Submission 174
Submission to the Senate Community Affairs Legislation Committee
Inquiry: The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026
By Tim and Emily Pryde 23 May 2026
Executive Summary
This submission outlines significant risks associated with proposed amendments to the NDIS Act 2013 that expand or mandate provider registration and alter the regulation of behaviour support. Drawing on lived experience supporting a participant with profound disability and complex behaviours, we highlight that registration is not a universal safeguard and does not reliably ensure safety, quality, or competence. For participants with high and complex needs, safety is derived from continuity, deep relational knowledge, and attuned support—factors that cannot be replicated through administrative compliance.
Families are already experiencing de facto pressure to use only registered providers, particularly where behaviour support plans or restrictive practices are involved. This trend is eroding genuine choice and control and disproportionately affects participants with complex needs, who rely on specialist sole traders and small providers. These providers are often the only workers willing and able to support high-risk clients, yet they are the least able to absorb the administrative and financial burden of registration. Their exit from the sector would collapse already thin markets and increase risk to participants.
The proposed changes also fail to recognise the essential role of family-centred models of care. Unpaid carers provide an estimated $77.9 billion in care annually—more than the total cost of the NDIS—and are critical to both participant safety and system sustainability. A legislative framework that sidelines families risks increasing NDIS expenditure through crisis escalation, hospitalisation, and reliance on more costly service models.
We recommend that the Committee ensure any amendments preserve genuine choice and control, provide flexible and fit-for-purpose registration alternatives, recognise family-centred models, and avoid embedding rigid compliance structures that may inadvertently reduce safety for participants with the highest and most complex needs.
Introduction
We welcome the opportunity to provide evidence to the Community Affairs Legislation Committee regarding the proposed amendments to the NDIS Act 2013, particularly those relating to provider definitions, registration requirements, and the regulation of behaviour support.
We are the parents and full-time carers of our 18-year-old son, Alex, who lives with profound autism (ASD Level 3), severe/profound intellectual disability, chronic anxiety, sensory pain, trauma, and highly complex behaviours of concern. Our lived experience spans more than a decade of navigating multiple systems—education, health, disability, and the NDIS. We have seen firsthand what keeps a person with complex needs safe, and what places them at risk.
Our submission focuses on the unintended but serious consequences of expanding or mandating NDIS provider registration in a way that does not accommodate family-centred models of care. We argue that the proposed changes risk reducing participant safety, eroding choice and control, collapsing thin markets, and increasing costs to the NDIS, contrary to the stated aims of the reforms.
Submission 174
Registration is not a universal safeguard
We acknowledge the legitimate intent behind safeguarding measures. However, registration alone does not guarantee safety, quality, or competence. For participants with high and complex needs, safety is derived from:
- deep, long-term understanding of the participant
- consistent communication partners
- trust built over time
- attuned responses to distress and escalation
These natural safeguards cannot be replicated through compliance frameworks, audits, or paperwork. In some cases, over-reliance on registration creates a false sense of security, shifting focus from real-world safety to administrative compliance.
The proposed amendments risk embedding this misconception into legislation.
De facto pressure toward mandatory registration is already eroding choice and control
Although the NDIS has not formally mandated registration across all supports, families of participants with complex needs are experiencing increasing pressure to use only registered providers—particularly where behaviour support plans (BSPs) or regulated restrictive practices are involved.
This pressure is already:
- narrowing the pool of available workers
- excluding the specialists who can safely support complex participants
- forcing families toward large providers who often decline high-risk clients
- undermining the legislated principle of choice and control
The Committee should note that policy intent and operational reality have diverged. The proposed amendments risk formalising a trend that is already harming participants.
Impact on sole traders and specialist providers
The workers most capable of supporting participants with severe behaviours of concern are often sole traders or small specialist providers. These individuals:
- have the skill and willingness to work with complex clients
- build long-term, trusting relationships
- provide continuity that prevents crises and restrictive practices
However, they are also the providers least able to absorb the cost and administrative burden of registration, audits, and reporting. The proposed changes will drive many of these workers out of the sector entirely.
This will disproportionately harm participants with complex needs, who already face extremely thin markets.
Economic implications: the system relies on unpaid care
Unpaid carers provide an estimated $77.9 billion worth of care annually—significantly more than the total cost of the NDIS. Families are the backbone of disability support in Australia.
A legislative framework that sidelines families in favour of bureaucratic oversight is not only harmful to participants—it is economically unsustainable. The proposed amendments risk increasing NDIS expenditure by:
Submission 174
- forcing participants into more expensive service models
- increasing reliance on registered providers who may not accept complex clients
- triggering crises, hospitalisations, and restrictive practices when family-centred models are disrupted
The Committee should consider whether the reforms align with the principles of efficiency, sustainability, and value for money.
Case studies demonstrating systemic risk
Case Study 1: Registration does not equal competence
Individuals with minimal experience can become registered providers by purchasing administrative support. These providers may then take on clients requiring restrictive practices. Meanwhile, families with decades of lived expertise are barred from using the same supports unless they operate through a registered entity. This is a structural inconsistency that undermines safety.
Case Study 2: Highly regulated systems can still fail
The Victorian Education Department—despite extensive oversight, governance, and reporting—was unable to keep our son safe. Thousands of incident reports and multiple layers of regulation did not prevent harm. Regulation protected the institution, not the child.
Case Study 3: Registered providers routinely decline complex clients
Between ages 8–10, approximately 40 registered services refused to support our son. The two that accepted him briefly withdrew due to complexity and risk. Only specialist sole traders—unregistered but highly skilled—were able to support him safely. Mandatory registration would eliminate these workers entirely.
These examples demonstrate that registration is not a proxy for safety, and that rigid regulatory frameworks can actively harm participants with complex needs.
Family-centred models must be recognised in legislation
Alex’s current support model—a family-led, multidisciplinary team consisting mostly of highly skilled sole traders—is the only arrangement that has ever kept him safe and eliminated the need for restrictive practices.
However, the proposed legislative changes do not accommodate such models. They assume:
- that registered entities should replace family involvement
- that families cannot fulfil key safeguarding roles
These assumptions are not evidence-based and do not reflect the lived reality of participants with profound disability.
Risks of the proposed amendments
If implemented without flexibility, the proposed changes will:
- reduce choice and control
- collapse thin markets for complex participants
- increase NDIS costs
- force participants into unsuitable service models
- increase the use of restrictive practices
- undermine family-centred care
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- prioritize bureaucratic protection over participant wellbeing
These outcomes are inconsistent with the objects and principles of the NDIS Act.
Conclusion
Families are not NDSI providers, but they are the most important protective structure for many participants with complex needs. A legislative framework that sidelines families, restricts access to specialist sole traders, and elevates bureaucratic compliance over real-world safety will harm the very people the NDIS exists to support.
We urge the Committee to ensure that any amendments to the NDIS Act:
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Preserve genuine choice and control
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Enable flexible, family-centred models of care
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Provide fit-for-purpose registration alternatives for sole traders
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Avoid embedding rigid compliance structures that increase risk and cost
The NDIS must remain a system that adapts to the needs of participants-not one that forces participants to adapt to the needs of bureaucracy.
We thank the Committee for considering this submission.