Chapter 2Safety in childcare
2.1As outlined in Chapter One, recent incidents and investigations involving early childhood education and care (ECEC) services have raised serious concerns about the safety of children and shaken public confidence in the sector.
2.2Evidence to the inquiry indicated that these cases cannot be viewed solely as failures within individual services. Concerning behaviour by adults who seek access to children may emerge and escalate before a person enters an ECEC setting, making it necessary to understand how the broader system identifies and responds to these risks.
2.3This chapter therefore begins by considering the broader child safety context and role of law enforcement in identifying and responding to child exploitation. It then examines how safety in the ECEC sector is monitored, including national compliance data and regulatory indicators. The chapter then outlines the key practical safeguards that operate together to keep children safe in ECEC, including workforce screening and reporting mechanisms, supervision practices and technological measures. It concludes by examining additional safety considerations for children with additional needs in ECEC settings.
The broader child safety environment
2.4The committee heard that law enforcement agencies are dealing with a growing volume of child sexual exploitation, particularly online. Mr Ian McCartney, Deputy Commissioner of the Australian Federal Police (AFP), told the committee that online child sexual exploitation ‘is not getting better; it’s getting worse’. He explained the need for communities to be informed about the reality of the threat to children, stating ‘if it used to take a village to raise a child, because of advances in technology, it now takes a country to keep them safe’.
2.5Ms Helen Schneider, also of the AFP, explained that AFP involvement in ECEC‑related offending typically begins when investigators identify child abuse material online and trace activity back to individuals in Australia. She noted that such investigations can reveal that individuals involved in offending work in roles that provide access to children.
2.6However, Ms Schneider emphasised that reactive investigations alone cannot provide an adequate safeguard for children. She told the committee that law enforcement 'can’t keep playing whack‑a‑mole with the numbers that we’re receiving' and stressed the need for 'targeted and deliberate prevention' measures that directly counter 'specific methodologies offenders are using'.
2.7The committee heard evidence that some individuals who sexually offend against children deliberately seek employment in child‑focused roles in order to facilitate access and grooming.
2.8Professor Michael Salter of the Childlight East Asia and Pacific Hub told the committee that individuals who sexually offend against children may pursue employment that provides opportunities for access and grooming. Similarly, Professor John Rouse told the committee that child sex offenders will 'always gravitate towards employment that provides them with access to children'.
2.9In their submission, the Childlight East Asia and Pacific Hub cited research from a national survey that found that of almost 2,000 Australian men, 9.4 per cent admitted to some form of sexual offence against a child, including 3.2 per cent who reported sexual contact with a minor while they were over the age of 18. These individuals were more likely to minimise or justify sexual abuse, while concealing their online activities through encrypted platforms and the dark web. Further, offenders who present a 'superficially prosocial façade' are unlikely to be detected abusing children for many years, if they are detected at all.
2.10While the committee heard that most contact sexual offending against children does not occur in childcare settings, witnesses emphasised that offending in these environments is particularly serious because of the young age and vulnerability of the children involved. Ms Schneider told the committee that contact offending ‘rarely is in childcare settings’, but when it occurs in these ‘high-harm settings’, it is ‘hugely confrontational, abhorrent and heinous’.
2.11The Childlight East Asia and Pacific Hub submitted that several recent high-profile cases involving offending in ECEC settings revealed significant failures in safeguarding and oversight. They argued that these cases involving ‘hundreds of victims and thousands of images’ demonstrate the need for stronger preventative measures to stop offenders from entering the sector and to ensure concerns about staff behaviour are escalated and investigated promptly.
2.12Ms Sarah Davies, the Chief Executive Officer of the Alannah and Madeline Foundation, emphasised that when considering the safety of children, it is ‘dangerous’ to categorise sectors of the industry by profit or not-for-profit. Ms Davies told the committee about small private providers whose intent, focus and motivation ‘is as professional and as ethical as any non-profit’.
National reporting and safety indicators
2.13The evidence outlined above highlights the seriousness of risks facing children more broadly. To understand safety within the ECEC sector, it is useful to examine the national data and regulatory indicators reported across the sector.
2.14Under the National Quality Framework (NQF), early childhood services must meet safety, quality and governance requirements. State and territory regulators assess and rate services against the National Quality Standard (NQS), which includes a quality standard for children’s health, wellbeing and safety.
