A Deep Dive into Queensland’s Child Safe Organisations System
In 2024, Queensland passed new legislation, the Child Safe Organisations Act 2024, which is designed to promote the safety and wellbeing of all children in Queensland. The legislation has two key parts which will bring into effect the Child Safe Standards and the Reportable Conduct Scheme in 2025 and 2026, respectively.
The Child Safe Organisations and the Reportable Conduct Scheme frameworks will both be introduced in a phased approach, which means different sectors will have to meet their legal responsibilities at different times. You can read more about the implementation of these frameworks and the timeline of the phased approach here.
As every organisation in Queensland will be at a different stage of compliance, there will be ‘sector leads’, who will mostly be Queensland Government agencies, who will implement the legislation in a way that best suits the organisations within that sector. The Queensland Family and Child Commission (QFCC) will be the oversight body.
This article serves as a comprehensive deep dive into the Child Safe Organisations System in Queensland, outlining the Child Safe Standards and Reportable Conduct Scheme, and when organisations are required to comply with the new legislation.
What are the Child Safe Standards?
The new Queensland Child Safe Standards are based on the National Principles, which were endorsed by all Australian states and territories in 2019. This means the framework in Queensland will be consistent with schemes operating in other states.
Any organisation which is based and operating in Queensland which is deemed to be a child safe organisation, will be required to uphold the 10 Child Safe Standards.
The 10 Child Safe Standards are:
- Child safety and wellbeing is embedded in organisational leadership, governance and culture.
- Children are informed about their rights, participate in decisions affecting them and are taken seriously.
- Families and communities are informed and involved in promoting child safety and wellbeing.
- Equity is upheld and diverse needs respected in policy and practice.
- People working with children are suitable and supported to reflect child safety and wellbeing in practice.
- Processes to respond to complaints of child abuse are child focused.
- Staff and volunteers are equipped with the knowledge, skills and awareness to keep children safe through ongoing education and training.
- Physical and online environments promote safety and wellbeing and minimise the opportunity for children to be harmed.
- Implementation of the Child Safe Standards is regularly reviewed and improved.
- Policies and procedures document how the organisation is safe for children.
Organisations must also embed what is known as the Universal Principle in each of the 10 Child Safe Standards, which requires that organisations provide an environment that ensures the cultural safety of Aboriginal and Torres Strait Islander children.
How and when will the Child Safe Standards be Implemented?
The implementation of the Child Safe Standards in Queensland will commence in a staged approach from 1 October 2025. There are three phases which outline which organisations are required to implement the standards, and when. The phases are summarised below:
Phase 1: Commences 1 October 2025
- Child protection services
- Services for children with disability
- Justice and detention services
- Government entities
Phase 2: Commences 1 January 2026
- Accommodation and residential services
- Early childhood education and care services
- Education services
- Health services
- Community services
Phase 3: Commences 1 April 2026
- Religious bodies
- Commercial services for children
- Transport/transport-related services
- Services or activities provided primarily for children.
What is the Reportable Conduct Scheme?
The Reportable Conduct Scheme applies to organisations with a high degree of responsibility for children or organisations which engage in activities where there is an increased risk to children. Any child organisation listed under the Reportable Conduct
Scheme is also required to implement the Child Safe Standards. The Reportable Conduct Scheme requires these organisations to report and investigate any concerns about the conduct of staff or volunteers in relation to their work with children.
Reportable conduct includes:
- A child sexual offence
- Sexual misconduct committed in relation to, or in the presence of a child
- Ill-treatment of a child
- Significant neglect of a child
- Physical violence committed in relation to, or in the presence of a child, or
- Behaviour that causes significant emotional or psychological harm to a child
In Queensland, the Reportable Conduct Scheme requires organisations to notify the Queensland Family and Child Commission (QFCC) when there are allegations or convictions of reportable conduct committed by an employee or volunteer.
The head of a Child Safe Organisation will be required to:
- Ensure systems are in place for preventing, reporting, investigating and responding to allegations and convictions of reportable conduct
- Notify the QFCC of reportable allegations or convictions
- Arrange for the allegations to be investigated and provide a final report to the QFCC
- Provide information as requested by the QFCC
How and when will the Reportable Conduct Scheme be Implemented?
The implementation of the Reportable Conduct Scheme will commence in a staged approach from 1 July 2026.
There are three phases which outline which organisations are required to implement the standards, and when.
Phase 1: Commences 1 July 2026
- Child protection services
- Services for children with disability
- Justice or detention services
- Government entities
Phase 2: Commences 1 January 2027
- Accommodation or residential services
- Education services
- Health services
Phase 3: Commences 1 July 2027
- Religious bodies
- Early childhood services
What should organisations be doing now to prepare for the Child Safe Organisations legislation?
With the phased implementation, organisations must be aware of whether they are required to comply with the new legislation, and if so when they are required to comply by. Each sector in Queensland will need to take different steps at different times to ensure they are compliant with Child Safe Standards and the Reportable Conduct Scheme and are meeting their obligations under the Child Safe Organisations legislation.
Organisations should not wait until the legislation is phased in. Organisations should be acting now to ensure that they are fully compliant in anticipation of the Child Safe Organisations legislation being implemented. This includes organisations reviewing their policies and procedures, child safe recruitment, training staff and having child-focused complaints systems in place that identifies and responds to reportable conduct.
How can Safe Space Legal help?
If your organisation requires assistance in meeting its obligations to implement the Child Safe Standards or Reportable Conduct Scheme, please get in touch with our team today.
Safe Space legal has significant legal and holistic expertise to empower organisations to be child safe. Our services include:
- Audits and Gap analyses against the National Principles and Child Safe Standards
- Child Safety policy development
- Child Safety training tailored to the organisation
- Reportable Conduct investigations