NDIS Mid-Term Audits Are Changing — Are You Ready for What’s Next?
- Anna Latifi
- Jul 8
- 3 min read
Preparing for an NDIS audit can feel overwhelming—especially if it's your first time. This guide breaks down what you need to know about mid-term audits, how to prepare confidently, and what the NDIS Commission now expects from providers in 2025.
What is a Mid-Term Audit?
Mid-term audits apply to providers in their first 3-year registration cycle. It’s a compliance check—not a full audit—focused on core modules relevant to your services. The goal? To ensure you’re still meeting NDIS Practice Standards before your next renewal.
This does not mean that you should wait until 3 months before your audit is due to engage an auditor, or begin preparations; on the contrary, always work on enhancing your systems, quality, and management.
With the NDIS Commission’s updated regulatory focus in 2025, including a more risk-based and outcomes-focused approach, it's crucial for providers to treat the mid-term audit as more than just a compliance tick-box. It's an opportunity to reflect, improve, and build credibility with both the Commission and participants. While not as intensive as your initial or renewal audit, it is a focused check on how well your organisation is continuing to meet the NDIS Practice Standards—especially in areas like:
Participant rights and dignity
Incident management and complaints
Worker screening and training
Risk management and service delivery
The Commission is paying closer attention to whether providers are genuinely embedding quality systems into everyday practice—not just holding policies on paper.
When to engage an auditor?: Begin communicating with your desired auditing body at least 5 months before your due date. This gives you and the auditors sufficient time to communicate with the auditors, prepare the requirements, and conduct it with less stress.
Aim for submission: Not everything can always be controlled, that is why I am to have my complete by latest 2.5-3 months before the due date. This gives the auditing body enough time to review, upload, and submit the report to the NDIS commission before your due date.
Complaint & Incident Handling: What the Commission Now Expects
As announced in the May 2025 newsletter, the NDIS Commission is shifting to a risk-based approach to managing complaints and reportable incidents. This means:
Low to moderate risk matters will increasingly be referred back to providers to resolve directly.
The Commission will focus regulatory resources on serious or systemic issues that pose risks to participant safety, wellbeing, or rights.
What this means for you
Your internal complaint handling process must be accessible, responsive, and well-documented.
Providers must actively support participants to understand how to make a complaint.
Every complaint or incident—even if resolved informally—contributes to the Commission’s view of your risk profile.
Complaints have surged from 7,800 in 2021–22 to over 29,000 by 2023–24. Providers must be ready to manage these effectively without relying solely on the Commission.
For your mid-term audit, ensure you can clearly show:
Your complaint and incident register is current
All matters are followed up appropriately
Learnings and improvements are documented
Now more than ever, your audit is about showing that your systems are:
Active
Aligned to standards
Responsive to participant needs
Common Evidence Gaps Seen in Mid-Term Audits
From our work with providers across Australia, here are common issues that can lead to non-conformities during mid-term audits:
Participant records lacking goals, consent, or clear service delivery evidence
Worker screening checks not up to date or missing for subcontractors
Complaints or incidents not documented or reviewed properly
Policies and procedures outdated, unreviewed, or not followed in practice
The Commission expects providers to not just own policies, but to demonstrate how they are embedded into service delivery and staff behaviour.
Best Practices for a Smooth Audit Process
Ensure you engage a Commission-approved auditor with enough lead time (don’t wait until month 17)
Keep your participant and staff files ready and updated regularly—not just before the audit
Conduct a simple internal audit or file review at least 7 months before the auditor arrives
Cross-check that your policies align with your practices
Keep a log of all continuous improvement activities—even small changes show active compliance
Introducing the NDIS Quality Roadmap
To help providers understand what “quality” looks like in practice, the Commission has released its Quality Roadmap. This framework supports the delivery of better outcomes through:
Empowered participants
A skilled and ethical workforce
Strong provider culture and accountability
Real collaboration and coordination in service delivery
The roadmap outlines the drivers of quality including:
Demand for innovation
Diverse and sustainable markets
Choice and control
Consumer voice
Need Support Preparing?
As an NDIS consultant working with providers across VIC, SA, NSW, and WA, I offer:
Pre-audit file reviews and compliance checks
Document and policy updates aligned with NDIS Standards
Internal audit reports to identify risks early
Staff training and file organisation tips to get your house in order before the auditor arrives
