This Fact Sheet provides information on Outcome Standards 2.7, 2.8, 4.4 and Compliance Requirement 17 Third party arrangements in relation to RTO Feedback, Complaints and Appeals
RTOs must implement transparent feedback, complaints and appeals policies that enable students and clients to be informed of their rights and the RTO’s responsibilities under the 2025 Standards. Any complaint or appeal is required to be recorded, acknowledged and dealt with fairly, efficiently and effectively (Outcome Standards 2.7 and 2.8).
This Fact Sheet considers feedback, complaint and appeal processes and suggests strategies for RTOs to implement which may assist in reducing the likelihood of complaints and appeals.
RTO Feedback, Complaints and Appeals Explained
Feedback is information about reactions to a product (e.g., training materials, assessment process, facilities), a person's performance or behaviour (e.g., trainers, staff, another student), or other matters used for continuous improvement. Feedback can be positive or negative.
Complaints are allegations made by a student or client regarding the conduct of an RTO, its staff, a third party offering services on its behalf, or other students in the RTO.
Appeals are requests for a review or reconsideration of decisions made by the RTO. These decisions could involve assessments or access to support services.
The principles of natural justice and procedural fairness must apply in each situation.
Common misunderstandings, challenges, risks and compliance issues
It can be uncomfortable for an individual to raise a complaint or appeal or for an RTO to hear or be advised of allegations of unfair decisions. For this reason, sometimes complaint and appeal policies and procedures can be complicated, confusing, drawn out, or not impartial. Procedures like this may deny the individual's right to be heard or prevent reviewers from accessing the relevant evidence.
Therefore, it is crucial that an RTO’s complaint and appeal policies and procedures are easily accessible and understood so that individuals’ training and assessment experience is fair, and the RTO can use the process as an opportunity for review and continuous improvement.
Suggestions for good practice
Implementing good practice ensures that concerns or complaints are addressed transparently, equitably, and in a timely manner, fostering trust between students, staff, and stakeholders. The following diagram identifies five stages in complaints or appeals management RTOs could implement to improve their practice.
1. Prevention
RTOs are encouraged to seek and readily receive feedback from students and stakeholders as part of their continuous improvement processes to enhance organisational learning and accountability. A well-implemented feedback and continuous improvement culture should significantly reduce the likelihood of a formal complaint or appeal
The best remedy for complaints and appeals is prevention, which relies on clearly defined standards and expectations. To help prevent behaviour that might be the basis for a complaint, the RTO would benefit from publishing a clear and comprehensive code of conduct that is followed and applied by all parties including RTO staff and students.
In appeals, the basis of decisions needs to be clearly defined (e.g., by flow charts or guidance) and adhered to. In appeals of assessment decisions, there needs to be a clear relationship between the competencies to be demonstrated, the assessment evidence (the Rules of Evidence), and the assessment judgement (the Principles of Assessment). Where a student is confident that a decision is fair because they understand and accept the basis of the decision, an appeal becomes less likely.
2. Early Intervention
Early intervention is the next best remedy for negative feedback, appeals, and complaints. Potential appellants and complainants should be encouraged to seek resolution directly with the other party. These conversations can be challenging, so it is useful to have access to a clear and comprehensive guide on having challenging conversations, provided by the RTO.
In many cases, the problem can be quickly resolved to the satisfaction of both parties before the formal complaints and appeals process is invoked.
3. Formal Process
In the event that an informal process is unsuccessful, then the publicly available, formal process needs to commence. This process needs to be accessible and prompt and must reflect the principles of natural justice and procedural fairness. In particular, the procedure should ensure that:
- there are no barriers to an individual lodging an appeal or complaint (e.g. overly complex forms) (Outcome Standards 2.7b & 2.8b);
- the individuals have full access to the relevant evidence;
- all parties involved have the opportunity to be personally heard;
- the situation is reviewed by an impartial person who was not involved in the original issue;
- the review is evidence-based, defensible and transparent;
- the complaint or appeal is resolved within a reasonable timeframe (Outcome Standards 2.7a,(iii) & 2.8a,(iii); and
- provides avenues for further action where the situation cannot be resolved (Outcome Standards 2.7a(iv), 2.8a(iv).
There is no set complaints or appeals process for an RTO to follow, but RTOs must have a policy that is known to its students and clients that complies with Outcome Standards 2.7 and 2.8. The process should ensure that:
- complaints and appeals are acknowledged in writing;
- appeals and complaints are resolved in reasonable timeframes (Outcome Standards 2.7a(iii) & 2.8a(iii)); and
- the progress of the complaint or appeal is regularly reported to all involved parties, ensuring transparency (Outcome Standards 2.7d & 2.8c).
In general, complaints should be pursued through the RTO and its complaints and appeals process before making a complaint to TAC.
4. Third Party Review
It is important that the RTO’s formal process allows for:
- the complainant or appellant to request a review by a party independent of the RTO should the processes fail to resolve the issue (Outcome Standard 2.8 a(iv))
- a third party review needs to be provided to the complainant or appellant when requested at no or low cost. (Outcome Standard 2.8 a(iv))
- the RTO ensures those services are the subject of a written agreement and comply with Outcome Standards 2.7 & 2.8; and
Where a complaint is not resolved, the complainant is advised of their right to lodge their complaint with the TAC. While TAC does not review appeals as an independent party, if the appellant believes that the RTO did not meet the requirements of the Outcome Standards during the appeal process, they can lodge a complaint. Please view the TAC website for more information on the TAC complaints process.
5. Accountability and Learning
The RTO must securely maintain evidence of all complaints, appeals, and their outcomes, as required by Outcome Standards 2.7d and 2.8c. Additionally, RTOs are required to integrate feedback, complaints, and appeals outcomes into their continuous improvement strategies, fostering a learning culture (Outcome Standard 4.4). This approach helps RTOs identify the root causes of complaints and appeals. and take proactive steps to minimise the likelihood of recurrence (Outcome Standards 2.7e and 2.8d).
Complaints and appeals may indicate that the RTO needs to review its policies, procedures, and practices. This process should contribute constructively to the RTO’s continuous improvement process.
This also applies to all services a third party provides (Compliance Requirement 17 - Third-Party Arrangements).
