SIL Registration Checklist: What Unregistered Providers Need Before July 2026

If you are currently delivering Supported Independent Living (SIL) services without NDIS registration, this checklist covers exactly what you need to prepare before mandatory registration commences on 1 July 2026.

1 July 2026 is the start of the transition period — not a hard deadline by which you must hold a Certificate of Registration. However, the NDIS Commission has indicated that unregistered providers who have not commenced the registration process will eventually be unable to deliver SIL supports. Specific cut-off dates and transition arrangements will be published by the Commission as the reform progresses. Do not wait for that guidance before starting preparation.

SIL registration requires a certification audit, which is the most comprehensive NDIS audit pathway. You will be assessed against 22+ practice standards across multiple modules, with mandatory site visits, staff interviews, participant interviews, and file reviews.

This is not a quick process. Preparation for registration — including gap analysis, policy development, and audit readiness — can take 6 to 12 months. The formal registration process itself, from application to Commission decision, typically takes 3 to 6 months. If you haven't started preparation, you are already behind.

What Makes SIL Registration Different?

SIL is classified as a high-risk support under the NDIS. This means:

SIL is classified as a high-risk support under the NDIS. This means:

• You must complete a certification audit (not verification)
• You must comply with the Core Module plus supplementary modules
• Auditors will conduct on-site assessments at your SIL properties
• Auditors will interview participants, staff, and management
• You need implemented systems with evidence, not just written policies

Unregistered providers who have operated without oversight face a significant shift. You will need to demonstrate that your governance, risk management, incident reporting, and workforce systems meet the NDIS Practice Standards before you can continue delivering SIL.

Practice Standards Modules for SIL Providers

SIL providers must demonstrate compliance with multiple NDIS Practice Standards modules:

Core Module (All Providers)

SIL providers must demonstrate compliance with multiple NDIS Practice Standards modules.

Core Module (All Providers)

The Core Module applies to every registered provider and covers:

• Rights and responsibilities of participants
• Governance and operational management
• Provision of supports
• Support provision environment
• Feedback and complaints management
• Incident management
• Human resource management
• Information management

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Module 1: High Intensity Daily Personal Activities

Most SIL providers deliver high-intensity supports and must comply with this module, which covers:

• Assessment, planning, and delivery of high-intensity personal supports
• Safe personal care that respects dignity and privacy
• Mealtime management and nutrition supports (where required)
• Ongoing monitoring and documentation
• Responsive support delivery that adapts to changing needs
• Incident escalation and response
• Worker training, competency, and supervision

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Module 2a: Implementing Behaviour Support Plans

If you support participants with behaviour support needs, you must comply with this module, which covers:

• Understanding and applying approved Behaviour Support Plans
• Reducing restrictive practices in line with NDIS Commission requirements
• Person-centred, trauma-informed, rights-based support delivery
• Embedding positive behaviour support strategies
• Monitoring and reviewing behaviour support outcomes
• Recognising and responding to behaviours of concern
• Incident escalation and reporting
• Collaboration with Behaviour Support Practitioners
• Worker training and supervision for implementing Behaviour Support Plans

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SIL-Specific Requirements

Beyond standard modules, SIL providers face additional requirements related to:

• Shared living arrangements and compatibility assessments
• Participant choice and control in their living environment
• Individualised support within group settings
• Vacancy management that prioritises participant needs
• Supporting participants to develop independent living skills

New Practice Standards for SIL

The NDIS Commission is developing new Practice Standards specific to Supported Independent Living, with a focus on improving quality and safety in shared accommodation settings, strengthening oversight of daily support delivery, and enhancing worker training requirements and audit expectations. As of April 2026, these standards have not yet been finalised, and specific audit arrangements under the new standards have not been confirmed. Providers should begin preparing now against the current Practice Standards, with the expectation that readiness activities may need to be adjusted once the new SIL-specific standards are published. Monitor the NDIS Commission website for updates.

Complete SIL Registration Checklist

Use this checklist to assess your readiness and identify gaps. Work through each section systematically.