2.15The Australian Children’s Education and Care Quality Authority (ACECQA) publishes national data each year on how the system is performing. It reports on all quality areas, but the three main types of information related to safety are:
quality ratings assigned through assessment and rating visits;
serious incident notifications, which providers are legally required to report when certain events occur (for example, a child is injured and requires medical treatment or hospital attendance); and,
confirmed breaches.
What the data shows
2.16ACECQA’s latest report from 2025 shows that ECEC services are consistently being rated highly against the quality ratings. Overall, 91 per cent of services with a published rating were assessed as Meeting NQS or above, and between 94 and 99 per cent met this benchmark across the individual quality areas. For children’s health and safety specifically, 95 per cent of services met or exceeded the standard—the highest since the NQF began.
2.17However, the number of serious incidents reported to regulators has been increasing. In 2024–25, services reported 160 serious incidents per 100 approved services, up from 148 in 2023–24 and 139 in 2022–23. Most serious incidents relate to injuries, trauma or illness affecting a child (77.7 per cent of all serious incidents), followed by incidents where emergency services were sought or ought reasonably to have been sought (11.5 per cent).
2.18ACECQA also reported more confirmed breaches. The rate rose from 201 per 100 approved services in 2023–24 to 222 in 2024–25. These breaches cover a wide range of issues, but the most common categories were: protection from harm and hazards; supervision; emergency and evacuation procedures; and upkeep of premises and equipment.
What the data does not show
2.19Evidence to the committee raised concerns about the limitations of the data reported on by ACECQA.
2.20The Front Project pointed to a disconnect between improving ratings and rising incident reporting, stating:
The paradox is clear: overall ratings are improving steadily and are at their highest point since the NQF began, yet serious incidents are rising, and systemic weaknesses remain in supervision, health practices, and emergency preparedness. This signals growing systemic challenges that may not be captured in high-level quality ratings alone.
2.21Without more frequent and comprehensive monitoring, the Front Project argued that ‘policymakers and families alike cannot be confident that everyday practices consistently meet the standard of safety that children deserve’.
2.22Similarly, the Parenthood submitted that despite improvements in overall ratings, gaps remain in some safety-critical practices. They drew attention to the fact that supervision requirements were not met in 3.4 per cent of services, health practices in 3.2 per cent, and incident management procedures in 2.0 per cent of services.
2.23Social Ventures Australia argued that the quality ratings are ‘not a perfect measure’, noting that lengthy periods between assessments mean the system may not capture changes in safety practice that occur between assessment and rating visits.
2.24A recent report published by the Queensland Family and Child Commission, In Plain Sight, highlighted the limits in using quality ratings to assess safety. In a specific case concerning a convicted child sex abuser, it found that 74 per cent of the centres the offender worked in were rated as Exceeding or Meeting the National Quality Standards.
2.25In response, ACECQA’s Chief Executive Officer, Mrs Gabrielle Sinclair, emphasised that ratings represent only a snapshot in time. She explained that:
Given the fact that an assessment and rating is a point in time, we don’t know whether the assessment and rating happened while he was there. But the assessment and rating is just one point of information. Because he moved very quickly, we would imagine that he didn’t stay in a service—and the report does point to the fact that, in really good services that had that really strong culture of every child is safe and there are four eyes on every child, he didn’t offend at all.
2.26While these explanations are relevant, the evidence received by the committee suggests that an over-reliance on quality ratings risks obscuring the lived experience of families and the practical realities within services. Submitters emphasised that compliance with the National Quality Standard, while important, does not necessarily reflect whether children are consistently safe in day-to-day practice. In particular, evidence highlighted that staffing ratios can be technically met while still resulting in inadequate supervision, especially where educators are not actively positioned or engaged in a way that mitigates risk. This disconnect between regulatory compliance and operational reality raises questions about whether the current framework is sufficiently focused on outcomes rather than inputs.
2.27Lady Gowrie QLD drew attention to the system’s reliance on providers to self-report incidents to regulators and said that some providers may under-report incidents ‘to avoid triggering regulatory intervention’.
