Raising the standard – Compliance with the Queensland Child Safe Standards

The Child Safe Organisations Act 2024 (Act) recently commenced on 1 October 2025.

Part one of our three-part series[1] gave a summary of the ten Child Safe Standards, and the dates by which organisations need to ensure that they have been implemented.

This second part of our three-part series addresses what compliance with the new Child Safe Standards looks like.

What are the Child Safe Standards and how should you implement them?

The Queensland Family and Child Commission (QFCC) has summarised the Child Safe Standards as standards that

‘… help create environments where Queensland’s children can grow, learn, and thrive without harm. They are built on children’s rights and provide a clear framework for keeping children safe’.

All organisations classified as ‘child safe entities’ under section 10 of the Act must implement and comply with the Child Safe Standards.[2] In broad terms, this obligation applies to any organisation that works with or provides spaces and facilities for children.

In implementing and complying with the Child Safe Standards, organisations must also comply with the Universal Principle of providing an environment that promotes and upholds the right to cultural safety of children who are Aboriginal persons or Torres Strait Islander persons.[3] 

The actions that a particular organisation will need to take to implement the Child Safe Standards and the Universal Principle will be unique to it. The necessary actions will depend on (among other things) the size and scale of the organisation, the sector it is in, the extent to which it works with children, and the nature of the work the organisation does with children. 

We outline in this article what each of the ten Child Safe Standards are in greater detail, and some actions that might be taken to implement them. 

Standard one – Leadership and culture

Making a commitment to child safety, wellbeing and cultural safety that is visible across the organisation and is evident in key policies and procedures is an important starting point to implementing standard one.[4] Indicators of compliance include ensuring the organisation:

1. can demonstrate it has publicly available and current documents and procedures, including:
   • child safety and wellbeing policies;
   • practice guidance;
   • information sharing protocols; and
   • staff and volunteer codes of conduct;
2. has established governance structures and clear reporting frameworks that enable organisational leadership to effectively monitor and act on risks to children’s safety;
3. provides leaders, staff and volunteers with regular training and support to understand and fulfil their responsibilities for children’s safety and wellbeing with reference to the relevant policies; and
4. works with Aboriginal and Torres Strait Islander staff and stakeholders to identify appropriate progress and success indicators and evaluation methods.

Standard two – Voice of children

As part of ensuring children have a voice, standard two[5] aims to ensure that organisations foster an environment where children’s voices are not just heard but actively shape outcomes that affect them. Some key indicators of compliance could include ensuring that the organisation:

1. has programs and resources to educate children on their rights, including their right to safety and their right to be listened to;
2. is proactive in providing age-appropriate platforms to regularly seek children’s views and encourage participation in decision-making; and
3. has processes where children are informed about their roles and responsibilities in helping to ensure the safety and wellbeing of their peers.

Standard three – Family and community

Standard three[6] focuses on the principle that child safety and wellbeing are strengthened when families and communities are informed, engaged and active partners in promoting safe environments. From a practical perspective, organisations should prioritise:

1. creating opportunities for families and communities to be involved in how the organisation operates, including to co-design and participate in the development and implementation of policies, practices and programs; and
2. having clear and accessible information for families and communities on issues of children’s safety and wellbeing, including in relation to Aboriginal and Torres Strait Islander families and those from other diverse backgrounds.

Standard four – Equity and diversity

Queensland’s diverse population is recognised through standard four,[7] which requires organisations to uphold equity and respect diverse needs in policy and practice. This can be achieved through:

1. policies that promote equity and diversity in the context of the safety and wellbeing of children;
2. child-friendly material being provided in accessible languages and formats that promotes inclusion and informs all children of the support and complaints processes available to them;
3. staff and volunteer training to help them recognise and respond effectively to children with diverse needs; and
4. a cultural safety framework and/or action plan to embed cultural safety, equity and diversity principles across policies, programs and governance structures.

Standard five – People

Standard five[8] requires organisations to ensure that staff and volunteers engaging with children are not only suitable to work with children but are supported with ongoing professional development and clear guidance, empowering them to model safe and respectful practices in every interaction. Key action areas for organisations to focus on when implementing this standard include:

1. rigorous recruitment and advertising practices, including ensuring that selection criteria demonstrate a commitment to child safety and wellbeing and an understanding of a child’s development needs and culturally safe practices; and
2. careful screening processes, including Working with Children Checks[9] and referee checks.