1. Governance and Organisational Structure

Documents and evidence required:

• Organisational chart showing current structure and reporting lines
• Position descriptions for all roles (including Board/Directors if applicable)
• Evidence of defined roles and responsibilities for key personnel
• Evidence of management meetings and documented decisions
• Strategic plan or business plan demonstrating organisational direction
• Constitution or governing rules (for incorporated entities)
• Evidence of active Board or governance oversight (for larger organisations)
• Conflict of interest register and management process
• Delegation of authority framework

Key questions auditors will ask:

• How does your governance structure provide oversight of SIL services?
• How do you ensure accountability for participant safety?
• How are strategic decisions made and communicated?

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2. Business Registration and Compliance

Documents and evidence required:

• ABN registration
• ASIC company extract (if applicable)
• Trust deed (if operating as a trust)
• Evidence of compliance with state/territory business registration requirements
• Evidence of compliance with any sector-specific registration (e.g. community housing registration if applicable)

3. Insurance

Documents and evidence required:

• [ ] Public liability insurance certificate (minimum $10 million recommended for SIL)
• [ ] Professional indemnity insurance certificate
• [ ] Workers compensation insurance (if employing staff)
• [ ] Property insurance (if you own or lease SIL properties)
• [ ] Evidence that insurance coverage is appropriate for SIL service delivery

4. Policies and Procedures

SIL providers need a comprehensive policy suite covering all NDIS Practice Standards. Each policy must be:

• Specific to your organisation (not generic templates)
• Reflective of how you actually operate
• Implemented with evidence of use
• Reviewed regularly (at least annually)

Core policies required:

• [ ] Governance policy
• [ ] Risk management policy and procedure
• [ ] Quality management and continuous improvement policy
• [ ] Privacy and confidentiality policy
• [ ] Information management policy
• [ ] Feedback and complaints policy and procedure
• [ ] Incident management policy and procedure (including reportable incidents)
• [ ] Human resources policy
• [ ] Recruitment and selection procedure
• [ ] Worker induction procedure
• [ ] Training and development policy
• [ ] Supervision policy and procedure
• [ ] Performance management procedure
• [ ] Code of conduct
• [ ] Work health and safety policy
• [ ] Emergency and disaster management policy
• [ ] Continuity of supports policy

SIL-specific policies required:

• [ ] SIL service delivery policy
• [ ] Participant intake and assessment procedure
• [ ] Service agreement procedure
• [ ] Support planning procedure
• [ ] Shared living arrangements and compatibility assessment procedure
• [ ] Participant rights and choice policy
• [ ] Mealtime management procedure (if applicable)
• [ ] Medication management procedure (if applicable)
• [ ] Restrictive practices policy and procedure (if applicable)
• [ ] Behaviour support implementation procedure (if applicable)
• [ ] Overnight and sleepover support procedure (if applicable)
• [ ] Participant money and property policy (if managing participant funds)
• [ ] Vacancy management procedure

5. Risk Management

Documents and evidence required:

• [ ] Risk management framework
• [ ] Risk register with identified risks, assessments, and treatments
• [ ] Evidence of regular risk register reviews (at least quarterly)
• [ ] Evidence of how risks are escalated and managed
• [ ] SIL-specific risks identified (e.g. shared living, participant compatibility, staffing continuity)

Key questions auditors will ask:

• How do you identify and manage risks in your SIL services?
• What are the biggest risks in your SIL operations and how do you mitigate them?
• How do you monitor whether risk controls are working?

6. Quality Management

Documents and evidence required:

• [ ] Quality management framework
• [ ] Internal audit schedule and reports
• [ ] Evidence of continuous improvement actions taken
• [ ] Participant feedback collection and analysis
• [ ] Quality improvement register or action log
• [ ] Evidence of regular service delivery reviews
• [ ] Key performance indicators for SIL services

Key questions auditors will ask:

• How do you know if your SIL services are delivering good outcomes?
• Give an example of an improvement you made based on feedback or audit findings.

