Submission 259
Submission 259
SUBMISSION BY
Disability Intermediaries Australia Limited.
CONTACT
Chief Executive Officer
1300 757 512 info@intermediaries.org.au
COPYRIGHT
© Disability Intermediaries Australia Limited.
All rights reserved. No part of this submission may be reproduced, distributed
or transmitted in any form without prior consent from Disability Intermediaries Australia Limited.
CITATION
If you wish to cite this submission, please use:
DIA, 2026, SUBMISSION TO
INQUIRY INTO THE NDIS AMENDMENT BILL 2026, DISABILITY
INTERMEDIARIES AUSTRALIA LIMITED, SYDNEY, AUSTRALIA.
Disability Intermediaries Australia Limited 2
Submission 259
Acknowledgement of Country
Disability Intermediaries Australia respectfully acknowledges Australia’s Aboriginal and
Torres Strait Islander communities and their rich culture and pays respect to their Elders past, present and emerging. We acknowledge Aboriginal and Torres Strait Islander peoples as Australia’s first peoples and as the traditional owners and custodians of the land and water on which we rely.
We recognise and value the ongoing contribution of Aboriginal and Torres Strait Islander
peoples and communities to Australian life and how this enriches us. We embrace the spirit of reconciliation, working towards the equality of outcomes and ensuring an equal
Submission 259
Acknowledgement of the Rights of People with a Disability
Disability Intermediaries Australiaacknowledges the objectives of the United Nations Convention on the Rights of Persons with Disabilities which affirms that all persons
with all types of disabilities must enjoy allhuman rights and fundamental freedoms.
Disability Intermediaries Australia embraces
this Convention as we continue to support choice and control and the dignity of risk for all
Australians with a disability.
Submission 259
ABOUT DISABILITY INTERMEDIARIES AUSTRALIA
Formed in 2018, Disability Intermediaries Australia (DIA) is the national peak body for non government disability intermediary organisations and practitioners. Members deliver
Support Coordination, Plan Management, Psychosocial Recovery Coaching and digital
intermediary services, reaching around two thirds of NDIS participants. Our membership spans sole practitioners through to substantial organisations, serving participants across every state and territory including regional, remote, First Nations, and culturally and linguistically diverse communities.
DIA members are intermediaries: they sit between the NDIA and participants, helping participants exercise choice and control over their funded supports. They translate the promise of the NDIS into practice. Plan managers pay invoices, manage budgets, and protect participants from financial exploitation. Support coordinators connect participants to services, advocate for adequate plans, and navigate the system on behalf of people who cannot always do so themselves. Psychosocial recovery coaches build the capacity of participants with mental health conditions to pursue their recovery goals.
DIA maintains that a well-functioning support market is foundational to the NDIS. Intermediaries—when well designed, regulated and funded—make choice and control practical by translating rules into action, reducing administrative burden, and strengthening accountability in plan implementation.
DIA has a long record of advocating for stronger, more consistent regulation of intermediary services. We believe that high quality, professionally accountable intermediaries are essential to the scheme working as it was designed to. We welcome the Government’s commitment to improving integrity and quality in this space, and we bring this submission in a spirit of genuine partnership
EXECUTIVE SUMMARY
DIA supports the reform program’s commitment to quality and integrity. We do not ask the Committee to reject this Bill. We ask for three things.
First, reconsideration of the related party provisions. DIA fully supports the objective of ensuring plan managers are genuinely independent from the services they fund. However, the related party provisions as drafted extend well beyond capturing genuine conflicts of interest. They risk prohibiting transparent, well-governed arrangements — including integrated providers in thin markets and First Nations communities — that cause no participant harm. DIA proposes replacing categorical structural prohibition with a regulatory management framework aligned to the Corporations Act standard, anchored by a mandatory public conflict of interest disclosure register and explicit protections for thin market and community-controlled providers.
Second, urgent action on the commercial decisions facing our members. The Bill legislates the architecture for a plan management panel and a commissioned support coordination function, but critical details — eligibility criteria, deed of arrangement terms, fees, and panel size — have not been disclosed. Providers are making irreversible exit and restructuring decisions now, in the absence of the information they need. Every quality provider who exits prematurely is a loss to participants. DIA asks the Committee to recommend that the NDIS Quality and Safeguards Commission immediately implement a registration renewal amnesty for all intermediaries whose audit renewal falls due before panel criteria and commissioned function entry requirements are publicly announced,
Disability Intermediaries Australia Limited 5
Submission 259
and that all critical details be disclosed with suPicient lead time for informed commercial decisions.
