What unregistered SIL providers must do now

For years, plenty of SIL supports were delivered by unregistered providers paid through plan-managed or self-managed participants. That world is changing. Government reviews have made clear that higher-risk supports like Supported Independent Living are heading toward mandatory registration — and the direction of travel is one way.

Why this is coming

SIL is high-stakes: vulnerable people, often in their own homes, frequently overnight. The reviews into NDIS safeguarding concluded that this kind of support needs the oversight that registration brings. Whether or not a specific date applies to you, the safe assumption for any serious SIL operator is: get registration-ready now.

What this means for your current participants

If you currently deliver SIL to participants who are plan-managed or self-managed, they can use an unregistered provider — for now. But think about it from the participant's perspective. If they are reassigned an agency-managed plan, or if they move to a different arrangement, they may only be able to use a registered provider. If you're not registered, you could lose that participant through no fault of either of you.

That's worth a conversation with your current participants and their plan managers. Let them know you're working toward registration. It builds trust and reassures them that their support arrangement is stable.

What "getting ready" actually means

• Your document foundation — the full set of policies, procedures, registers and forms the Practice Standards require. This is the part that takes the longest, so start here.
• Your evidence trail — start keeping real records now: incidents, complaints, supervision, consent. Auditors want history, not a folder created the week before.
• Your worker screening — make sure everyone delivering supports has valid NDIS Worker Screening checks.
• Your audit booking — certification audits take time to arrange. Leaving it late means scrambling.

A practical step-by-step prep plan

Here's a realistic approach broken into phases. Adapt the timing to your situation, but don't compress it too much — building genuine evidence takes time.

• Phase 1: Get your documents sorted (allow several months) — Either write your document library from scratch or get a ready-made pack personalised to your organisation. Either way, personalise everything: your name, ABN, real processes. Don't submit anything with placeholder text.
• Phase 2: Start building your evidence trail (ongoing from day one) — Set up your registers immediately and use them from the start. Every incident recorded. Every complaint logged. Every supervision session dated and noted. This history is what an auditor wants to see.
• Phase 3: Train your team (before you book your audit) — Walk every worker through the key policies. Run a scenario-based session on incidents, complaints and safeguarding. Record who attended and when. Keep the sign-in sheet.
• Phase 4: Choose your auditor — The NDIS Commission maintains a list of approved quality auditors. You get to choose who audits you. It's worth doing a bit of research: ask other providers who they used, look at turnaround times and communication style. Book well in advance — approved auditors can have long lead times.
• Phase 5: Submit your application to the NDIS Commission — The application itself (through the NDIS Commission portal) happens before or alongside the audit booking. Allow time for this process, as there may be back-and-forth with the Commission before the audit is formally arranged.
• Phase 6: The audit — For SIL, this is a certification audit with an on-site visit, staff interviews and document review. If your systems are real and your staff know the policies, this is manageable. It's a check, not a trap.

Choosing an auditor: what to look for

Not all approved quality auditors are the same. When researching your options, consider:

• Experience with small SIL providers — Some auditors specialise in large organisations. You want someone who understands what a small or sole-operator SIL business looks like.
• Availability — How far out are they booked? If you have a target registration date, work backwards from there.
• Communication — Do they respond promptly? Are they clear about what they need from you before the audit? A good auditor makes the process easier, not harder.
• Cost — Audit fees vary. Get quotes from a couple of approved auditors so you can budget properly.

The providers who start preparing now will glide through registration. The ones who wait will scramble.

The cost of waiting

Providers who wait until registration is forced on them face a crunch: every approved auditor booked out, documents rushed, and the risk of losing participants who can only stay with a registered provider. Early movers get to do it calmly.

Common mistakes unregistered providers make when preparing

• Waiting for a firm deadline before starting — The registration process takes time. If you start the week a deadline is announced, you're already behind.
• Assuming past practice counts as evidence — If you've been delivering SIL for years but haven't been keeping formal records, you can't backfill an evidence trail. You can only start now and build from here.
• Not telling your participants — Keep your current participants informed of your progress. It builds loyalty and avoids surprises.
• Underestimating the document work — The document library for a SIL certification is substantial. Start building it now, not later.

