From royal commissions to real accountability: Queensland’s Reportable Conduct Scheme and child safety investigations

Australia’s child-safety landscape is undergoing a profound shift. Following the findings of the Royal Commission into Institutional Responses to Child Sexual Abuse, governments committed to nationally consistent oversight of how organisations respond to allegations of harm involving children. That commitment was reinforced by the Disability Royal Commission, which again highlighted systemic failures in institutional responses. 

A central reform flowing from these inquiries is the Reportable Conduct Scheme (RCS) — a framework designed to ensure serious allegations involving children are reported, independently overseen, and properly investigated. 

What is the Reportable Conduct Scheme? 

The Reportable Conduct Scheme requires organisations to report and investigate certain types of serious misconduct by workers or volunteers that involve children. Unlike traditional complaint or disciplinary processes, the scheme applies even where conduct does not amount to a criminal offence and can include behaviour occurring outside the workplace. 

“Reportable conduct” typically includes: 

• Child sexual offences and sexual misconduct 

• Ill-treatment or significant neglect 

• Physical violence committed in the presence of a child 

• Behaviour causing significant emotional or psychological harm 

The model was first established in New South Wales and was formally recommended for national adoption by the Royal Commission (Recommendation 7.9). 

Queensland: A major reform on the horizon 

Queensland has now confirmed its commitment to this reform. On 16 October 2025, the Queensland Government announced that the Reportable Conduct Scheme would be fast-tracked and fully operational from 1 July 2026. 

The scheme is legislated under the Child Safe Organisations Act 2024 (Qld), which integrates both: 

• the Reportable Conduct Scheme, and 

• mandatory Child Safe Standards. 

From 1 July 2026: 

• The head of an organisation must notify the Queensland Family and Child Commission (QFCC) within three business days of becoming aware of a reportable allegation or conviction. 

• An investigation must commence as soon as practicable, with an interim or final report provided to the QFCC within 30 business days, unless an extension is granted. 

The scheme applies broadly across sectors, including: 

• education and early childhood services 

• child protection and youth services 

• health and disability services 

• residential, respite and accommodation services 

• justice and detention services 

• religious and community organisations 

Importantly, organisations are required to investigate allegations even if they do not result in criminal charges, and even if the conduct occurred outside the course of employment. 

How other states and territories compare 

Queensland’s reforms sit within a broader national picture: 

New South Wales, Victoria and the ACT - These jurisdictions already operate mature Reportable Conduct Schemes, with an established focus on investigation quality, regulator engagement, and ongoing compliance. The NSW Reportable Conduct Scheme is widely considered the "gold standard" because its model of independent oversight for child abuse allegations was recommended for adoption nationally by the Royal Commission into Institutional Responses to Child Sexual Abuse. 

Tasmania - Tasmania’s scheme commenced on 1 January 2024 under the Child and Youth Safe Organisations Act 2023. 

South Australia, Western Australia and the Northern Territory - These jurisdictions have accepted the Royal Commission’s recommendations in principle but have not yet implemented a scheme. Legislative progress is expected over coming years. 

Queensland therefore represents one of the largest upcoming RCS implementations in Australia, both in scale and in the diversity of organisations affected. 

Why the scheme matters 

The Reportable Conduct Scheme fundamentally reframes child safety as a governance and accountability issue, not just a legal or human resources matter. 

For organisations, the risks of non-compliance are substantial: 

• Strict statutory timeframes 

• Financial penalties for failures to notify or report 

• Regulatory scrutiny by an independent oversight body 

• Serious reputational damage if investigations are mishandled 

For children and families, the scheme improves transparency, reduces the risk of institutional cover-ups, and strengthens confidence that allegations will be handled consistently and independently. 

Preparing for 1 July 2026 

With the commencement date now fixed, Queensland organisations have a narrowing window to prepare. Many will need to build or significantly uplift their capability.  

The Reportable Conduct Scheme is not a one-off compliance task. It introduces an ongoing obligation that will shape investigative practice, governance, and risk management across Queensland’s child-serving sectors for years to come. 

For many, this will be the first time they have been legally required to conduct formal, regulator-facing investigations into serious allegations involving children. This is where preparation matters.