Queensland’s Reportable Conduct Scheme: What organisations need to do now

Organisations across Queensland are facing a material shift in expectations around how allegations involving children are identified, reported and investigated, with the introduction of the state’s Reportable Conduct Scheme from 1 July 2026.

The scheme will apply to a broad range of organisations, including government agencies, education and health providers, disability services, early childhood operators, residential services, and religious bodies. Its introduction significantly raises the bar for governance, accountability, and investigative rigour in matters involving child abuse or misconduct by staff and volunteers.

A step change in accountability for leadership

The Reportable Conduct Scheme represents a fundamental change in how organisations are expected to manage allegations involving children. Accountability will sit squarely with senior leadership, including CEOs, who will be responsible for ensuring matters are appropriately escalated, investigated, and documented.

This is not limited to a reporting obligation, the framework requires allegations to be managed through a structured, defensible investigation process, with outcomes that can withstand regulatory scrutiny. For many organisations, this will require a reassessment of existing governance arrangements, decision‑making pathways and assurance mechanisms.

Tight timeframes and heightened regulatory scrutiny

Under the scheme, organisations must notify the Queensland Family and Child Commission within three business days of becoming aware of a reportable allegation. This compressed timeframe places pressure on existing incident response processes and requires clear internal escalation protocols.

In parallel, organisations are expected to undertake formal investigations that are timely, consistent and well documented. Regulators will expect to see evidence that allegations have been assessed independently, conflicts have been managed, and outcomes are supported by appropriate reasoning and records.

More than a policy update

Many organisations underestimate the scale of operational and cultural uplift required to comply with the new regime. Treating the scheme as a simple policy update risks leaving gaps in capability at the point they matter most.

The reforms fundamentally change:

• How allegations are received and triaged
• Who is accountable for decisions and outcomes
• The level of independence and objectivity expected in investigations
• The degree of transparency required with regulators.

Without careful preparation, organisations may find themselves exposed to regulatory, legal and reputational risk.

The critical role of independent forensic investigations

As part of Queensland’s broader Child Safe Organisations reforms, the scheme is designed to promote consistent and transparent responses to allegations of harm, including neglect, ill‑treatment, and sexual or physical abuse.

Independent forensic investigation capability will be critical, particularly where matters are complex, sensitive or involve senior personnel. Specialist expertise helps ensure investigations are proportionate, defensible and aligned to regulatory expectations, while also supporting fair outcomes for all parties involved.

Getting the response wrong can have significant consequences for an organisation, including enforcement action, loss of stakeholder trust and long‑term reputational damage.

Preparing ahead of 1 July 2026

With the commencement date fast approaching, organisations should be acting now to assess their readiness for the Reportable Conduct Scheme. Key focus areas include:

• Strengthening incident escalation and reporting pathways
• Reviewing and uplifting investigation frameworks and procedures
• Clarifying accountabilities across leadership and governance structures
• Providing targeted training for leaders and key decision‑makers.

Early preparation will place organisations in a far stronger position to respond appropriately, meet regulatory expectations and maintain trust with children, families, staff and the broader community.

How BDO can help

Our forensic services team can help organisations assess their readiness, uplift governance and investigation frameworks, and design clear escalation and reporting processes aligned to regulatory expectations. Where incidents arise, we provide independent forensic investigation support to help ensure matters are managed objectively, proportionately and defensibly. Contact us to learn more about how we can support your business.