7. Complaints Management

Documents and evidence required:

• [ ] Complaints policy and procedure
• [ ] Complaints register with all complaints logged
• [ ] Evidence of complaint investigations and outcomes
• [ ] Evidence outcomes were communicated to complainants
• [ ] Evidence of systemic improvements following complaints
• [ ] Information provided to participants about how to make complaints
• [ ] Easy-read or accessible complaints information for participants

Key questions auditors will ask:

• How do participants know how to make a complaint?
• Walk me through how a recent complaint was handled.

8. Incident Management

This is a critical area for SIL providers. Auditors will scrutinise your incident management closely.

Documents and evidence required:

• [ ] Incident management policy and procedure
• [ ] Incident register with all incidents logged
• [ ] Evidence of incident investigations with root cause analysis
• [ ] Corrective actions documented and implemented
• [ ] Evidence of reportable incidents notified to NDIS Commission within required timeframes (24 hours for most reportable incidents)
• [ ] Evidence of staff training on incident identification and reporting
• [ ] Incident trend analysis and reporting to management
• [ ] Evidence incidents inform risk register and quality improvement

Reportable incidents include:

• Death of a participant
• Serious injury of a participant
• Abuse or neglect of a participant
• Unlawful sexual or physical contact
• Sexual misconduct
• Unauthorised use of restrictive practices

Key questions auditors will ask:

• How do staff know what to report and when?
• Show me how a recent incident was managed from identification to resolution.
• How do you ensure reportable incidents are notified within 24 hours?

9. Worker Screening

All workers delivering SIL supports must have a valid NDIS Worker Screening Check clearance. This is mandatory.

Documents and evidence required:

• [ ] Register of all workers (employees, contractors, volunteers)
• [ ] Current NDIS Worker Screening Check clearance for every worker
• [ ] System for tracking clearance expiry dates
• [ ] Process for verifying clearances before workers commence
• [ ] Evidence clearances are checked before workers have contact with participants

Important notes:

• Processing times vary by state (typically 2 to 6 weeks, but can be longer)
• Workers cannot deliver supports until clearance is received
• You must verify clearances yourself (do not rely on worker self-declaration)

10. Staff Training and Competency

Documents and evidence required:

• [ ] Training register for all workers
• [ ] Evidence of NDIS Worker Orientation Module completion for all workers
• [ ] Induction records for all workers
• [ ] Role-specific training records
• [ ] Evidence of competency assessment for high-risk tasks
• [ ] Ongoing professional development records
• [ ] Signed code of conduct acknowledgements

SIL-specific training should include:

• [ ] Manual handling and personal care
• [ ] Mealtime management (if supporting participants with swallowing difficulties)
• [ ] Medication administration (if applicable)
• [ ] Behaviour support and de-escalation
• [ ] Restrictive practices (if authorised to use)
• [ ] First aid and emergency response
• [ ] Infection control
• [ ] Fire safety and evacuation
• [ ] Participant rights and dignity
• [ ] Privacy and confidentiality
• [ ] Incident identification and reporting

Key questions auditors will ask:

• How do you ensure workers have the skills to support participants safely?
• How do you assess competency for high-risk tasks like medication administration?

11. Supervision and Support

Documents and evidence required:

• [ ] Supervision policy and procedure
• [ ] Supervision schedule for all workers
• [ ] Records of supervision sessions
• [ ] Evidence of how supervision addresses worker performance and development
• [ ] Clear reporting lines documented
• [ ] On-call or after-hours support arrangements for workers

Key questions auditors will ask:

• How often do workers receive supervision?
• How do you support workers dealing with challenging situations?

12. Participant Files

Auditors will sample participant files to verify your service delivery. Each file should include:

Intake and assessment:

• [ ] Referral or enquiry documentation
• [ ] Intake assessment
• [ ] Compatibility assessment (for shared living arrangements)
• [ ] NDIS plan or relevant extracts
• [ ] Funding confirmation

Service agreement:

• [ ] Service agreement signed by participant (or representative)
• [ ] Evidence of informed consent
• [ ] Evidence participant understood the agreement (e.g. easy-read version, interpreter used)
• [ ] Schedule of supports
• [ ] Fees and charges clearly documented

Support planning:

