Current compliance trends, high-risk areas and practical guidance to help childcare services prepare for an unannounced compliance visit.
By BEST Childcare Consultancy
There has probably never been a stronger focus on child safety and compliance in early childhood education and care than there is right now. Regulatory changes, serious incidents and recent enforcement actions are encouraging all services to take a closer look at the everyday practices that keep children safe.
For Approved Providers, Nominated Supervisors and service leaders, it is worth asking: If ECRU arrived for an unannounced compliance visit tomorrow, would we feel confident in what they would see?
Compliance is more than having the right policies. It is visible in everyday practice—how educators supervise, manage transitions, conduct head counts, administer medication, maintain records, secure the environment and respond when something goes wrong.
Most services work incredibly hard to get these things right, but small gaps can develop over time. Finding and correcting them yourself is far better than having them identified following an incident or during a regulatory visit.
So, what should you be checking in 2026? This BEST guide looks at the key areas emerging from current ECRU information, with practical questions and links to official guidance and resources to help you identify and address any gaps.
ECRU and ACECQA guidance, tools and templates to help you address any gaps you find.
1. Adequate Supervision – The Standout Issue for 2026
If there is one area every service should review immediately, it is adequate supervision. ECRU’s 2026 Sector Updates contain repeated enforcement matters involving inadequate supervision. These include children being inadequately supervised within services, during excursions and OSHC activities, a child left on a locked bus, children leaving services and a seven-year-old being found approximately one kilometre from a service. The message for services is clear: being within ratio does not automatically mean children are adequately supervised. Supervision needs to be active, dynamic and effective.
Educators should be able to demonstrate how they:
- position themselves according to risk and children’s needs;
- continually scan and listen;
- identify and manage blind spots;
- communicate with other educators;
- know which children they are responsible for;
- adjust their position when circumstances change;
- supervise higher-risk activities more closely; and
- maintain supervision during busy routines and transitions.
This should include reviewing supervision during indoor and outdoor play, toileting, nappy changes, meals, sleep and rest, arrivals and departures, transitions, excursions and transportation. ACECQA’s 2026 supervision guidance specifically identifies transitions, transportation, excursions, arrivals and departures, sleep/rest and other higher-risk situations as circumstances requiring careful supervision planning. Check your service: Don’t simply ask, “Are we in ratio?” Ask, “If I stood in this room or playground for 20 minutes, could I see active and dynamic supervision happening?”
Official guidance and tools:
ACECQA – Adequate Supervision Resources
https://www.acecqa.gov.au/adequate-supervision-resources
ACECQA – What Adequate Supervision Looks Like in Practice
https://www.acecqa.gov.au/what-adequate-supervision-looks-practice
2. Missing Children, Gates, Doors and Children’s Whereabouts
Closely connected to supervision is a particularly serious risk: a child leaving a service or becoming unaccounted for. ECRU’s 2026 published enforcement activity includes several incidents involving children leaving services, being unaccounted for or not being adequately supervised. Services should examine much more than whether the front gate locks.
Consider: Who is responsible for each child? How do we know where every child is? What happens when children move between environments? Are gates checked? Could a child leave unnoticed? What happens if our head count does not match? Head counts should also be meaningful. Simply counting “23 children” is less protective if educators do not recognise which child is missing. Review gates, fences, doors, collection procedures, transition practices, playground boundaries, shared spaces and your response procedure for a missing or unaccounted-for child.
Official guidance and tools:
ACECQA – Adequate Supervision Resources
https://www.acecqa.gov.au/adequate-supervision-resources
This resource includes specific guidance on minimising the risk of children going missing or being unaccounted for and children being mistakenly locked in or out of service premises.
3. Transitions – Small Moments With Big Risks
Transitions deserve particular attention because even a service with strong supervision throughout most of the day can become vulnerable during the few minutes when children are moving between people, places or activities. This might include moving from inside to outside, room to bathroom, playground to mealtime, room to sleep area, school to OSHC, service to excursion, bus to service, or between families and educators at arrival and departure.