2.28On the other hand, other submitters told the committee that increases in serious incident notifications or breaches should not automatically be interpreted as a decline in safety. Affinity Education Group pointed to findings from the Productivity Commission indicating that data can be influenced by factors unrelated to poor safety performance. They explained:
Higher rates of reported breaches or serious incidents can reflect improved reporting practices, more proactive regulatory oversight, or the increased size and complexity of services, rather than a decline in standards. For example, services rated as Exceeding the National Quality Standard often report more serious incidents not due to lower quality, but because of stronger internal processes and a greater likelihood to report. Similarly, increased regulatory visits and broader definitions of breaches can inflate the data, making it an unreliable sole indicator of service quality.
2.29Guardian Childcare and Education made a similar point, drawing on research by the University of Sydney’s Erin Harper who said that higher‑quality providers can show higher incident reporting because ‘they have clearer processes, more experienced or qualified educators, or higher ratios of educators to children’. They submitted that, for these reasons, ‘regulators need to be careful not to judge operators based on the raw data’.
2.30Likewise, the Australian Childcare Alliance (ACA) noted that services supporting higher numbers of children with additional needs may ‘naturally record more incidents or receive more notifications’. They argued that public reporting can make such services appear higher risk, even though they may in fact be ‘doing critical inclusion work’.
2.31ACECQA itself noted in its annual report that ‘most reported serious incidents result in no formal compliance action being required by state or territory regulators’ and that higher reporting rates may reflect factors such as improved reporting practices, overly cautious reporting procedures, or particular service circumstances.
Safeguards in the ECEC system
2.32As discussed above, national reporting and quality ratings provide only a partial picture of safety within ECEC services. While these indicators offer insight into incidents and compliance, they do not capture the day-to-day safeguards operating within services to protect children. Evidence to the committee therefore examined the practical safeguards used within ECEC services to keep children safe. The main areas raised in evidence were:
workforce screening and reporting schemes;
supervision practices; and
technological safeguards.
2.33On 22 August 2025, federal, state and territory education ministers agreed to a package of reforms intended to strengthen safety across the sector, including:
implementing a national educator register;
mandatory national child safety training for all ECEC staff;
a nationwide assessment of closed-circuit television (CCTV) use in ECEC services;
banning or restricting the use of personal mobile phones or digital devices while working directly with children;
joint compliance and monitoring activities with states and territories to improve data exchange;
a rapid assessment of the operational application of educator-to-child ratios and practices;
more regular assessment and rating visits to ECEC services; and
other measures designed to improve transparency for parents.
2.34As these reforms were announced shortly before the inquiry commenced, most submitters did not comment on them in detail. Evidence therefore focused primarily on the safeguards as they currently operate within ECEC services and the areas where stakeholders considered improvements are needed, with proposed reforms noted where relevant.
Workforce safeguards
2.35Evidence to the inquiry focused on three main workforce safeguards: the proposed national educator register, Working With Children Checks (WWCCs), and reportable conduct schemes.
National educator register
2.36As part of the August 2025 reforms, education ministers agreed to establish a national educator register to ‘give regulators clear visibility of who is working in the sector and where’. The register was designed by ACECQA in partnership with all states and territories and will collect and maintain information about all staff working in ECEC, including their identity, training and qualifications, and WWCCs.
2.37Submitters welcomed the decision, but emphasised that the register’s effectiveness will depend significantly on its design. The Early Learning and Care Council of Australia put the underlying principle plainly, submitting that ‘the most powerful means of protecting children from “bad actors” in the workforce is to erect every possible obstacle to recruiting them’. Evidence before the committee reflected this view, and in particular, that the register must be structured to give employers, not only regulators, meaningful access to information at the point of hiring.
2.38The Australian Childcare Alliance (ACA) submitted that the register must give employers real-time verification of qualifications, WWCC status, employment history, and any record of misconduct or disciplinary action. The ACA noted that current employment decisions are constrained by reliance on resumes and self-reported information, reference checks limited by privacy and legislative barriers, and an assumption that WWCCs alone are sufficient to identify unsuitable workers. The ACA specifically flagged that current discussions include options involving a one-way flow of information from employers to regulators only, and submitted that this approach would do ‘nothing to empower employers to make wise recruiting decisions’.
2.39Y Australia supported a comprehensive register, submitting that it should include details of all educators, support staff and volunteers, with real-time updates including automatic alerts when a person is disqualified, investigated or sanctioned, integration with police, child protection and interstate databases, and strong privacy protections to ensure information is accurate and shared appropriately.