Keeping your current participants informed

One of the things providers often overlook is communicating with their current participants and their families. If you're working toward registration, tell them. Explain what it means: that your service is going through a formal quality check, that it's a good thing, and that it doesn't mean anything is changing day-to-day. Participants who understand what registration is are less likely to worry about it and more likely to feel confident in your service.

If participants are interviewed by an auditor as part of the process — and for certification, they may be, with their consent — they should already know this is happening. Surprise on audit day is avoidable with a simple conversation beforehand.

What registration actually costs — and how to budget for it

Registration isn't free. The main costs are:

• Your own document pack — Whether you build it yourself (time cost) or use a ready-made service (money cost).
• NDIS Worker Screening checks — There's a fee per worker, paid to your state screening authority. Costs vary by state.
• Auditor fees — The certification audit fee depends on your auditor, the size of your service, and the scope of the audit. Get quotes from at least two approved auditors.
• NDIS Commission application fee — There is an application fee payable to the Commission. Check the current fee schedule on the Commission's website.
• Your time — Preparing for an audit is not a small project. Budget for the hours you'll spend on documents, training, and preparation. If you have staff, budget for their time in training sessions too.

Knowing the full cost upfront helps you plan and avoids nasty surprises. Factor the audit cost into your business plan as an investment in your ability to operate and grow.

What happens after registration

Once you're registered, you're registered for a period of time — typically three years for certification. During that time, you may have a mid-term review (a lighter-touch check, usually desktop-based). At the end of the period, you'll need to renew — another audit. This is why building your quality system as a living part of your business matters so much: registration is not a one-time event. It's a continuous commitment to operating to the standard.

How to make the most of the time you have now

Whether registration is months away or a couple of years away, the best thing you can do right now is treat your service as if you were already registered. Use the incident register. Record your supervision sessions. Keep participant notes to the standard. Renew screening checks before they expire. Review your policies on schedule.

When your audit eventually comes, you won't be scrambling to build a system from nothing. You'll already have months or years of evidence that your service runs properly. That's the difference between a stressful audit and a calm one.

You don't need to be perfect. You need to be genuine. Auditors can tell the difference, and so can your participants.

A word on sole traders and family-run SIL

Some of the smallest SIL providers are run by a single person — often someone who started by caring for a family member and then expanded to support others in the community. The registration process can feel disproportionately large for a business of one or two people. That's a fair feeling. But the standards are the same regardless of size, and the Commission does work with small providers through the process. The key is not to be put off by the scale of the requirements, but to break it into manageable steps and start early.

If you're a sole operator, the governance quality area in particular asks you to think about what happens if you are unavailable — illness, family emergency, burnout. Your continuity plan needs to have a real answer to that question. Who would support your participants if you couldn't? What's the backup arrangement? Building that network before you need it is both good practice and an audit requirement.

Frequently asked questions from unregistered providers

"Do I need to stop taking new participants while I work toward registration?" This depends on who manages the participant's plan. If participants are self-managed or plan-managed, you may be able to continue as normal while you work toward registration. If you're seeking to work with agency-managed participants, you will need registration first. Check the current rules with the NDIS Commission if you're unsure.

"Can I use the same documents for registration that I already use?" If you're currently delivering SIL without registration, you may have some documents in place. Start with what you have, but review each document against the Practice Standards — many unregistered providers' informal documentation doesn't meet the standard required for certification. It's better to know this early.

"How do I choose between approved auditors?" The Commission's website lists all approved quality auditors. Contact two or three, describe your service and ask for a quote and a timeline. Ask if they have experience auditing small SIL providers. Pick the one who seems genuinely helpful, not just the cheapest — a good auditor makes the process easier.

Registration is no longer a "maybe later" for serious SIL providers. The ones who prepare now will glide through it. The ones who wait will pay for it.