These are often busy periods when educators are opening gates, assisting individual children, talking with families, cleaning, preparing environments or completing several tasks at once. This can create moments where responsibility for a child becomes unclear or supervision is unintentionally reduced. Review your Flow of the Day with your team and identify where educators are multitasking, where supervision may be stretched and, most importantly, whether it is always clear who is responsible for each child during every transition.
Official guidance:
ACECQA – Active Supervision
https://www.acecqa.gov.au/qa2-information-sheet-active-supervision-ensuring-safety-and-promoting-learning
4. OSHC School Collection and Safe Arrival
OSHC services should give particular attention to school collection arrangements. A critical question is: What happens when a child who is expected to attend does not arrive?
Services should have reliable systems for reconciling expected attendance against the children actually collected or arriving at the service. Review who checks attendance, who contacts the school or family, how quickly this happens, what occurs when nobody can be contacted and how responsibility is transferred between the school, family and OSHC service.
Official guidance:
ACECQA – Safe Arrival of Children
https://www.acecqa.gov.au/qa2-information-sheet-safe-arrival-children
5. Excursions and Regular Outings
Several serious supervision incidents published by ECRU have involved excursions. Having an excursion risk assessment in a folder is not enough if the document does not reflect what actually happens. Before an excursion, consider:
Where could we lose sight of a child? Where are the toilets? Who supervises them? How will children be grouped? Who conducts head counts? What happens if groups separate? Are the proposed educator numbers actually sufficient for this location and these particular children?
Risk assessments should be living documents rather than paperwork completed simply to meet a requirement.
Official guidance and templates:
ACECQA – Adequate Supervision Resources
https://www.acecqa.gov.au/adequate-supervision-resources
ECRU – Compliance Checklists, Forms, Templates and Risk Assessment Examples
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
The ECRU page includes an Excursions and Regular Outings risk-assessment example template.
6. Transportation – Account for Every Child
The March 2026 ECRU Sector Updates included an incident involving a seven-year-old child left unattended on a locked bus on a 39-degree day. Transportation therefore deserves careful scrutiny. Services should review embarkation and disembarkation records, vehicle checks, educator responsibilities, attendance reconciliation and the distinction between driving and actively supervising children. A particularly important question is: Who physically checks the entire vehicle after the children have disembarked, and how is that check recorded?
Official guidance:
ACECQA – Guidance for Adequate Supervision During Transportation
https://www.acecqa.gov.au/qa2-guidance-adequate-supervision-during-transportation
ECRU – Resources and Transporting Children Safely Factsheet
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
7. Burns and Environmental Hazards
In February 2026, ECRU reported an incident involving an eight-month-old child who received a severe burn after being left next to a bottle warmer. In April, ECRU subsequently published a Prevent Risk of Burns Compliance Bulletin. That makes burns and environmental hazards an important area for services to review. Look beyond obvious hazards. Consider bottle warmers, hot drinks, kitchens, food trolleys, electrical appliances, heaters, hot water, chemicals, damaged equipment, choking hazards and anything children may unexpectedly reach or access.
Official WA guidance:
ECRU – Compliance Bulletins
https://www.wa.gov.au/organisation/department-of-communities/education-and-care-regulatory-unit-compliance-bulletins
ECRU – Other Resources, including Burns Prevention Factsheet
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
8. Medication and Medical Conditions
Medication is another area highlighted by ECRU enforcement activity in 2026, including an August matter involving an incorrect medication dosage. Don’t wait until medication needs to be administered to discover that your system has weaknesses. Check the right child, right medication, right dose, right time, authorisation, expiry, storage and documentation. Educators should also understand the child’s medical management plan, risk-minimisation plan and communication arrangements where applicable. A useful mock-compliance question is: “Show me exactly what you would do if you had to administer this child’s medication right now.” That often tells you considerably more than simply checking whether a medication policy exists.
Official guidance:
ACECQA – Quality Area 2: Children’s Health and Safety
https://www.acecqa.gov.au/quality-area-2-childrens-health-and-safety-1
9. Ratios Are Important – But Look at Deployment Too
Services must meet educator-to-child ratio requirements, but adequate supervision involves more than achieving the correct number on paper. Consider where educators actually are. If educators are concentrated in one part of the environment while children are spread across several areas, the service may technically have the required number of educators but still have a supervision problem. Review rosters against actual educator deployment, particularly during breaks, opening and closing periods, transitions, toileting, sleep/rest and mixed indoor/outdoor play.