2.40Guardian Childcare and Education and the Early Learning and Care Council of Australia (ELACCA) both emphasised the importance of including risk‑related information on the register. Guardian submitted that the register should capture substantiated allegations of child harm or serious misconduct and allow employers to record when a person resigns while under investigation. ELACCA submitted that the register should contain sufficient detail to identify red flags or potentially risky behaviour, which may not have triggered formal investigative processes or findings.
Working With Children Checks (WWCCs)
2.41Working with Children Checks (WWCCs), also known as Working with Vulnerable People Checks in the ACT, are a key safeguard intended to prevent unsuitable individuals from undertaking child-related work. Individuals who work directly with children must hold a valid WWCC confirming they are suitable to undertake child-related work. The process to obtain a WWCC varies significantly between jurisdictions in relation to screening processes, eligibility thresholds and information‑sharing arrangements.
2.42Goodstart Early Learning described some differences in how WWCC arrangements operate across jurisdictions, for example that:
A clearance may only be reassessed or suspended after a person has been formally charged or a reportable conduct finding has been substantiated, allowing individuals under investigation to continue working with children;
Individual educators are responsible for linking their WWCC to their employer, meaning organisations may not be notified if a worker’s clearance status changes; and
Individuals may commence child-related work after lodging a WWCC application but before background screening has been completed.
2.43In a recent opinion piece, Mr Noel Macnamara, Director of the Centre for Excellence in Therapeutic Care at the Australian Childhood Foundation, discussed the implications of these jurisdictional differences. He described the current WWCC framework as fractured ‘across eight separate state and territory schemes, each with its own laws, standards, and processes’, creating ‘gaps that allow offenders to slip between jurisdictions’. Mr Macnamara used recent cases to illustrate the consequences of these gaps:
Even more disturbing are the cases where individuals accused, or even charged, with serious sexual offences have continued to work with children while holding valid WWCCs. The recent case of Joshua Brown, charged with more than 70 sexual offences while employed in childcare, is only one example. Another is David Neil Tuck, who allegedly abused children while licensed. In many instances, mobility between states and employers is enabled by inconsistent standards and a lack of real-time alerts.
2.44The committee also heard about the practical difficulties current WWCC arrangements create for services and staff. Ms Jessica Baker of the Ngaanyatjarra Pitjantjatjara Yankunytjatjara Women’s Council explained that operating across the Northern Territory, South Australia and Western Australia involves navigating three different legislative schemes, which can be a barrier for Anangu educators who move regularly between communities. Ms Baker said that obtaining multiple checks and meeting differing requirements can delay employment and disrupt continuity of care, and expressed support for a single federal WWCC to reduce these barriers.
2.45Other submitters also called for a nationally consistent approach to screening individuals who work with children.
2.46As noted, governments have recently agreed to reforms aimed at strengthening national coordination. These include mutual recognition of refusals and cancellations, which would prevent a person denied a WWCC in one jurisdiction from holding one in another, as well as improved assessment frameworks and better information‑sharing between authorities.
2.47However, some stakeholders argued that reform needs to go further. Submitters proposed a number of reforms to strengthen WWCCs, including:
Lowering the threshold for revoking or suspending a WWCC, so that substantiated allegations of child harm or regulatory findings automatically trigger revocation or are formally recorded on a person’s clearance;
Integrating WWCCs with reportable conduct schemes, with both functions administered by the same authority to ensure early identification of concerning behaviour and a more coordinated response to risk;
Embedding mandatory child‑abuse prevention training into the WWCC process, ensuring all card holders are trained and assessed in foundational knowledge on preventing and responding to child sexual abuse; and
Using artificial intelligence to support WWCC screening, including analysing an applicant’s online presence to identify concerning behaviour that may not otherwise be detected.
Reportable conduct
2.48Some evidence concerned the operation of reportable conduct schemes for ECEC. These schemes are legislated frameworks requiring institutions that provide services to, or work with, children to report and investigate allegations or concerns about child-related misconduct by employees. Currently, all jurisdictions except for South Australia and the Northern Territory have operating reportable conduct schemes for ECEC.
2.49Busy Bees Early Learning submitted that the reportable conduct requirements across jurisdictions are inconsistent, with different thresholds for what constitutes a reportable allegation, different reporting bodies, and varying timeframes for notification. Busy Bees expressed that this creates confusion as staff become uncertain which jurisdictional standard applies, increases administration and does not result in a ‘corresponding uplift in child safety outcomes’.