Third, a genuine, structured working partnership. DIA asks to be formally included in the co-design of panel criteria, deed of arrangement terms, commissioned function entry requirements, and any accreditation standard for plan management. DIA has the member knowledge, sector expertise, and professional standards infrastructure to contribute meaningfully. The reform program will be stronger for it, and the transition safer for the participants our members serve.
Disability Intermediaries Australia Limited 6
Submission 259
- The Related Party Provisions: DIA’s Principal Concern with the Legislation 1.1 DIA supports the principle; we are concerned about the drafting DIA fully supports the objective of ensuring that plan managers are genuinely independent from the services they fund on participants’ behalf. A plan manager who controls, or financially benefits from, the service delivery they are authorising has a structural conflict of interest that undermines the integrity of the financial intermediary function. This is exactly the kind of conduct the related party provisions are designed to prevent, and DIA supports that intent.
Our concern is with how the provisions are drafted. As currently written, the related party framework extends well beyond capturing genuine conflicts of interest. It risks prohibiting structural arrangements that do not create actual participant harm, that are common and legitimate in a maturing market, and that in some communities are the only viable model for delivering both plan management and support services to participants who would otherwise go without. DIA’s strong preference is that conflict of interest be managed through regulation and professional standards rather than legislated structural prohibition — for reasons we set out below.
Disability Intermediaries Australia Limited 7
Submission 259
Submission 259
1.3 The case for regulatory management over legislative prohibition DIA’s position is that the most ePective and durable approach to managing conflicts of interest in plan management is through regulation and professional standards rather than legislative structural prohibition. We make this argument for three reasons.
First, prohibition is a blunt instrument that catches legitimate arrangements alongside harmful ones, as the four categories above illustrate. Regulation, by contrast, can be designed to target the actual risk — undisclosed conflicts, covert financial relationships, participant coercion — while permitting arrangements that are transparent, governed, and demonstrably managed. A mandatory, publicly searchable conflict of interest disclosure register, operated by the Commission and updated in real time, would give participants, the NDIA, and the public visibility of every related party connection held by every plan manager. Undisclosed conflicts would become immediately detectable. The register targets the information gap that enables harm, rather than the corporate structures that happen to trigger a categorical definition.
Second, legislative prohibition creates permanent market structure rigidity that is diPicult to reverse and may prevent future innovation. The NDIS is a young scheme and the intermediary market is still maturing. Models of integrated service delivery that are genuinely beneficial to participants — particularly in thin markets where combined service provision is the only viable model — should not be foreclosed by permanent legislative prohibition based on a policy response to the compliance failures of a specific period. Regulatory frameworks can be updated as evidence develops. Legislation cannot be changed quickly in response to unintended consequences.
Third, prohibition is particularly harmful in thin markets. In communities where a single provider delivers multiple services because no alternative exists, a categorical related party ban does not improve participant choice. It eliminates services. The participant whose plan manager is prohibited from also coordinating their supports does not gain an independent plan manager — they lose a plan manager entirely if the local provider cannot restructure to comply. This is a participant harm the provisions, as drafted, will produce in identifiable communities across Australia.
Disability Intermediaries Australia Limited 9
Submission 259
1.4 What DIA proposes DIA proposes that the Government replace the current categorical related party prohibition approach with a regulatory management framework built around the following elements:
-
Alignment with the Corporations Act framework: related party relationships assessed by reference to materiality and actual governance arrangements, not categorical structural connection. Well-governed, transparently structured arrangements with documented separation and participant disclosure should not be treated the same as covert conflicts.
-
A mandatory conflict of interest disclosure register, operated by the Commission: every plan manager required to declare all related party relationships in real time, publicly searchable. This makes the information gap that enables harm visible to participants and regulators without prohibiting the underlying arrangements.
-
A specific thin-market and community-controlled provider pathway within any panel or commissioning criteria, recognising that combined service provision in thin markets serves participants rather than exploiting them, and that categorical exclusion in these communities produces coverage deserts rather than improved participant protection.
-
An explicit code of conduct provision specifying the referral practices that are prohibited regardless of corporate structure: financial inducements, undisclosed commissions, directing participants to related services without disclosing the connection and oPering alternatives. These are the behaviours that harm participants. They should be named and prohibited directly, regardless of whether the provider has a related party relationship. DIA believes this framework achieves the Government’s stated objective — protecting participants from plan managers who exploit their position for financial gain — more ePectively than legislative structural prohibition, because it targets the actual conduct rather than the corporate architecture. It also preserves the capacity for legitimate, well governed integrated service delivery to continue serving participants, particularly in communities where no alternative exists.
