialist support coordinators support participants with complex and high-risk needs that standard coordination cannot address. Group 0132 sits on the certification pathway. Registration requires a two-stage audit against the Core Module of the NDIS Practice Standards plus Specialist Module 4, which covers practitioner competency, detailed activity documentation, and conflict of interest management.
Group 0132 registration was mandatory before the September 2024 reforms were announced. The pause on mandatory registration for standard support coordinators does not affect specialist support coordinators. Their obligations are unchanged:
- Hold current NDIS registration and maintain compliance with all Core Module sections
- Meet Specialist Module 4 requirements: documented practitioner expertise, detailed records of contacts and actions for each participant, and a conflict of interest policy applied in practice
- Complete mid-term audits at approximately 18 months into each three-year registration cycle
- Notify the Commission of changes to key personnel or organisational structure
For the full breakdown of what Specialist Module 4 requires at audit, the NDIS Practice Standards modules guide covers what auditors assess under each criterion. For the certification audit timeline and non-conformity process, the NDIS audit pathways guide covers the full lifecycle.
A standard support coordinator who begins delivering specialist support coordination without adding group 0132 and completing a certification audit is providing supports without the required registration, which is a criminal offence under the NDIS Act.
What Unregistered Standard Support Coordinators Must Still Do
The pause on mandatory registration does not remove the compliance obligations that apply to all support coordinators, registered or not.
The NDIS Code of Conduct
The Code of Conduct, established under the National Disability Insurance Scheme (Code of Conduct) Rules 2018, applies to every NDIS provider and every NDIS worker regardless of registration status. All seven obligations apply to unregistered standard support coordinators:
- Act with respect for individual rights to freedom of expression, self-determination, and decision-making.
- Respect the privacy of people with disability.
- Provide supports and services in a safe and competent manner with care and skill.
- Act with integrity, honesty, and transparency.
- Promptly raise and act on concerns about matters that might put the safety and wellbeing of a person with disability at risk.
- Take all reasonable steps to prevent and respond to all forms of violence, exploitation, neglect, and abuse.
- Take all reasonable steps to prevent and respond to sexual misconduct.
Breaching any of these carries a civil penalty of 250 penalty units per incident. At the current federal penalty unit value of $330, that is $82,500 for an individual and $412,500 for a body corporate. For serious contraventions, the NDIS Amendment (Integrity and Safeguarding) Act 2025 raised the maximum to 10,000 penalty units: $3.3 million for an individual and $16.5 million for a corporation. A contravention is treated as serious where the provider knew their conduct was a breach, or was reckless as to whether it was. These penalties apply to unregistered providers exactly as they apply to registered ones. The broader enforcement powers introduced by the 2025 amendments are covered in our guide to the NDIS Amendment Bill 2025.
Complaints Management
Participants supported by unregistered standard support coordinators retain the right to complain to the NDIS Commission. The Commission will investigate, issue compliance notices, pursue civil penalties, and issue banning orders where a breach is established. Registration status does not limit the Commission's enforcement powers.
The 2025 amendments also gave the Commission expanded information-gathering powers: it can now issue formal notices requiring unregistered providers to produce documents and information, and refusing to comply is itself a civil penalty offence.
Unregistered providers must maintain a functioning complaints process that participants can actually use, and document how complaints are received, assessed, and resolved.
Worker Screening and Incident Reporting
Unregistered standard support coordinators are not subject to the "no card, no start" worker screening rule that applies under the Practice Standards framework to registered providers. They also have no mandatory incident reporting obligation to the Commission under the NDIS (Incident Management and Reportable Incidents) Rules 2018.
Both of these exclusions have practical limits. Sole traders who are personally delivering supports must hold an NDIS Worker Screening Check for themselves. Participants can require workers to hold clearances as a condition of engagement, and many do. Where a complaint involves harm by a worker, the Commission may consider whether the provider took reasonable steps to vet that worker before engagement.
For incident reporting, the Commission relies on participant and family complaints rather than proactive disclosure from unregistered providers. That gap does not reduce Code of Conduct exposure when harm occurs. The NDIS worker screening guide covers clearance mechanics and renewal timelines.
What to Do Now While Waiting for Reform Guidance
The commissioned model launches in July 2028. The government has not yet published the specific quality and integrity standards providers will need to meet for panel inclusion. Providers who wait until those criteria are confirmed before building their compliance foundations will not have enough time to demonstrate them.
Three actions address the most significant current risks.
Document your Code of Conduct compliance framework. A written record of how each of the seven obligations is met in practice, covering privacy, participant safety escalation, conflict of interest management, and responses to suspected abuse, is the minimum credible evidence of genuine compliance.
Build documentation to at least verification-level standard. Qualifications on file for each worker, insurance certificates current, written incident and complaints policies in place, and worker screening records. This is the baseline that the commissioned model will almost certainly require. Building it now costs less than building it under time pressure in 2027.