2.50Ms Samantha Page of Early Childhood Australia told the committee these inconsistencies across jurisdictions mean the same concerning behaviour may or may not trigger a reportable conduct response. She explained that behaviours such as pushing professional boundaries, isolating a child, or ‘what would be considered grooming of the family relationships’ would meet the threshold of a reportable conduct scheme in some states, but not in others.
2.51Arguments about the benefits of a nationally consistent reportable conduct scheme are not new. The Australian Human Rights Commission noted that the Royal Commission into Institutional Responses to Child Sexual Abuse in 2015 considered reportable conduct schemes as a ‘best practice model for cross-sector oversight of institutional handling of employee related child protection matters’. The Royal Commission recommended that nationally consistent legislative schemes be established in each state and territory. Further, in October 2024, states and territories collectively recognised ‘the benefits of nationally consistent legislative reportable conduct schemes’.
2.52Busy Bees recommended establishing such a scheme with harmonised thresholds, processes and timeframes, arguing that this would reduce duplication and ‘support a common culture of safety’. Similarly, Knowmore recommended that the Australian Government should ‘lead work … to implement nationally consistent reportable conduct schemes, reflecting best practice standards’.
Supervision safeguards
2.53The committee heard consistently that supervision is one of the most important practical safeguards in early childhood education and care. For example, Dr Michael Salter said that ensuring line of sight on children at all times has been ‘critical in reducing opportunities for abuse’, especially when caring for very young children without the ability to speak yet.
2.54The Education and Care Services National Law and National Regulations require that all children being educated and cared for at an approved service are adequately supervised at all times and are protected from harm and hazards.
2.55Evidence to the committee suggested that current regulatory settings can allow services to comply with minimum staffing ratios while still exposing children to avoidable risks. Submitters described the use of ‘under the roof’ ratios, whereby educators are counted as present for compliance purposes but are not deployed in a way that ensures active supervision across all areas. This can result in ‘passive supervision’, where risks are observed but not proactively mitigated. Stakeholders argued that a shift toward dynamic, risk-based supervision, where educators are deliberately positioned and actively engaged, would better reflect the intent of the regulatory framework and improve safety outcomes.
2.56The National Regulations also prescribe the minimum number of educators required to educate and care for children, which vary based on children’s ages and the type of service. As noted, ACECQA has undertaken a rapid review of the educator-to-child ratio and practices that improve the safeguarding and supervision of children in ECEC services, which is discussed in detail in Chapter Three.
2.57Despite these requirements, submitters argued that minimum ratios do not always provide sufficient protection, particularly when an educator is working alone or caring for children with higher needs. The Independent Education Union of Australia said this is particularly the case when ‘a significant proportion of … children have medical, developmental and/or serious behavioural needs’.
2.58Concerns were also raised about the practical limitations of current ratios in outside‑school‑hours care. Mrs Margaret Harrison of the United Services Union described situations where a single educator may be responsible for up to fifteen children aged between four and twelve, many with additional needs, creating risks for children and considerable stress for staff.
2.59The United Services Union therefore called for an ‘urgent review’ of the ratios, arguing that they are ‘too high’ to ensure safety under current operating conditions.
2.60Submitters also identified particular moments of heightened risk. In some jurisdictions, services may operate at reduced ratios during sleep and rest periods, when educators often undertake administrative tasks. The Queensland Department of Education advised that reduced‑ratio provisions have recently been removed in Queensland, following findings that rest periods are a ‘risk time for children’ and that maintaining full ratios is ‘critical’ for safety.
2.61Many organisations also supported strengthened supervision in other high‑risk situations, such as toileting or intimate care. A commonly suggested measure was the ‘four‑eyes’ approach, under which two adults remain within line of sight of each other while supervising. Y Australia described this as ‘the single most effective reform’ to protect children in ECEC services.
2.62While supporting enhanced supervision, ELACCA cautioned that mandating a two‑adult or ‘four‑eyes’ requirement in all circumstances could worsen educator shortages and increase service costs.
Technological safeguards
2.63Some stakeholders also discussed technological safeguards that may support supervision in ECEC services. Most evidence focused on the use of CCTV in certain areas of a service, although a small number of submitters also briefly raised the potential role of mobile‑device restrictions and emerging tools such as AI.
