Victoria is shifting responsibility for receiving reportable conduct and child safety notifications from the Commission for Children and Young People (CCYP) to the Social Services Regulator (SSR) to address information sharing gaps and strengthen regulatory consistency. This shift comes amid a rise in notifications, persistent trends emerging of non‑compliance and recent changes to the Reportable Conduct Scheme (Scheme).

Whilst not directly impactful, the heightened risks around institutional liability will be a key factor moving forward following:

• the High Court’s expansion of non‑delegable duties in AA v Trustees of the Roman Catholic Church for the Diocese of Maitland‑Newcastle [2026] HCA 2 (see our previous case note, "High Court expands institutional liability for historic child abuse”); and

• the introduction of the Justice Legislation Amendment (Vicarious Liability for Child Abuse) Bill 2025 in Victoria which reverses the High Court's earlier decision in Bird v DP (a pseudonym) [2024] HCA 41 and seeks to hold institutions liable for child abuse committed by individuals who were not formal employees but who operated in roles “akin to employment”, such as clergy, volunteers or others placed in positions of authority by the institution.

From 23 February 2026, responsibility for receiving allegations of reportable conduct and child safety concerns will transfer from the CCYP to the SSR with a new webform available through the SSR's website. Importantly, any existing reports made to the CCYP will be transferred to the SSR so previous reports will not need to be re-submitted.

This change does not alter an organisation's obligations under the Child Safe Standards or the Scheme and the CCYP will continue to maintain its oversight role, including making enquiries, undertaking advocacy, monitoring and promoting improvements to child safety in Victoria.

The Victorian Government rationale for redirecting reportable conduct notifications from the CCYP to the SSR is aimed at addressing critical information‑sharing gaps identified by the Rapid Child Safety Review and to strengthen state‑wide consistency by consolidating key child‑safety regulatory functions within a single authority.

To access further information directly from the CCYP about the above changes, please access this link: https://ccyp.vic.gov.au/news/changes-to-your-regulator/.

On 28 October 2025, the CCYP tabled its 2024-25 annual report in the Victorian Parliament which outlined its work over the past year in promoting the safety, wellbeing and rights of Victoria’s children and young people.

We highlight below some key insights from the annual report:

1. Increase in number of reportable conduct notifications
   
   The annual report has highlighted a notable increase in the number of reportable conduct notifications and opened cases between 2024 and 2025. Specifically, the number of new notifications increased from 1,892 to 2,232 new notifications (340 more notifications than the previous year). This reflects a trend of increasing frequency in new notifications since the earliest period covered by the report (2017 to 2018), where there were only 803 total new notifications. The report explains that this increase has been driven by mandatory reporting laws, increased community awareness and the expanded definition of workers covered by the Scheme. Accordingly, organisations should be aware of this upward trend and ensure their reporting processes remain robust.
    
2. Frequently investigated sectors and areas of non-compliance
   
   The annual report also highlighted the most frequently investigated areas of non-compliance, particularly among community sporting and cultural organisations, include inadequate screening practices, insufficiently tailored child safety policies, limited staff training and poor communication with children and families about child safety. The report provided a breakdown of the specific sectors and organisation types and their respective share of the non-compliance investigations undertaken by the CCYP in the 2024-2025 period. The annual report revealed that investigations into cultural, sporting or recreational services comprised 71% of the total investigations undertaken by the CCYP during this period. More specifically, within this 71% share of investigations, 78% related to community sporting clubs and other sporting organisations, while the remaining 22% comprised investigations into cultural and recreational institutions. Comparatively, the next highest sector was religious bodies, which was at 6%.

As reporting pathways shift, it is important that organisations use this time to review existing policies around the Child Safe Standards and confirm that their organisation's policies, codes of conduct, training and risk management strategies remain current and fit for purpose.

The combined effect of the regulatory shift to the SSR, increasing reportable conduct notifications, non‑compliance trends and the broadened scope of institutional liability through the High Court's recent decision in AA v Trustees of the Roman Catholic Church for the Diocese of Maitland‑Newcastle [2026] HCA 2 and the new vicarious liability legislation, underscores the need for organisations to reassess and strengthen their suite of child-safeguarding policies and procedures to ensure they meet the Child Safe Standards and evolving regulatory expectations.

For more information on the matters covered in this article or to discuss their implications, please contact our Institutional Risk & Liability team.