From 1 July 2026, Queensland’s new Reportable Conduct Scheme is in full effect. The Scheme sits within the Child Safe Organisations Act 2024 (Qld) and is administered by the Queensland Family and Child Commission (QFCC).
The Scheme provides a mechanism for assessing allegations of child abuse or neglect involving a worker, and for taking action to protect children.
The Reportable Conduct Scheme
Who the Scheme applies to
The Scheme applies to ‘reporting entities’, which are organisations that care for, supervise, or exercise authority over children. This encompasses early education and care services (including day care and out of school hours care), schools (state, independent and non-state), religious bodies, accommodation or residential services, child protection services, services for children with disability, health services, justice or detention services and government entities.
Reportable conduct
Under the Scheme, reporting entities are required to report allegations and convictions concerning child abuse or neglect by workers, complete an investigation in response to allegations about a worker’s behaviour towards children and record outcomes in a way that can be shared with other organisations to prevent harm to children.
Allegations or convictions must be reported to the QFCC if they meet the definition of reportable conduct under the Act. These are referred to as reportable allegations and reportable convictions.
Reportable conduct covers the following categories:
- a child sexual offence
- sexual misconduct in relation to or in the presence of a child (for example, inappropriate touching or the use of sexual language without a legitimate reason)
- ill-treatment of a child (for example, excessive or degrading demands or comments, or inappropriate behaviour management)
- significant neglect
- physical violence committed in relation to or in the presence of a child
- behaviour that causes significant emotional or psychological harm to a child.
Actions that are reasonable for the discipline, management, or care of a child will not constitute reportable conduct, for example, exercising reasonable behaviour management consistent with the school’s code of conduct.
A ‘reportable allegation’ arises if a reasonable belief is formed that a worker has committed reportable conduct. A worker has a ‘reportable conviction’ if they have been convicted of an offence that may involve reportable conduct.
Timing of the conduct
Reportable conduct is not limited to conduct that occurs during work hours. It can occur while a worker is off duty or out of hours, and it can involve former workers if the conduct occurred while they were still engaged by the reporting entity.
Conduct that occurred before 1 July 2026 generally falls outside the Scheme, unless it is reported after 1 July 2026 while the worker is still engaged, or the school voluntarily elects to apply the Scheme to it.
Who an allegation can be made about
Workers who may be the subject of an investigation of a reportable allegation or conviction include anyone who performs work of any kind for the entity. This broadly includes:
- employees (such as teachers)
- volunteers (including parent helpers)
- contractors, subcontractors and consultants (for example, relief teachers engaged through an agency, groundskeepers or IT contractors)
- principals, executive officers and others involved in the school’s management
- trainees and work experience students
- religious leaders or officers connected with the school.
Reporting requirements
When an allegation is made that constitutes reportable conduct, an initial report must be provided to the QFCC within three business days. This should outline the details of the reportable allegation or conviction, the identity of the head of the reporting entity (such as the principal) and any risk management action taken if the worker is still engaged. The reporting entity must also notify the QFCC, as soon as practicable, that an investigation is underway and provide the investigator’s details.
Unless there is a reasonable excuse, an interim report must be provided to the QFCC by the reporting entity within 30 business days of receiving the allegation, outlining the facts and circumstances known to date, an update on action taken and a copy of the worker’s written submissions, if made.
As soon as practicable after the investigation concludes, a final report with investigation findings must be provided to the QFCC by the reporting entity. This must include the facts and circumstances of the reportable conduct, the findings and reasons for the findings, copies of documents relied on, and any risk management action taken or proposed.
Failing to notify or report to the QFCC is an offence for which the head of the reporting entity can face a financial penalty of up to 100 penalty units (equating to a maximum penalty of $17,270 as at 1 July 2026).
The investigation process
An investigator must be impartial, be free from conflicts of interest and afford the worker procedural fairness throughout the investigation process. This includes providing the worker with an opportunity to respond to the allegations and material relied on, and considering that response before any final findings are made.
The outcomes that may result from an investigation into allegations of reportable conduct include:
- substantiated, where on the balance of probabilities the conduct occurred
- unsubstantiated, where it is more likely than not that the alleged conduct did not occur
- no outcome, where it is not possible to determine either way (for example, where an allegation is historical and there is a lack of evidence)
- conduct outside the Scheme, where the conduct occurred but does not constitute reportable conduct.
After reviewing a reporting entity’s final report, the QFCC may request further information, commence its own investigation where appropriate, or provide advice and recommended actions to improve child safeguarding practices.
Key takeaways for schools
- Review and update policies and procedures to align with the obligations under the Scheme.
- Schools have only three business days to provide an initial report to the QFCC once they become aware of a reportable allegation or reportable conviction.
- The scope of the Scheme extends beyond school hours and school premises and can capture former workers for conduct that occurred during their engagement.
- ‘Worker’ is defined broadly, and the obligation extends beyond employees to volunteers, contractors, relief staff and trainees, not just teachers.
- Before finalising any adverse finding, the worker must be given written notice and a genuine opportunity to respond.
If you have any questions about the issues raised in this article or would like assistance with matters related to Queensland’s Reportable Conduct Scheme, please contact our workplace relations and safety team.
