By Claire Boardman, Law Graduate

The Queensland Parliament passed the Child Safe Organisations Act 2024 on 19 September 2024 (the Act) following extensive policy development, impact analysis and public consultation through the Growing Child Safe Organisations in Queensland Consultation Regulatory Impact Statement in 2023.

The Act introduces Child Safe Standards and the Reportable Conduct Scheme as initially recommended in the Final Report of the Royal Commission into Institutional Responses to Child Sexual Abuse.

Recently, time frames for compliance have been brought forward. Entities should urgently seek advice as to whether their current implementation of the standards meets the requirements of the Act and seek advice on how to comply with the law.

Child Safe Standards

The 10 National Principles for Child Safe Organisations apply as child safe standards and compliance is required by the following entities in Queensland:

1. From 1 October 2025:
   1. Child protection;
   2. Services for children with a disability;
   3. Justice or detention services; and
   4. Government entities.
2. From 1 January 2026:
   1. Accommodation and residential services;
   2. Education services;
   3. Health services;
   4. Early childhood education, care and child-minding services; and
   5. Community services.
3. From 1 April 2026:
   1. Commercial services for children;
   2. Transport services provided specifically for children;
   3. Religious bodies; and
   4. Services or activities provided primarily for children.

The Reportable Conduct Scheme

The Reportable Conduct Scheme introduces strict requirements for a ‘reporting entity’, defined as an entity that cares for, supervises or exercises authority over children, whether as a primary function or otherwise and either mentioned in schedule 2 of the Act or prescribed by regulation. The head of a reporting entity must ensure the entity has in place the various systems outlined in section 30 of the Act relating to reportable conduct, reportable allegation and reportable conviction, as defined in sections 26-28 of the Act.

If a worker becomes aware of a reportable allegation or reportable conviction of another worker, they must report the matter to the head of the reporting entity. It is irrelevant whether or not the conduct or misconduct is alleged to have occurred in the course of the worker performing work for the reporting entity.

The head of the reporting entity must then notify the Commission within 3 business days, provide a written report within 30 business days, conduct an investigation, notify the Commission that an investigation is being conducted, and provide the Commission with a final report. The Commission may monitor compliance and investigations.

While the Act itself sets out various start dates, the Queensland Government has released a statement that compliance for all reporting entities is now required by 1 July 2026.

The Act does not apply to allegations or convictions of a worker before 1 July 2026 unless, after 1 July 2026, a person reports the matter and the worker is performing work for the reporting entity when the matter is reported. The head of a reporting entity may voluntarily comply with the Act.