Standard six – Complaints management

Standard six[10] requires organisations to have processes in place that provide a child-focused approach to complaints and concerns. To implement this standard, organisations should consider ensuring that they:

1. have child-friendly complaints policies that are accessible to children, carers, families, staff and volunteers, and promote timely feedback to those who raise concerns; and
2. offer training for staff to handle complaints sensitively, with a focus on supporting and protecting children and seeking to ensure that no child or person is retraumatised throughout the process.

Standard seven – Knowledge and skills

Standard seven[11] intersects with standards four and five in positively requiring staff and volunteers working with children to be equipped with the knowledge, skills and awareness to keep children safe through ongoing education and training. In addition to being screened and qualified, organisations should ensure that staff and volunteers receive ongoing education, training and mentoring to build the knowledge, skills and awareness to proactively safeguard children in all interactions.

Standard eight – Physical and online environments

Given the diversity of settings where children interact with organisations, creating safe physical and online environments is a cornerstone of children’s safety and wellbeing. To ensure compliance with standard eight,[12] some key issues organisations should consider include:

1. whether it has a risk management strategy that addresses physical and online risks;
2. staff and volunteer access and use of online environments in line with the organisation’s code of conduct, and relevant communication protocols; and
3. whether there are appropriate measures in place to ensure the safety and wellbeing of children with respect to third parties who might visit environments provided by organisations, such as contractors engaged to provide services.

Standard nine – Continuous improvement

Child safety is a dynamic process. Standard nine[13] focuses on the need for organisations to continuously review and improve the implementation of the Child Safe Standards. To ensure compliance with standard nine, organisations should consider:

1. seeking the participation of children, carers and communities in regular reviews of child safety and wellbeing policies;
2. regularly analysing complaints and outcomes to assist in improving child safe practices; and
3. providing consistent updates to staff and volunteers as changes and improvements occur.

Standard ten – Policies and procedures

Standard ten[14] requires organisations to ensure that their policies and procedures prioritise the safety and wellbeing of children. Policies and procedures should equip staff and volunteers with an understanding of how to identify and prevent harm to children. To ensure compliance with standard ten, organisations should consider conducting:

• regular audits of their policies and procedures to provide evidence of how they are child safe and culturally safe; and
• interviews or surveys of children, carers, families and community members to determine the confidence level in, and awareness of, the policies and procedures relevant to child safety and wellbeing.

Key documents

Listed below are some key documents that all child safe entities should consider developing and regularly reviewing, as a starting point:

• a published commitment to children’s safety and wellbeing in your organisation’s physical and/or online environment;
• a child safety and wellbeing policy;
• a code of conduct for staff and volunteers who work with children and for promoting child safety and wellbeing;
• a complaints handling policy; and
• a risk management policy that identifies, assesses and takes steps to mitigate the risk of harm to children.

The QFCC has indicated that these are documents that your organisation may need as a foundation to build on, but that this list is not exhaustive.

When does compliance with the Child Safe Standards need to have occurred by?

The following phase one services listed in part one of this series should have taken steps to ensure that the Child Safe Standards have been implemented by 1 October 2025:

• child protection services;
• government entities;
• justice or detention services; and
• services for children with disability,

The phase two services mentioned in part one of this series should now be prioritising taking steps to implement the Child Safe Standards, given the upcoming deadline for compliance of 1 January 2026. The phase three services mentioned in part one of this series have until 1 April 2026 to ensure that they have implemented the Child Safe Standards.

We encourage you to reach out to our team of experts for any assistance you need in ensuring that your organisation has implemented the Child Safe Standards by the relevant deadline.

Early next year, we will deliver part three of this series, which will focus on:

• which sectors will need to introduce a Reportable Conduct Scheme by 1 July 2026, and how to effect this; and
• enforcement options that are available to the QFCC, which is responsible for monitoring and reporting on the operation of the Child Safe Organisations system established by the Act.

---

[1] If you haven’t already, please refer to part one of this three part series: Phase one of the Queensland Child Safe Standards to be introduced in October 2025 – what are your obligations?.

[2] Section 11(1) of the Act.

[3] Section 11(2) of the Act.

[4] Section 9(a) of the Act.

[5] Section 9(b) of the Act.

[6] Section 9(c) of the Act.

[7] Section 9(d) of the Act.

[8] Section 9(e) of the Act.

[9] https://ppr.qed.qld.gov.au/pp/working-with-children-blue-card-procedure.

[10] Section 9(f) of the Act.

[11] Section 9(g) of the Act.

[12] Section 9(h) of the Act.

[13] Section 9(i) of the Act.

[14] Section 9(j) of the Act.