VRQA Releases Updated Draft Guidelines to the Minimum Standards for School Registration

In late April 2026, the VRQA released updated guidelines to the minimum standards for school registration.

Generally, the new guidelines aim to:

• Provide more guidance about what compliance looks like;
• Explain evidence requirements in plain language; and
• Make clear when requirements apply only to new school applications.

What the education sector needs to know

It is most important for schools to take note of the following significant proposed changes:

1. Multi-school proprietors: Critically, the new guidelines expressly prohibit cross-subsidisation between schools under the same body. Even if owned by the same legal entity, money, assets or loans from one school cannot be used to support another. In addition, while shared services (including IT, HR or payroll) are still permissible, they must now be documented in a formal service agreement detailing a specific methodology for cost allocation. And, new schools within a system will not be able to be funded from existing schools.
   
   
2. Governance: The 2027 guidelines explicitly require that the school governing body must have a majority of independent directors. Most importantly, all applicants for school registration and registered schools must be charities registered with the Australian Charities and Not-for-profits Commission. Previously, only a state-based not-for-profit requirement was specified. The NFP to registered charity status update formalises the school’s obligation to the public, increases the complexity of its legal governing documents and introduces a permanent federal layer of accountability, through the ACNC Governance Standards, alongside state-based school registration standards.
   
   
3. Evidence of Board activity: During a cyclical review, schools must now provide the last 12 months of governing authority meeting agendas and minutes. The 2022 guidelines focused more on structural documents like constitutions and charters. The VRQA will now assess how a board functions in practice, not just what its policies stipulate.
   
   
4. Financial metrics: The business plan requirements have shifted from using the “Direct Measure of Income (DMI)” score to the “Capacity to Contribute (CTC)” score. Schools must update their five-year financial forecasts to align with current Commonwealth funding terminology and metrics.
   
   
5. Digital evolution: The 2027 guidelines introduce a formalised process for existing schools to register an online or hybrid campus. This includes a requirement for a comprehensive online supervision policy and an enrolment agreement that defines the role of parents/guardians during school hours. It recognises that digital delivery is a permanent fixture of education requiring its own distinct duty of care framework.
   
   
6. Student attendance – welfare integration: While twice-daily attendance remains mandatory, the 2027 guidelines place a heavier emphasis on using attendance data to identify students at risk. There is a new requirement to record unsatisfactory attendance directly on a student’s file.

Following consultation, the guidelines will be available to all school in Term 3, and apply to registered schools from 1 January 2027.

Make sure to keep an eye out, as the VRQA will continue to consult further on the new guidelines.

How we can help

Moores’ Education and Training team has a wealth of experience in navigating the complex landscape of independent school regulation and assisting clients to meet their compliance requirements. Please contact our expert Education and Training team for tailored advice on how you can ensure your school is staying up to date with the relevant guidelines.

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^{Disclaimer: This article provides general information only and is not intended to constitute legal advice. You should seek legal advice regarding the application of the law to you or your organisation.}