Conflict of Interest Register Software
Record conflicts and gifts in one register, with a management plan on every declaration, reminders when a review falls due, and an export you can hand an assessor. Declaring the conflict is the easy half; showing how you managed it is what gets audited.
On the free trial and every paid plan. No credit card required.
A policy is not a register, and assessors know the difference
Most practices have a conflict of interest policy. Far fewer can produce the declarations made under it, the management plan for each, and evidence that anyone reviewed them since. The NDIS Commission treats a conflict as non-compliant when it is not declared, or declared and then not managed. That gap is almost always a filing problem, not an ethics problem.
What is a conflict of interest register?
A conflict of interest register is the record of every conflict declared in your organisation: who declared it, what the interest is, how you decided to manage it, who was told, and when it is next due for review. It covers actual conflicts, potential ones, and conflicts that only look like a conflict to an outsider. The register is what lets you show an assessor that conflicts are being handled as they arise, rather than dealt with informally and forgotten.
Does the NDIS require a conflict of interest register?
The NDIS Practice Standards require registered providers to identify and manage conflicts of interest as part of governance and operational management. The Commission treats a conflict as non-compliant when it has not been declared, or when it has been declared but not managed properly. Providers are also expected to keep accurate records of how each conflict was managed and to give copies to the parties affected, which in practice means a register plus a management plan per declaration rather than a policy on its own.
What counts as a conflict of interest for an NDIS provider?
The most scrutinised case is support coordination that steers a participant toward supports the same organisation delivers, because it puts the provider's revenue against the participant's choice and control. Others come up constantly: an ownership or financial interest in a service you refer to, gifts or hospitality from a supplier, secondary employment with a competitor, a close personal relationship with a participant, and supporting a family member. None of these are prohibited. Failing to declare one, or declaring it and doing nothing, is the problem.
How often do declarations need to be reviewed?
There is no single legislated interval, so the test is whether your review cadence is defensible and actually happening. ClinicComply defaults to 12 months and lets you set any interval per declaration. What matters at audit is the evidence that reviews occur: a register full of declarations that were filed once and never revisited shows a system that ran for a day, which is why ClinicComply reminds managers as each review date approaches and keeps reminding them weekly while a review is overdue.
Built around the questions an assessor actually asks
A management plan on every declaration
Declaring the conflict is the easy half. Each record also holds how you are managing it, who was notified, and what alternatives the participant or patient was offered, which is the part an assessor asks to see.
Review reminders that keep going
Set a review date and managers are reminded at 30, 14, 7 and 1 days before, on the day, then every week while it stays overdue. An overdue review that nobody acts on is the failure this exists to prevent.
Conflicts and gifts in one register
Record a conflict, or a gift or benefit with its value and whether it was accepted or declined. One register, one export, because auditors ask about both together.
Declare for anyone, not just logins
Name a team member, or record a contractor, board member, supplier or family member as a free-text party. A declaration is never blocked because someone has no account.
Evidence attached, not filed elsewhere
Upload a signed declaration or management plan straight onto the record, or link a document you already hold. Either way it also lands in your Evidence Library.
Counts toward your accreditation
The register feeds the conflict of interest items in the NDIS Practice Standards, RACGP and dental checklists, and appears in your evidence pack with its declaration counts and review position.
The declarations practices actually need to make
Categorise each declaration, tag it to the framework it sits under, and record whether the interest is actual, potential or perceived.
- Financial or ownership interest in a related service
- Referral to an entity you or a colleague own
- Support coordination recommending in-house supports
- Gifts, hospitality and benefits from suppliers
- Secondary employment or outside directorships
- Supporting or treating a family member or friend
- Close personal relationship with a participant
- Board, committee or advisory appointments
- Any other interest you need on the record
Conflicts of interest: common questions
What is a conflict of interest register?
A conflict of interest register is the record of every conflict declared in your organisation: who declared it, what the interest is, how you decided to manage it, who was told, and when it is next due for review. It covers actual conflicts, potential ones, and conflicts that only look like a conflict to an outsider. The register is what lets you show an assessor that conflicts are being handled as they arise, rather than dealt with informally and forgotten.
Does the NDIS require a conflict of interest register?
The NDIS Practice Standards require registered providers to identify and manage conflicts of interest as part of governance and operational management. The Commission treats a conflict as non-compliant when it has not been declared, or when it has been declared but not managed properly. Providers are also expected to keep accurate records of how each conflict was managed and to give copies to the parties affected, which in practice means a register plus a management plan per declaration rather than a policy on its own.
What counts as a conflict of interest for an NDIS provider?
The most scrutinised case is support coordination that steers a participant toward supports the same organisation delivers, because it puts the provider's revenue against the participant's choice and control. Others come up constantly: an ownership or financial interest in a service you refer to, gifts or hospitality from a supplier, secondary employment with a competitor, a close personal relationship with a participant, and supporting a family member. None of these are prohibited. Failing to declare one, or declaring it and doing nothing, is the problem.
How often do declarations need to be reviewed?
There is no single legislated interval, so the test is whether your review cadence is defensible and actually happening. ClinicComply defaults to 12 months and lets you set any interval per declaration. What matters at audit is the evidence that reviews occur: a register full of declarations that were filed once and never revisited shows a system that ran for a day, which is why ClinicComply reminds managers as each review date approaches and keeps reminding them weekly while a review is overdue.
Do we need to record gifts and benefits as well?
Yes, and they belong in the same register rather than a separate spreadsheet, because the assessor question is the same: what was offered, what did you decide, and who knew. ClinicComply records a declaration as either a conflict or a gift or benefit, and gift records additionally capture what was offered, its approximate value, and whether it was accepted or declined. RACGP practices and NDIS providers both need this for supplier and pharmaceutical relationships.
Is the conflict of interest register included in the free trial?
Yes. The register is on the free trial and on every paid plan, including Solo, with no cap on the number of declarations. You can file a declaration, assign a mitigation action, attach evidence and run the export before you decide anything.
Related templates & reading
- Unlimited declarations on every plan
- Australian data residency (Sydney)
- On the free trial
This page is general information, not legal advice. Verify conflict of interest obligations against current NDIS Commission, RACGP and AHPRA guidance.
Be the practice the assessor compliments.
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