Closed-circuit television (CCTV)
2.64The committee heard mixed views about the use of CCTV in ECEC settings. Some submitters supported the use of CCTV as part of broader safety measures. For example, Dr Michael Salter of the University of New South Wales told the committee that he supported the use of CCTV as ‘part of the safety equation’, particularly ‘where kids are sleeping and also in environments where children are being provided with intimate care’.
2.65Professor John Rouse said that using CCTV may reduce opportunities for misconduct or assist in identifying abuse after it occurs:
It’s one of a raft of tools that should be in place... [C]onsideration of the placement of CCTV in such a way that we are target-hardening against offenders’ behaviour … has to be considered … because, ultimately, it may be the only evidence we have sometimes to determine whether a child was physically abused.
2.66Despite their endorsement of CCTV, both Dr Salter and Professor Rouse held concerns about the privacy and data-security implications of using it. Professor Rouse said:
I think there are significant concerns around that from the privacy sector, because you wouldn’t just be viewing your child; you’d be viewing all the children, and the people during their working day. Where are those cameras placed? What are people able to see? How is that captured? Can parents also screen-capture and record this stream? Where does that end up? What’s their access, and how do they access? Knowing child sex offenders the way I do, they will be seeking access to these systems to watch children.
2.67Similarly, one submitter who worked in the Victorian Child Protection system said that CCTV can ‘foster a false sense of security’, shifting attention away from safety practices, staff conduct, and incident response. The submitter recommended that any use of CCTV in ECEC services be supported by clear protocols on how footage is viewed, training for staff, and proper communication with families. The submitter also encouraged that CCTV be accompanied by ‘quality assurance mechanisms such as unannounced site visits, regular staff appraisals, and transparent complaints procedures’.
2.68Mr Luke Twyford, Principal Commissioner of the Queensland Family and Child Commission, said that CCTV may suit some centres more than others, and that each centre needs to develop ‘its own specific plan’. He explained:
If you are in far western Queensland in a place like Longreach where you have two staff and an old, ageing facility—this is hypothetical, of course—and numbers that are not high enough to give you a profit to invest into a new building then maybe you should think about CCTV and how it fits into the plan and your staff supervision ratios, whereas if you’re a brand new east coast multimillion-dollar early childcare provider then your reliance on CCTV should be less, because you have better access to workers.
2.69Some large childcare providers told the committee that they had already implemented CCTV in some of their centres. For example, Affinity Education Group noted that it is currently fast-tracking the installation of CCTV across all its centres to ‘enhance supervision and safety’.
2.70However, other submitters were concerned about the use of CCTV in ECEC. For example, St Kilda & Balaclava Kindergarten submitted that CCTV should not be a substitute for quality care from workers:
Cameras cannot build secure relationships, comfort a child in distress, or notice the subtle early signs of emotional harm. Investing in workforce conditions—better pay, more training, improved ratios—is what truly keeps children safe.
2.71Lady Gowrie Queensland held a similar view, submitting that the best way to ensure child safety in ECEC settings is to have qualified and sufficient staff members with established relationships with children and parents. They argued that this approach ‘provides a more protective, responsive and diligent safeguarding approach for children’s safety and wellbeing’.
2.72Some submitters commented on the Australian Government’s recent commitment to undertake a national assessment of the use of CCTV in early childhood services, which will involve up to 300 ECEC services across Australia. Ms Samantha Page, Chief Executive Officer of Early Childhood Australia, told the committee that, while they had some concerns about it, they were ‘pleased’ CCTV was going to be ‘properly evaluated’. The NSW Advocate for Children and Young People said that children’s rights must be considered as part of the trial and that ‘strict privacy provisions must be put in place regarding both the review and storage of any footage’.
Safeguards for children with additional needs
2.73The committee heard that existing safeguards do not always reflect the needs of children who require additional support in ECEC settings. Evidence indicated that growing numbers of children attending services have severe allergies, type 1 diabetes and other medical conditions, and current arrangements are not always designed to manage the complexity of these needs.
Allergy management
2.74Evidence to the inquiry highlighted significant concern about allergy management in ECEC services. Submitters noted that allergic reactions in care are common, that many children experience their first food-related allergic reaction while attending ECEC, and that failures in prevention or recognition can have serious consequences.
