Ask the Expert: What Do Former NDIS Lead Auditors Want Every SIL Provider to Know?
Mandatory registration for Supported Independent Living (SIL) providers commenced on 1 July 2026. At the same time, the new SIL Practice Standards came into effect, sitting alongside the existing NDIS Practice Standards that all registered providers must meet.
For providers currently delivering SIL without registration, there's another critical date approaching. To continue operating while your registration application is being assessed, your application must be submitted by 1 October 2026.
Our consultants continue to see the same misconceptions and compliance gaps, regardless of a provider's size. We sat down with two of Provider+'s senior NDIS consultants, Yvette Clark and Gillian Collis, both former NDIS Lead Auditors, to discuss what separates providers who sail through certification from those who don't.
Meet the Experts
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Yvette Clark
Yvette Clark is a Senior NDIS Consultant at Provider+ and a former Lead NDIS Auditor with more than 34 years of experience in the disability sector. She supports providers through NDIS registration, audit preparation and compliance, with extensive experience in Supported Independent Living (SIL) and quality systems.
Gillian Collis
Gillian Collis is a Senior NDIS Consultant at Provider+ and a former NDIS Lead Auditor with more than 20 years of experience across the disability and aged care sectors. She works closely with providers to prepare for registration and audits, helping them build practical systems that meet the NDIS Practice Standards.
01
If You're Not Yet Registered
"When an unregistered provider first comes to you, what's the most common gap you find that they didn't know existed?"
Most unregistered providers underestimate what's required to become a registered NDIS provider. Successful registration depends on more than participant documentation, it requires evidence of compliant governance, workforce management, quality systems and organisational processes.
G
Gill:
Most providers simply don't realise how much is actually required to become a registered provider. They often come to us with little more than a consent form and a service agreement, believing that's enough. It isn't.
Those documents are only a small part of what's required. You also need participant documentation, workforce records, governance systems, policies, procedures and quality management processes that demonstrate you're meeting the Practice Standards. That's what auditors assess.
Y
Yvette:
Honestly, the biggest surprise is usually the sheer volume of documentation required. Providers don't realise how much needs to be in place before an auditor even walks through the door.
It's not just participant files. You also need compliant staff records, governance documentation, emergency management documentation, internal audit processes, complaints and incident management systems, and much more. Most providers underestimate both the scope of the requirements and the evidence needed to demonstrate compliance.
"What's the single biggest mistake providers make when preparing for a SIL certification audit, and why does it keep happening?"
The most common audit issues are incomplete documentation, outdated staff training records and insufficient evidence that compliance systems are working in practice.
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Gill:
The biggest issues are consistently incomplete staff training records, missing documentation and poor emergency preparedness.
Providers naturally focus on delivering quality support, but it's often not until audit preparation begins that they realise things like fire drills, evacuation procedures and emergency planning haven't been properly documented. These are exactly the areas auditors expect to see clear evidence for.
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Yvette:
Participant documentation is another major gap, particularly for participants with higher support needs or where restrictive practices are involved.
We also regularly see shortcomings around medication management, staff training records and work health and safety requirements for SIL properties, including evacuation plans, fire equipment, fire drill records and test-and-tag registers. They're fundamental requirements, but they're often overlooked because providers don't realise how much evidence auditors expect to see.
02
What a Major Non-Conformity Actually Looks Like
"What does a major non-conformity look like in a SIL context, and how preventable are they really?"
A major non-conformity usually occurs when a provider cannot demonstrate that critical compliance systems, such as quality management, internal audits or governance, are operating effectively.
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Yvette:
In my experience, they're highly preventable, and that's probably the frustrating part.
One of the biggest areas is quality management. Providers either don't have a functioning internal audit program, or they can't demonstrate that it's actually being followed.
Having policies isn't enough. Auditors aren't simply checking whether you've got documents sitting in a folder somewhere. They want evidence that your systems are operating across the organisation, that they're being monitored, and that improvements are actually happening.
A lot of providers also underestimate the level of evidence required. Having a policy in place is only half the job. You need records that show it's being applied consistently in day-to-day operations.
03
What Separates the Providers Who Pass From Those Who Don't
"From your experience on both sides of the audit process, what separates providers who pass with flying colours from those who struggle?"
Providers who consistently perform well during certification understand their compliance obligations and maintain effective systems throughout the year, rather than preparing only when an audit is approaching.
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Gill:
It comes down to two things.
The first is genuinely understanding your compliance obligations, not just knowing the standards exist, but understanding how your day-to-day operations align with them.
Next one is having systems that actively manage quality every day, rather than pulling documentation together a few weeks before the audit.
Quite often, the providers who perform best are those who sought experienced support early, instead of trying to fix everything at the last minute.
04
What Registered Providers Might Be Getting Wrong
"A lot of providers think being registered means they're fine. What are you seeing that suggests some registered SIL providers might be in for a surprise now the new SIL Practice Standards are here?"
Registration isn't the finish line. Providers must continue meeting the existing NDIS Practice Standards while also complying with the new SIL-specific Practice Standards.
G
Gill:
The biggest issue is that many providers still don't fully understand the current NDIS Practice Standards or what's actually required. On top of that, they'll now need to understand and comply with a separate set of SIL-specific Practice Standards.
Key personnel also don't always have a clear understanding of their operational responsibilities or the level of accountability expected of them. Internal audits are often minimal, or haven't been done at all, and the systems and processes just aren't strong enough.
The providers most at risk aren't necessarily failing today. They're operating with very little margin for error. With the introduction of the new SIL Practice Standards, that margin becomes much smaller.
"What's something providers never think to prepare for that auditors always check?"
Internal audit evidence is one of the most commonly requested, and most commonly missing, sources of evidence during certification audits.
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Yvette:
Internal audit evidence, every time.
Providers often have policies saying internal audits occur, but when an auditor asks to see the audit schedule or completed audit records, there's nothing available.
Auditors don't just want to hear that a quality system exists. They want to see the evidence such as dates, findings, actions taken and records showing the process has actually been followed.
05
The October 2026 Countdown: What Concerns Our Experts
"With providers preparing for the 1 October 2026 deadline, what concerns you most about what you're seeing from providers right now?"
Many providers underestimate how long it takes to become genuinely audit-ready. Waiting until the registration deadline is approaching can significantly increase compliance risks.
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Gill:
A few things concern me. One is that many providers still don't have a clear understanding of what's required, especially now that the new SIL Practice Standards have been introduced.
Another is that some providers understand the requirements in theory but haven't put them into practice. During a certification audit, intent isn't enough, you need evidence.
The other concern is timing. Many providers underestimate how long it takes to become genuinely audit-ready. Submitting an application before the deadline is only one part of the process.
"If you could only tell an unregistered SIL provider one thing to do before 1 October, what would it be?"
Start by assessing your current level of compliance, identifying gaps and understanding what evidence you'll need before beginning the registration process.
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Gill:
Get an honest assessment of where you actually stand.
Review your current systems against both the existing NDIS Practice Standards and the new SIL-specific standards. Identify your compliance gaps based on evidence, not assumptions.
If you're not confident doing that yourself, get experienced support. There's still time, but it's far better to understand your gaps now than discover them during certification.
Why Provider+ Has an Edge
Provider+ brings something to this space that most competitors can't replicate: our consultants have direct NDIS auditing experience. They've sat on the other side of the table. They know what auditors look for because they've been auditors themselves.
That's not just sector knowledge. It's operational insight that shapes how we help providers prepare. We don't just help you build documentation. We help you build systems that actually work, with practical, honest guidance on what compliance looks like under real audit conditions.
Understand exactly why registration takes 6–12+ months
