Mandatory registration is coming, but don’t panic

Over the coming months, expect to hear a fair bit about mandatory registration of NDIS providers:

What’s happening?

Back in December 2025, the Department of Health, Disability and Aging released a short consultation paper about a new definition of NDIS provider. The paper is really about mandatory registration of providers, including for speech-language pathologists (SLPs) and other allied health providers. The consultation ends on 28 February 2026.

The big picture:

• It’s very likely that allied health NDIS providers will need to become registered providers. 
• But it’s not yet clear:
  • when this will happen; or 
  • what, exactly, registration will require of us in practice. 
• There are a few practical things we can do now to prepare. But, many of us have other urgent business and compliance priorities right now, and we shouldn’t over-react to future registration requirements until we know more details.

Context: 

• Most small allied health providers are unregistered because of the expense, time-commitment, and red tape involved in becoming and staying registered, including the costs of audit or verification processes.
• Large registered providers have long argued that this creates an uneven playing field, favouring unregistered providers.
• Disability advocates and small allied health providers have counter-argued that, forcing small providers to register under current rules, would cause many providers to exit the sector, reducing participant choice and control (and competition for the big providers).

Politically convenient:

The Government has won popular and media support for its NDIS and Thriving Kids reforms by:

• criticising the number of unregistered providers; 
• suggesting, fairly openly, that unregistered providers are a bunch of unregulated cowboys in a sector riddled with fraud, waste and poor safety; and
• not mentioning that many of the most egregious participant safety incidents to date, including participant deaths, and large fraud cases involve registered providers.

Case in point:

In his Thriving Kids Announcement of August 2025, Minister Butler said: 

“While there are currently more than 260,000 NDIS service providers, only 16,000 are registered….I’ll repeat that – 15 out of 16 providers are unregistered, leaving far too much scope for poor quality service, sharp practice, conflicts of interest and precious little oversight. That has to change.”

Reality check:

• Unregistered ≠ unregulated: Allied health NDIS providers are bound by the NDIS Code of Conduct and health laws. 
• SLPs in private practice are regulated as Certified Practising Speech Pathologists and are subject to SPA’s professional standards, Code of Ethics and complaints processes. (These mirror AHPRA rules that regulate other allied health professionals, like occupational therapists, physiotherapists, and psychologists.)

Key questions for us: 

• What will mandatory registration involve? 
• When will it be required?
• What, if anything, should we be doing to prepare for it? 

What we know:

In August 2024, the Government released the advice of the NDIS Provider and Worker Registration Taskforce. In a nutshell, they recommended that, in addition to Worker checks:

• AHPRA-registered allied health professionals have their existing registration recognised for NDIS registration purposes; and
• “consideration be given” to the appropriateness of extending this recognition to SLPs and other allied health professions who are self-regulated by rules that mirror AHPRA’s requirements.

Growing consensus that all allied health providers should be regulated the same way:

• It’s likely that SLPs will eventually be granted access to the National Registration and Accreditation Scheme (NRAS) through a ‘light touch’ professions registration pathway, giving us a form of registration, with AHPRA oversight. This should bolster the argument that SLPs should be treated in the same way as AHPRA-regulated allied health professionals. 
• The 2024 Scope of Practice Review report into the health workforce recommended that the regulatory model for professions operating outside of the NRAS (including for SLPs) be strengthened and standardised.
• The Productivity Commission also wants greater regulatory alignment across the care sector.

What does the Government think?

There are some pretty obvious clues in the consultation paper. The Government appears to want:

• mandatory registration of all providers (p 5), including allied health and therapeutic services, early childhood and early intervention services, health services, such as paediatric support and peer support programs and initiatives (p 8);
• a risk-proportionate regulatory model (p 7) and a regulatory system that reflects the level of risk and complexity of services delivered (p 2);
• a registration system “where providers of similar services are on a level playing field” (p 3); and
• participants to have choice and control of accessing supports (p 4).

(Source: p7) 

Risks for SLPs and other unregistered allied health providers: 

• The Government knows that, if it gets it wrong, reforms could have unintended consequences, including disruptions to services and unnecessary red tape (p 4). 
• Through its pricing controls, Thriving Kids, and its other reforms, governments are deliberately seeking to restructure the market for NDIS and other publicly funded supports, including allied health supports. 
• Solo speech pathologists in metropolitan areas and clinic owners who train and supervise SLPs are particularly vulnerable to further changes, like mandatory registration, that might increase their compliance costs and other overheads. 
• Many SLPs are working hard to reduce their reliance on NDIS funding. 
• It’s likely some SLPs will not want to register, requiring them to cease providing NDIS supports altogether, reducing participant choice and control.     

What to do now:

• stay calm, watch and wait for the outcome of the consultations;
• ensure your Worker Checks are up to date; 
• review your policies for compliance with both professional rules and the NDIS Code of Conduct; and
• implement/revise your Incident Management, Complaints Management and other compliance systems and policies to ensure they meet NDIS requirements that currently apply to registered providers. 

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This article also appears in a recent issue of Banter Booster, our free newsletter navigating problems for busy speech pathologists, one week at a time.

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