Track the Commission's reform communications. Further guidance on commissioned model criteria is expected well before July 2028. Providers who monitor those updates will have more lead time to respond than those who hear about them secondhand. The NDIS compliance quiz gives a structured assessment of where your practice sits right now.
How ClinicComply Helps
Unregistered standard support coordinators have fewer formal obligations than registered providers, but those obligations carry real enforcement consequences and will expand when the commissioned model launches. ClinicComply provides a structured way to document and track them now.
The policy library stores your Code of Conduct compliance framework, complaints management procedure, and conflict of interest policy against the specific obligations they address. For specialist support coordinators already registered, the platform maps Core Module and Specialist Module 4 criteria to a live evidence checklist and tracks corrective actions between audits. Automated reminders flag mid-term audit due dates, policy review milestones, and worker screening renewal deadlines before they fall overdue.
The NDIS policy templates library covers documentation frameworks for both standard and specialist support coordination providers. Explore the full feature set at cliniccomply.com.au/features, or start a free 30-day trial at cliniccomply.com.au/signup.
Frequently Asked Questions
Is mandatory registration for support coordinators happening in 2026?
No. In December 2025, the government confirmed that mandatory registration for standard support coordinators (group 0106) has been paused while broader NDIS reform is considered. Mandatory registration for SIL providers and platform providers proceeded from 1 July 2026, but support coordinators were excluded from that first wave. There is no mandatory registration date currently set for standard support coordinators. The government is designing a commissioned support coordination model expected to begin from 1 July 2028.
What is the difference between standard and specialist support coordination for registration purposes?
Standard support coordinators (group 0106) sit on the verification pathway. Registration is currently optional for these providers, as mandatory registration has been paused. Specialist support coordinators (group 0132) sit on the certification pathway and have always been required to hold registration. They must complete a two-stage audit assessed against the Core Module and Specialist Module 4 of the NDIS Practice Standards. The pause on mandatory registration for standard support coordinators has no effect on group 0132 requirements.
Do unregistered support coordinators have to follow the NDIS Code of Conduct?
Yes. The Code of Conduct applies to every NDIS provider and worker, regardless of registration status. Unregistered support coordinators delivering services to self-managed or plan-managed participants are fully bound by all seven obligations. The Commission can investigate complaints, issue compliance notices, and pursue civil penalties against unregistered providers for Code breaches. Under the NDIS Amendment (Integrity and Safeguarding) Act 2025, serious contraventions attract penalties of up to $3.3 million for an individual and $16.5 million for a corporation.
What is the NDIS commissioned support coordination model?
The commissioned support coordination model is the government's planned replacement for the current open-market approach. Instead of any provider meeting minimum requirements being able to offer coordination, the commissioned model will use a curated panel of approved providers who meet defined quality and integrity standards. Participants will have choice within that panel. The model is expected to begin from 1 July 2028. The specific criteria for panel inclusion have not yet been published.
Do unregistered support coordinators need NDIS Worker Screening Checks?
Not as a legal requirement under the registration framework for most providers. The "no card, no start" rule applies to registered providers through the Practice Standards, not to unregistered providers. However, sole traders who are personally delivering supports must hold a clearance for themselves. Participants can also require workers to hold clearances as a condition of engagement, and many do. Where a complaint involves harm caused by a worker, the Commission may consider whether the provider took reasonable steps to vet that worker before engagement.
Do unregistered support coordinators have to report incidents to the NDIS Commission?
No. Mandatory incident reporting under the NDIS (Incident Management and Reportable Incidents) Rules 2018 applies only to registered providers. Unregistered standard support coordinators have no obligation to proactively report incidents to the Commission. Participants can still complain to the Commission about an unregistered support coordinator's conduct, and the Commission will investigate and can take enforcement action including civil penalties and banning orders.
What does Specialist Module 4 require for specialist support coordinators?
Specialist Module 4 requires documented practitioner expertise commensurate with participant complexity; detailed activity records covering contacts, actions, referrals, and progress against NDIS goals; and a conflict of interest policy applied in practice. Auditors assess all three by reviewing participant files and interviewing coordinators at Stage 2. Generic coordination experience does not satisfy the expertise requirement, and thin activity records are among the most common findings in group 0132 audits.
Should I register voluntarily as a standard support coordinator even though mandatory registration is paused?
Voluntary registration under the verification pathway remains available. The arguments for registering now are market access (some plan-managed participants can only use registered providers for certain supports) and positioning for the commissioned model panel. The argument against is the compliance cost of maintaining registration under a framework that is about to change significantly. Most providers are better served by building documentation to verification-level standard now and making the registration decision once the panel criteria are confirmed. For context on what unregistered NDIS providers of all types must and must not do, the NDIS unregistered provider obligations guide covers the full picture.