• [ ] Individual support plan aligned to NDIS goals
• [ ] Evidence participant was involved in developing their plan
• [ ] Regular plan reviews documented
• [ ] Evidence supports are delivered as planned

Daily records:

• [ ] Progress notes or shift notes
• [ ] Evidence of supports delivered
• [ ] Communication records
• [ ] Any variations to planned supports documented

Health and safety:

• [ ] Health information and care needs
• [ ] Medication records (if applicable)
• [ ] Mealtime management plan (if applicable)
• [ ] Behaviour support plan (if applicable)
• [ ] Risk assessments specific to the participant
• [ ] Emergency plan for the participant

Consent and privacy:

• [ ] Consent forms for information sharing
• [ ] Evidence of privacy being maintained
• [ ] Records stored securely

13. Restrictive Practices (If Applicable)

If your SIL services involve restrictive practices, this area will receive significant scrutiny.

Documents and evidence required:

• [ ] Restrictive practices policy and procedure
• [ ] Evidence all restrictive practices are authorised under relevant state/territory legislation
• [ ] Current behaviour support plans for all participants where restrictive practices are used
• [ ] Evidence plans are developed by a registered Behaviour Support Practitioner
• [ ] Restrictive practice use register
• [ ] Evidence of reporting to NDIS Commission as required
• [ ] Evidence of reduction strategies and progress toward reducing restrictive practices
• [ ] Training records for all staff implementing restrictive practices
• [ ] Competency assessments for staff using restrictive practices

Key questions auditors will ask:

• How do you ensure restrictive practices are only used as a last resort?
• Show me evidence of how you are working to reduce restrictive practice use.

14. Properties and Environment

Documents and evidence required:

• [ ] Evidence SIL properties are safe and fit for purpose
• [ ] Fire safety compliance (smoke alarms, evacuation plans, fire extinguishers)
• [ ] Electrical safety compliance
• [ ] Pool safety compliance (if applicable)
• [ ] Accessibility features appropriate to participant needs
• [ ] Maintenance records
• [ ] Cleaning schedules and records
• [ ] Emergency evacuation plans for each property
• [ ] Evidence of regular safety inspections

15. Emergency and Continuity Planning

Documents and evidence required:

• [ ] Emergency and disaster management plan
• [ ] Business continuity plan for SIL services
• [ ] Evidence of emergency drills conducted
• [ ] After-hours emergency contact arrangements
• [ ] Backup staffing arrangements
• [ ] Participant-specific emergency plans

Key questions auditors will ask:

• What happens if a worker does not show up for a shift?
• How would you maintain services during a major incident or disaster?

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Gap Analysis: Assess Your Readiness

Use this summary to assess where you stand:

If you have multiple areas marked "Not Started" or "Partial", you need to begin preparation immediately.

Timeline: What You Should Be Doing Now

The timeline below reflects a provider who is starting preparation in April 2026. For providers who are not yet close to audit-ready, this is an ambitious schedule. The registration process typically takes 3 to 6 months from application to Commission decision, and preparation before that point can take just as long. Prioritise your highest-risk gaps first and engage an auditor early to understand their availability.

April 2026 (Now):

• Complete gap analysis using this checklist
• Identify critical gaps that will take longest to address
• Begin policy development or updates
• Lodge NDIS Worker Screening applications for any workers without clearances (allow 6 to 8 weeks for processing)
• Contact approved auditors to understand availability and get quotes — availability will tighten significantly as July approaches
  

May 2026:

• Continue implementing systems and gathering evidence
• Train staff on new or updated policies and procedures
• Start internal audit processes
• Submit your NDIS registration application once your systems are sufficiently developed
• Book your certification audi

June 2026:

• Complete Stage 1 audit (desktop review) if audit is booked
• Address any Stage 1 findings promptly
• Prepare for Stage 2 audit
• Ensure all participant files are complete
• Brief staff on audit process and expectation

July 2026:

• Mandatory registration transition period commences
• Complete Stage 2 audit (on-site assessment) if scheduled
• Address any non-conformities identified
• Await NDIS Commission determination
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Estimated Costs

Budget for the following costs: