Today’s correspondent was:
… at AFAC 2026 and one of the exhibitors (training suppliers) presented to me an argument that (for SES) training should be part of the National Training Framework (ie training.gov.au) not locally developed in the state by local SES. He argued there was a (possible legal) risk for the training organisation in training outside of the national Framework.
Is this real?
It’s hard to address this without knowing what the person had in mind. Personally I cannot see a risk.
National training is, in infer, training listed on the National Training Register (https://training.gov.au/). The advantage of providing nationally recognised training is that you can sell it to your staff and volunteers as a useful reason to join – they can take their training elsewhere including the workplace. If they have a qualification or statement of attainment issued by a Registered Training Organisation (RTO) then that should be recognised by all. For example, if you are going for a job that requires a first aid certificate and you can show you have a first aid certificate from an RTO then that should be good enough even if your employer normally sends their staff to another RTO to get that qualification.
Training that is listed on register and delivered by an RTO is meant to meet the standards set out in the National Vocational Education and Training Regulator Act 2011 (Cth) and supporting policies – see https://training.gov.au/resources.
That does not mean, however, that the training is necessarily better than training developed and offered by an organisation ‘in house’. It may be; it may not. If an organisation like the SES has developed its own training program to suit its own needs then so be it.
One can understand why the SES may not want to use Nationally Accredited Training. The training programs may not suit their needs. They may not want to put their own training program through the process of getting accredited as it is time consuming and complex. And then other RTOs may deliver the training diluting the author’s own intellectual property and, in this case, the SES’s ability to ensure the quality control that they want to impose.
The Work Health and Safety Regulation 2025 (NSW) r 39(2) (and I take NSW as the example but remember all states other than Victoria have adopted the model WHS Act and regulations) says:
The person [conducting a business or undertaking] must ensure that information, training and instruction given to a worker is suitable and adequate having regard to–
(a) the nature of the work carried out by the worker, and
(b) the nature of the risks associated with the work at the time the information, training or instruction is given, and
(c) the control measures implemented.
That doesn’t mean the training has to be a nationally registered package. Workplaces can deliver their own training and may need to in order to address their particular circumstances and work practices.
If a person, say an SES volunteer, does a job badly and something goes wrong, the question will be what did they do and was that a reasonable thing to do. Issues may arise as to whether their training was appropriate and did they do what they were trained to do but whether the training was ‘nationally accredited’ or not won’t answer those questions. As noted the accredited training package may not suit the needs of the SES in which case it may not have been adequate training. And regardless of what training the member undertook, there is no guarantee that they will act in accordance with their training.
Conclusion
I have no idea what risk the ‘exhibitor’ was thinking about, but I cannot see any. The risk to be addressed is whether people are getting appropriate training for the task at hand. There is nothing that says that training must be in the form of a nationally accredited package.
This blog is a general discussion of legal principles only. It is not legal advice. Do not rely on the information here to make decisions regarding your legal position or to make decisions that affect your legal rights or responsibilities. For advice on your particular circumstances always consult an admitted legal practitioner in your state or territory.
Australian Emergency Law 
NSW SES is an RTO (90656 NSW State Emergency Service). It would seem the information provided to the person was incorrect. Like any other business, there will be VET and non-VET training. The decision on which is determined through a training needs analysis. This document forms the justification for the type and level of training and or recertification training required.
I think it is worth noting that paramedics and other first responders within ambulance services often don’t receive nationally accredited training.
First Responders might receive national training such as first aid certificates but many of the other requirements of those roles don’t fit into a nationally accredited course.
Paramedics complete a degree program or other qualification that AHPRA accepts as sufficient to hold registration as a paramedic, however almost every aspect of a paramedic’s training once employed is unaccredited. Graduate/Intern programs aren’t accredited, and while most of the training contains transferable skills, there is nothing that requires another ambulance service or health service to accept that training as sufficient and they may still retrain them.
An example of this is someone transferring from one statutory ambulance service to another even as a qualified paramedic may have to complete the exact same induction program as a graduate paramedic to ensure that the transferring paramedic knows the way that their new service does things.
Further to this Paramedics as part of their professional registration have to complete their own continuing professional development (CPD), some their service may provide but other portions of it they source themselves. The paramedics themselves have to declare each year to the national regulator that they have completed the required CPD hours that is relevant to their practice because not all paramedics will have the same CPD needs.
A paramedic could go to a RTO and request they receive recognition of prior learning (RPL) because of their work. For example they could request recognition for Provide First Aid, Provide Advanced First Aid, Provide Advanced Resuscitation, Management of Asthma and Anaphylaxis as well as several other first aid certifications/qualifications but there is nothing that requires their employer to provide those nationally accredited qualifications to then (although some services are RTOs and may do that).
Michael, you’ve again brought clarity to speculative issues in our sector—thank you.
Your analysis aligns perfectly with the actual position of the NSW State Rescue Board. The SRB does not mandate that agencies use nationally recognised units of competency. It sets the training standards, but leaves it to individual agencies to determine how they meet them. As the SRB Annual Report makes clear:
This means agencies can—and should—use training pathways that best suit their operational context and risk profile, whether that includes units of competency or not.
As the former Director of Training for CFA, I witnessed firsthand how dysfunctional the national units of competency system has become. They were meant to build a safer, more mobile workforce, but instead created barriers that eroded capability. The promise of “nationally recognised” training proved to be a misnomer—our volunteers holding competencies we awarded were regularly told, “Yes, you have the unit of competency, but you haven’t done our course,” when moving between agencies or states.
The units of competency have become an expensive exercise in compliance, not common sense. Brigades are unable to build response capability when their agency mandates these units but they lack access to trainers holding the over-rated Certificate IV TAE. With the TAE costing around $5,000 per person, the maths is stark: if an organisation loses 100 trainers a year because they’re fed up with the constant bureaucracy of TAE compliance and upgrades, that’s $500,000 wasted—money that could have been spent on actual capability building.
It’s a mockery that anyone holding a unit of competency can be an assessor for it simply by holding the TAE. This highlights the risk of a certification product that appears compliant on the surface but is smoke and mirrors at the back end. I’ve met countless people holding PUASAR002 (swiftwater rescue) who just attended a two- or three-day course—instant heroes with minimal experience. The units of competency don’t require demonstrated experience and have little more credibility than any “CTRL+P certificate.” We all know examples where people were awarded units of competency they didn’t even attend—because the system focuses on compliance (documentation with ticks and signatures) rather than genuine competence.
The Australian VET sector is beyond crisis—it’s now a disaster, with millions of dollars going into resuscitating a dead horse. Imagine if we gave agencies back more autonomy to redirect this wastage of government funds toward making training impactful and fit-for-purpose again, supplemented with robust assessment that has evidence available on demand and is passively reviewed.
This is exactly what modern platforms like IPSQA now enable—organisations can build credible, auditable credentialing systems that demonstrate actual competence without the compliance overhead and cost of the national framework. The technology exists to make training more rigorous, not less, while dramatically reducing costs and bureaucracy.
It’s time for our industry to stop thinking that units of competency are the be-all and end-all. As you’ve said, the real question is whether people are getting appropriate training for the task at hand. Let’s focus on outcomes, not paperwork.