Disability Intermediaries Australia Limited 10
Submission 259
1.5 Our request to the Committee DIA asks the Committee to recommend that the Government review the related party provisions in the Bill with a view to aligning them with the Corporations Act standard, incorporating materiality thresholds and governance-based assessment, and providing a regulatory management pathway for arrangements that are transparent and governed. We further ask that the Committee recommend explicit thin-market protections in any panel or commissioning criteria.
We recognise the Government’s legitimate concern with conflicts of interest in plan management. We share it. We ask only that the legislative response be calibrated to the actual harm rather than the broadest possible structural definition, and that DIA be included in the design of the regulatory framework that will replace it.
Disability Intermediaries Australia Limited 11
Submission 259
- DIA’s Support for Reform — and Our Request for
Partnership
2.1 DIA has long advocated for stronger intermediary regulation DIA has publicly and consistently called for stronger regulation of the intermediary sector for more than eight years.
Our members are among the most compliant operators in the NDIS ecosystem. They have built their practices around participant outcomes. They are not the problem the reform program is designed to address. They are the solution the scheme needs to retain. 2.2 Our members face significant commercial decisions without the information they need The reform program as currently structured asks plan managers and support coordinators to make irreversible commercial decisions in a very short timeframe, without the information those decisions require. The Bill legislates the architecture for a plan management panel and a commissioned support coordination function, but has not disclosed:
-
The eligibility criteria for the plan management panel, commencing October 2027.
-
The entry requirements for the commissioned support coordination function, commencing July 2028.
-
Whether full registration or enrolment will be required for support coordinators to be eligible for the commissioned function.
-
The terms of the deed of arrangement that will govern plan managers on the panel.
-
The fee that will apply to panel plan managers under the deed.
-
The size of the panel relative to current participant demand and geographic coverage requirements. Without these answers, a plan management provider cannot determine whether to invest in panel readiness, restructure their practice, wind down operations, or prepare their staP for redundancy. A support coordinator cannot determine whether to invest in registration, defer it, or exit the market. These decisions have significant employment consequences for a sector that — based on DIA’s own 2021 member workforce survey — employs a workforce of which approximately 40 per cent have lived experience of disability.
The timeframe is not abstract. Registration renewal cycles are already falling due. Providers are making exit decisions now, in the absence of the information they need, because uncertainty is itself a form of commercial pressure. Every provider who exits prematurely is a loss to participants who valued and relied on that relationship.
Disability Intermediaries Australia Limited 12
Submission 259
2.3 Our request: a close working relationship with Government and the
Commission
DIA is not asking the Committee to reject this Bill. We are asking the Committee to recommend that the Government enter a genuine, structured working relationship with DIA and our members as it designs the details of the reform program. Specifically, DIA requests:
-
That the NDIS Quality and Safeguards Commission immediately implement a registration renewal amnesty for all plan managers and support coordinators whose audit renewal falls due before the panel criteria and commissioned function entry requirements are publicly announced. Providers should be permitted to defer their renewal without fault, penalty, or adverse consequence to their current registration status. It is not reasonable to require providers to incur registration costs whose future value is entirely unknown.
-
That DIA be formally invited to contribute to the development of the plan management panel criteria, deed of arrangement terms, commissioned support coordination entry requirements, and any quality standards or performance metrics that will apply to intermediary functions. DIA has the member knowledge, sector expertise, and professional standards infrastructure to contribute meaningfully to this design work.
-
That the panel criteria, deed of arrangement terms, commissioned function entry requirements, and any fee arrangements be disclosed and genuinely consulted on before commencement, with suPicient lead time for providers to make informed commercial decisions.
-
That a unified accreditation standard for plan management be co-developed by DIA, the Commission, and the NDIA — purpose-built for the intermediary function, specifying sector-appropriate qualifications, conflict of interest obligations, participant-facing standards, and CPD requirements — as the quality mechanism that underpins both the panel and the broader market.
Disability Intermediaries Australia Limited 13
Submission 259
Conclusion
DIA brings this submission as an organisation that has been advocating for better regulation of the intermediary sector for nearly eight years. Our membership began because intermediaries felt that we needed to make a statement about standards when none existed. We support the reform program’s commitment to quality and integrity. We ask for two things: the partnership and information our members need to navigate an uncertain transition in a very short timeframe, and a reconsideration of the related party provisions so that the legislative response is calibrated to actual participant harm rather than catching well-governed operators whose corporate arrangements bear no relationship to the conduct the provisions target.
DIA is ready to work with the Government, the NDIA, and the Commission to get this right. We are available to provide oral evidence to the Committee and to participate in any consultation process the Government establishes.
Disability Intermediaries Australia
Tanya Walford
Acting CEO
1 June 2026