QUEENSLAND
Family & Child
Commission
Queensland
Government
— 07 3900 6000
Committee Secretary
Community Affairs Legislation Committee
Via email: community.affairs.sen@aph.gov.au
Dear Committee Secretary,
Thank you for the opportunity to provide a submission to the Senate Standing Committee on
Community Affairs Legislation’s inquiry into the National Disability Insurance Scheme
Amendment (Integrity and Safeguarding) Bill 2025 (the Bill).
The Queensland Family and Child Commission (the Commission) is Queensland’s statutory authority responsible for promoting the safety, wellbeing and rights of children and young people, identifying systemic issues affecting children and families. The Commission also has regulatory functions under the Child Safe Organisations Act 2024 (Qld), implementing Child Safe Standards and the Reportable Conduct Scheme.
| welcome the intent of the Bill to strengthen integrity, quality and safeguarding
arrangements within the National Disability Insurance Scheme (NDIS). The proposed reforms intersect directly with child safeguarding systems, particularly for children with disability and children in out-of-home care who rely on NDIS-funded supports.
This submission focuses on the importance of ensuring national disability safeguarding reforms operate coherently with child safeguarding and worker screening frameworks, and that regulatory systems are designed to support integrated and interoperable oversight.
Safeguarding children with disability across service systems
Children with disability are disproportionately represented among cohorts experiencing vulnerability, often involved with multiple service systems including child protection, health, education and justice portfolios. Where safeguarding and regulatory responsibilities are fragmented across sectors and jurisdictions, the risk of harm increases.
The Bill’s focus on enhanced provider regulation, information-gathering and enforcement presents an opportunity to strengthen protections for children with disability. For these reforms to be effective, however, they must align with state-based child safeguarding and worker screening systems that operate alongside and in parallel with the NDIS.
Level 8, 63 George Street Telephone: 07 3900 6000 Brisbane Qld 4000 Facsimile: 07 3900 6050 PO Box 15217 Website: qfcc.qld.gov.au
Brisbane City East Qld 4002 ABN: 91 102 013 458
Integrated worker screening and safeguarding registers
The Child Death Review Board’s report, /n Plain Sight, identifies the absence of integrated worker screening and safeguarding registers as a significant regulatory gap (see Operational Recommendation 5).’
Current screening and safeguarding systems cross disability, education, early childhood and child-related employment are not designed to routinely share or match information, meaning an individual barred in one register may still be able to obtain clearance in another. This creates a risk that adverse findings in one system may not be visible in another, allowing unsafe individuals to move between sectors undetected.
Strengthening safeguards in a single sector, without addressing interoperability, risks displacing harm rather than preventing it.
An integrated or interoperable approach to worker screening and safeguarding registers would improve safety outcomes for children and NDIS participants, reduce duplication of screening processes, and enhance regulatory intelligence across jurisdictions.
Alignment with national inquiry findings
Both the Royal Commission into Institutional Responses to Child Sexual Abuse (2017) and the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (2023) identified fragmentation between safeguarding and worker screening systems as a critical weakness in Australia’s regulatory framework. While these findings have been broadly accepted, implementation remains uneven.
The Bill provides a timely opportunity to strengthen coordination between the NDIS Quality and Safeguards Commission and state-based child safeguarding authorities. The Commission encourages the Committee to consider whether the Bill sufficiently enables such coordination, or whether additional legislative, policy, or implementation measures are required.
‘ Queensland Child Death Review Board. 2025, In Plain Sight — Review into System Responses to Child Sexual Abuse, https://www.afcc.qld.gov.au/sites/default/files/2025-12/report-csa-in-plain-sight-web.pdf
qfcc.qld.gov.au Queensland Family and Child Commission
Conclusion
The Commission supports the intent and policy direction of the Bill and its focus on strengthening participant safety, provider regulation and system integrity. To maximise its protective effect for children with disability, the Commission encourages reforms that:
e promote interoperability between disability and child safeguarding registers and worker screening systems;
e reduce regulatory gaps that allow unsafe individuals to move between sectors undetected; and
e support coordinated safeguarding across Commonwealth and state jurisdictions.
An aligned, cross-sector approach will better protect children with disability and enhance public confidence in safeguarding systems nationally.
lf you would like to discuss this matter further, please don’t hesitate to contact me directly on
PS © via email at
Yours sincerely
Luke Twyford
Principal Commissioner
Queensland Family and Child Commission
Sb February 2025
qfcc.qld.gov.au te Queensland Family and Child Commission