Official guidance:
ACECQA – Educator-to-Child Ratios
https://www.acecqa.gov.au/nqf/educator-to-child-ratios
10. Responsible Person and Person in Day-to-Day Charge
Services should be able to demonstrate clearly who the Responsible Person is at any point during operating hours. For a person placed in day-to-day charge, don’t rely solely on a signed form. Check that the required suitability considerations have actually occurred and that supporting evidence is available. Also check that Responsible Person records accurately reflect who was in charge.
Official guidance:
ACECQA – Staffing Arrangements and Responsible Person Requirements
https://www.acecqa.gov.au/national-quality-framework/guide-nqf/section-4-operational-requirements/quality-area-4-staffing-arrangements
WA forms and sample documentation:
ECRU – Other Resources
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
This ECRU page includes sample documentation for Responsible Person delegation and consent and working directly with children records.
11. Qualifications and Staffing Records
Check that qualification evidence is complete and current and that the people being counted toward qualification requirements can legally be counted. This includes reviewing Certificate III and Diploma requirements, ECT requirements, first aid qualifications and educators recorded as actively working towards a qualification.
Official guidance:
ACECQA – Qualification Requirements
https://www.acecqa.gov.au/qualifications-0/qualification-requirements
ACECQA – Centre-Based Qualification Requirements
https://www.acecqa.gov.au/qualifications-0/qualification-requirements/qualifications-centre-based-services-children-preschool-age-or-under
12. Working With Children Checks and Staff Suitability
ECRU’s Compliance and Enforcement Framework specifically identifies the unauthorised presence or employment of people without appropriate clearances among matters warranting regulatory attention. Services should have systems that identify upcoming expiries rather than discovering them after a card has expired. Remember to consider not only educators but also relevant volunteers, students and other people attending the service.
Current WA information:
WA Government – Working with Children Check
https://www.wa.gov.au/service/community-services/community-support/working-children-check
13. Records – Could You Produce Them During an Unannounced Visit?
An excellent compliance test is very simple: If an ECRU Authorised Officer asked for the record right now, could you find it quickly and would it be complete? Review attendance records, staffing records, Responsible Person records, medication documentation, incident records, enrolment information, excursion/transport records and other prescribed records. Cross-check records against each other. A roster, sign-in sheet and working-directly-with-children record should tell a consistent story.
ECRU checklists, required-document list and sample records:
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
This is one of the most valuable links for WA services because it contains ECRU’s current LDC and OSHC Compliance Monitoring Checklists and Documents Required for Compliance Monitoring.
14. Notifications – Would Management Recognise a Notifiable Event?
Sometimes the original incident is only part of the compliance problem. A second problem can arise when a service fails to recognise that the incident, complaint or allegation needed to be notified to the Regulatory Authority. Approved Providers and Nominated Supervisors should know what needs notification, who is responsible for doing it and the applicable timeframe.
Official guidance:
ACECQA – Notification Types and Timeframes
https://www.acecqa.gov.au/resources/applications/notification-types-and-timeframes
15. Sleep and Rest
Sleep and rest remains an important child-safety area, particularly for babies and younger children. Check the service’s sleep and rest risk assessment, physical environment, educator positioning, monitoring practices, individual children’s needs and whether the written policy reflects what actually happens. ACECQA’s current guidance emphasises risk assessment, adequate supervision and monitoring, individual children’s needs and keeping sleep/rest policies current.
Official guidance:
ACECQA – Sleep and Rest Legislative Requirements
https://www.acecqa.gov.au/resources/supporting-materials/infosheet/safe-sleep-and-rest-practices
16. Digital Devices, Images and Online Environments
Digital safety is an increasingly important compliance area. WA already introduced requirements from 1 September 2025 relating to policies and procedures for digital technologies and online environments. Further national child-safety reforms have been introduced nationally, but services need to be careful about commencement dates in Western Australia.
