Whose compliance obligations are these, mine or my registered provider's? When the strengthened Quality Standards commenced, the director of a four-person nursing agency in Bendigo, subcontracting to two aged care organisations, found her inbox full of webinar invitations and compliance-software ads implying her team needed its own governance framework.

This example is illustrative.

Every subcontracting business should ask, because the answer decides whether the new framework is a burden or a non-event.

What changed on 1 November 2025

The new Aged Care Act and the strengthened Aged Care Quality Standards both commenced on 1 November 2025, the same day Support at Home replaced Home Care Packages. The regulator is the Aged Care Quality and Safety Commission, and under the new Act providers must be registered in the relevant registration categories to deliver funded aged care.

Registered providers carry the compliance and audit obligations. The Standards are enforced against the registered provider, the entity the Commission registers, audits and holds to account.

Where that leaves a subcontracting partner

If you deliver services through a registered provider (the local partner model), those obligations sit with that provider, not your business. You don't need your own registration, audit program or government-facing compliance function.

That isn't the same as having no responsibilities. You're still accountable for:

  • Safe, respectful service delivery. Turning up as agreed, working competently, and treating older clients with dignity.
  • Prompt incident reporting. If something goes wrong or nearly goes wrong, your registered provider needs to know quickly to meet its obligations.
  • Keeping your own house in order. Current insurance, relevant checks, honest communication about capacity.

The test of a good backbone provider: compliance gets lighter for you, not heavier. A partnership that shifts the provider's homework onto your desk is a red flag.

Why this suits small operators

Compliance anxiety keeps capable local businesses out of aged care. Under this structure a four-person agency or a sole trader can work in a regulated sector without an internal compliance function it can't afford.

Weighing up a partnership? Ask what the provider carries and what they expect of you. Ours is at become a partner; our why us page covers how we support partners.