2.75Allergy & Anaphylaxis Australia submitted that families ‘frequently report incidents’ where children were served food containing their known allergens or where early signs of a reaction were not recognised. It provided a specific example of a child who experienced two episodes of anaphylaxis in a single day while attending an ECEC service. According to the child’s mother, staff ‘did not recognise that he was having anaphylaxis’, and that adrenaline was not administered until she arrived to collect him. The child subsequently had a short stay in hospital.
2.76The National Allergy Council said such incidents cause significant distress for families, with some parents delaying enrolment or returning to work because they lack confidence that services can manage their child’s allergy safely.
2.77Submitters identified current training requirements as a major contributor to accidental allergen exposure. Under the National Regulations, only one staff member on duty must hold approved anaphylaxis management training, and there is no requirement for training in general allergy management.
2.78Some submitters raised concerns about these requirements. Allergy & Anaphylaxis Australia noted that the trained staff member may not be present when a reaction occurs, while Dr Peter Goss of the Australian Paediatric Society described the requirement as ‘grossly inadequate’ and having led to some ‘near disasters’.
2.79To address these issues, submitters commonly recommended that all educators be required to complete training in both anaphylaxis management and general allergen management.
2.80The National Allergy Council advised that its Best Practice Guidelines for Anaphylaxis Prevention and Management provide a nationally consistent, evidence‑based framework developed through consultation with key stakeholders, including ACECQA. It recommended that the guidelines be formally adopted and embedded across the sector. This proposal was strongly supported by other submitters.
2.81Other recommendations aimed at improving allergy and anaphylaxis management in ECEC services included:
Mandatory food‑allergen management training for all staff involved in ordering, storing, preparing, serving or supervising food, through the National Allergy Council’s All About Allergens for Children’s Education and Care program;
Improved post allergy‑incident reporting systems, recommended by the NSW Anaphylaxis Education Program; and
Annual communication and age‑appropriate education for children, families, volunteers and the broader community about food allergies and anaphylaxis.
Diabetes management
2.82Evidence to the inquiry indicated that supporting young children with type 1 diabetes (T1D) in ECEC services is highly challenging, with submitters stressing that the condition requires constant monitoring and rapid responses. One parent described T1D as ‘relentless, around the clock’, with even small errors carrying ‘life‑threatening consequences’.
2.83Families reported that many ECEC services struggle to meet this level of care. A 2025 survey by the National Type 1 Diabetes Council, Type 1 Foundation, Type 1 Voice and Team Diabetes found that 78 per cent of families had difficulties with their child’s participation, 81 per cent said their ability to work was affected, and 86 per cent had kept their child home due to concerns about safety and diabetes management.
2.84Type 1 Voice submitted that families are often ‘subjected to a choice between enduring a substandard system of care and safety for their child or withdrawing their child from these services’, noting that in some cases, services refuse to enrol children with T1D at all.
2.85Some parents of children with T1D provided individual submissions to the inquiry, describing the impact when services cannot meet their child’s needs. One parent submitted that after their three‑year‑old was diagnosed with T1D, they attempted to re‑enter him in childcare but ultimately withdrew him after seven months, saying his ‘life‑threatening, regular and time‑sensitive needs… far outweigh the capacity of any ECEC service that is unfunded and unsupported’.
2.86Submitters said ECEC services struggle to support children with T1D because educators are not trained or authorised to provide the level of medical care required. The National Type 1 Diabetes Council said that staff are ‘unqualified and untrained’ to perform the emergency response and complex care needed to keep young children with T1D safe. They noted this is because there is no accredited training pathway to equip educators for these tasks, and that legal restrictions around administering insulin further limit what staff can do.
2.87Submitters made a range of recommendations to address these issues, including:
Establishing an accredited workplace training program delivered by a Registered Training Organisation to qualify ECEC educators to support children with T1D;
Ensuring ECEC providers, staff and families receive clear advice regarding their roles and responsibilities under relevant legal and regulatory frameworks;
Introducing a transition period, during which the government would pause enforcement of the new requirements to give organisations time to complete the required training and comply;
Enabling state and territory governments to enact regulatory provisions that authorise educators with the requisite qualifications to administer insulin and carry out medical tasks;
Implementing the International Society for Pediatric and Adolescent Diabetes (ISPAD) Position Statement on Type 1 Diabetes in Schools, which submitters noted has been legally validated for use in Australia; and
Requiring services enrolling children with T1D or severe allergy to demonstrate staffing sufficiency with respect to relevant National Quality Standard requirements.