As at 18 August 2026, ECRU advised that the more recent December 2025/February 2026 child-safety amendments had not yet commenced in WA, although WA services were being encouraged to prepare for them.
This is an excellent example of why services need to follow WA-specific ECRU updates, rather than assuming every national announcement immediately applies in WA.
Current WA legislative updates:
https://www.wa.gov.au/organisation/department-of-communities/education-and-care-regulatory-unit-latest-updates-and-changes-legislation
ACECQA digital-device resources:
https://www.acecqa.gov.au/resources/resource-finder
The Biggest Compliance Question: Does Your Practice Match Your Policy?
One theme runs through almost every area above. A service can have beautifully written policies and still have a compliance problem. An Authorised Officer can observe what is happening, speak with educators, inspect records and compare actual practice with the service’s policies and procedures. If the supervision plan says educators position themselves across the playground but everyone regularly gathers together, there is a gap. If the medication procedure requires checking but educators cannot explain the process, there is a gap. If the transition procedure requires children to be reconciled but staff simply count heads, there may be a gap. Compliance must live in practice—not just in the policy folder.
Where Has BEST Identified These Priorities From?
The BEST 2026 ECRU Spot Check Risk Watch List is not an official ECRU list of inspection targets. BEST has developed the watch list by reviewing publicly available information from the Western Australian Education and Care Regulatory Unit and ACECQA, including:
ECRU’s Compliance and Enforcement Framework; 2026 Sector Updates and enforcement learnings; Compliance Bulletins; current Compliance Monitoring Checklists; Documents Required for Compliance Monitoring; forms and templates; legislative updates; and current ACECQA child-safety and supervision guidance.
ECRU’s Compliance and Enforcement Framework explains that routine monitoring includes annual visits and spot checks and that ECRU undertakes targeted inspections of services considered high risk.
ECRU also specifically describes its Sector Updates as providing learnings from enforcement actions and recent sector trends.
That means recent enforcement activity is valuable information for every Approved Provider, Nominated Supervisor and service leader—not merely the service involved.
Keep these pages bookmarked:
ECRU – 2026 Sector Updates
https://www.wa.gov.au/organisation/department-of-communities/education-and-care-regulatory-unit-sector-updates
ECRU – Compliance Bulletins
https://www.wa.gov.au/organisation/department-of-communities/education-and-care-regulatory-unit-compliance-bulletins
ECRU – Compliance Checklists, Templates and Other Resources
https://www.wa.gov.au/government/document-collections/education-and-care-regulatory-unit-other-resources
ECRU – Compliance and Enforcement Framework
https://www.wa.gov.au/government/publications/education-and-care-compliance-enforcement-framework
ECRU – Latest Legislative Changes
https://www.wa.gov.au/organisation/department-of-communities/education-and-care-regulatory-unit-latest-updates-and-changes-legislation
Would Your Service Be Ready If ECRU Walked In Tomorrow?
Sometimes it takes an independent set of eyes to identify risks that have gradually become part of everyday practice.
BEST Childcare Consulting offers Mock ECRU Compliance Visits for Western Australian education and care services.
Our approach is not simply to walk through a checklist. We look at your service from a regulatory, operational and practical perspective, including current ECRU compliance trends and areas of emerging risk.
A BEST mock visit can examine supervision and educator positioning, ratios and deployment, transitions, sleep and rest, medication, Responsible Person arrangements, staffing records, qualifications, attendance and required records, physical environments, gates and security, excursions, transportation, policies and procedures, and whether your documented systems match what is actually happening in practice.
Where concerns are identified, BEST can help the service understand:
What is wrong?
Why does it matter?
What requirement or guidance applies?
What needs to change?
Where can we find the official information or template?
How do we demonstrate that the issue has genuinely been rectified?
The aim is not simply to find non-compliance. The aim is to help services identify vulnerabilities before they become incidents, complaints, enforcement matters or findings during an ECRU visit.
Contact us TODAY.
Jen 0410 438 040
This article provides general information for Western Australian education and care services and should not be treated as legal advice. Regulatory requirements and guidance can change. Services should confirm current requirements through ECRU, ACECQA and the applicable WA legislation.
