Queensland has introduced a new safeguarding framework under the Child Safe Organisations Act 2024. The new framework represents major changes for schools, early childhood services, and other organisations working with children, aimed at embedding child safety into leadership, governance, and everyday practice.

This article outlines the staged rollout, explains the Child Safe Standards and Universal Principle, clarifies the new definition of harm, and highlights key compliance risks and practical tips for implementation.  

The reforms begin on 1 October 2025. Most schools and accommodation services (including boarding houses) fall into Phase 2, meaning they must be fully compliant with the Child Safe Standards and the Universal Principle by 1 January 2026.

A second reform, the Reportable Conduct Scheme, will apply from 1 January 2027. We outline the RCS in more detail in our article See something, say something: Responding to harm under Queensland’s new reportable conduct scheme.

The Standards are ten interrelated benchmarks designed to embed child safety into an organisation’s culture, policies, and practices. They include:  

1. Leadership, governance and culture.

2. Child participation and empowerment.

3. Family and community engagement.

4. Equity and inclusion.

5. Staff suitability and support.

6. Child-focused complaints handling.

7. Staff training and awareness.

8. Safe physical and online environments.

9. Continuous review and improvement.

10. Documented policies and procedures.

These are not just aspirational goals; they are enforceable obligations. Schools, child care centres, and other organisations working with children must demonstrate that child safety is embedded across all levels of the organisation. Again, having a child safety policy will not be sufficient to meet the obligation. Organisations will need to show that a true safeguarding culture is in place.  

Each Standard must also uphold the Universal Principle, which is the right of Aboriginal and Torres Strait Islander children to feel culturally safe. This means embedding cultural safety in decision-making, complaint handling, and everyday practice. It’s not an add-on; it must be integrated into all aspects of child safety planning and delivery.  

The Act introduces a broader definition of harm. The definition includes:

“Damage to the health, safety, or well-being of a child. It can be the result of abuse or neglect by an adult or the conduct of other children.”

This definition captures peer-to-peer harm, which may not be covered under the Child Protection Act 1999 (Qld) or the Education (QCT) Act 2005 (Qld). Importantly, harm under the Standards does not need to be “significant” to trigger action. This lower threshold means schools and child-facing organisations must take proactive steps to prevent all forms of harm, regardless of severity.  

Organisations must “have regard to” the QFCC Guidelines for implementing the Universal Principle and Child Safe Standards. These Guidelines provide practical advice, examples, and indicators of success, which in turn help schools translate broad principles into measurable actions.

While not legally binding in every detail, the Guidelines are the benchmark for compliance. Schools are expected to adopt measures that meet the intent of each Standard.  

Under section 111 of the Act, schools are no longer required to maintain a separate Child and Youth Risk Management Strategy (CYRMS) under the Working with Children (Risk Management and Screening) Act 2000 (Qld).

Previously, organisations regulated by the Blue Card system were required to develop, implement, and maintain a child and youth risk management strategy. The purpose of this strategy was to identify potential risks of harm to children and young people and to put in place measures to reduce those risks.

Although the legislation no longer requires compliance with the CYRMS framework, the QFCC Guidelines still require organisations to have written risk management strategies. Those strategies must clearly align with the Child Safe Standards and should be reflected in foundational documents, including:

• A Child Safety and Wellbeing Policy.

• A Code of Conduct for working with children.

• A child-focused risk management strategy.

These documents should be reviewed regularly and tailored to your context. The QFCC Guidelines recommend creating an implementation roadmap with clear timelines, realistic actions, and measurable outcomes.  

Standard 9 requires organisations to regularly review and improve their child safety practices. For child-facing organisations, including schools, day care, out-of-hours care, and their governing bodies (including those overseeing multiple child-safe entities), this traditionally is reflected in the development of structured review schedules – for example, committing to review complaints or incidents within a set timeframe.

While this may seem like good governance, embedding prescriptive timelines directly into your child safety policies can create unintended legal consequences and non-compliance with the new standards.

Policies that include specific procedural commitments may become directive in a way that is not child safe. For example, timelines for policy reviews may lead people to think that they do not need to review practice or policy outside of those timelines. In that circumstance, an organisation may not be responding to risk as it arises.

Further, if such standards are incorporated into enrolment agreements, employment contracts, or other formal documents, they can be difficult to change in response to evolving risk.

This risk was recently highlighted in the High Court’s decision in Elisha v Vision Australia Ltd [2024] HCA 50. The Court found that Vision Australia’s disciplinary procedures were contractually enforceable because they were incorporated into the employment contract through clauses referencing company policies. The Court held:

“It would ‘defy both logic and common sense’ to suggest that an employer… would not similarly be bound by those policies.”

The lessons are clear: if your policies make promises, you must be prepared to keep them - or face the consequences. Further, if your policies are in contracts or other enforceable documents, you may not be able to respond and change as needed to meet emerging risk.

This is not to say that policies should not be reviewed regularly. Standard 9 requires it. However, the approach to reviews should be carefully considered:

• Avoid rigid timelines unless legally required.

• Use flexible phrasing such as “as appropriate” or “where relevant.”

• Embed review schedules in internal procedures or contracts, rather than public-facing policies, to reduce enforceability risk.

It may still be appropriate to ensure serious or critical incidents are reviewed individually and expeditiously, even if routine matters follow a broader review cycle.

This approach allows child-facing organisations to meet their obligations under the Child Safe Standards while maintaining flexibility and reducing exposure to legal claims.  

The Queensland Family and Child Commission (QFCC) is the oversight body. It can:

• direct entities to complete a self-assessment;

• issue compliance notices (with penalties up to 100 units);

• apply to the court for enforcement orders; and

• publicly report non-compliance.

Non-compliance isn’t just a legal risk; it’s a reputational one. 

With the Child Safe Standards and Universal Principle becoming mandatory for most schools and child-facing entities by 1 January 2026, now is the time to take proactive steps to ensure your organisation is ready. Here’s how to get started:

1. Review the QFCC guidelines thoroughly

Begin by familiarising yourself with the Guidelines for implementing the Universal Principle and Child Safe Standards in Queensland. These Guidelines are not just advisory. They provide the practical roadmap for compliance. Use them to:

• understand the intent behind each Standard;

• identify key action areas and indicators of success; and

• reflect on how your current practices align with expectations.

2. Conduct a gap analysis

Compare your existing policies, procedures, and culture against the Standards. This will help you identify areas that need improvement and prioritise actions that will have the greatest impact.

3. Update and align your policies

Ensure your child safety policies:

• clearly reflect the 10 Child Safe Standards and the Universal Principle;

• are accessible and understandable to staff, students, and families;

• avoid overly prescriptive language that may create compliance risks; and

• include foundational documents such as a Child Safety and Wellbeing Policy, Code of Conduct, and integrated risk management strategy.

4. Engage leadership and governance

Child safety must be embedded in your school’s leadership and governance structures. This means:

• including child safety in strategic planning and board agendas;

• assigning clear responsibilities for oversight and implementation; and

• ensuring senior leaders actively promote a culture of safety and inclusion.

5. Train staff, volunteers, and student leaders

All workers of an entity, including volunteers, contractors, executive officers, and clergy, must understand their obligations under the Standards. Training should cover:

• recognising and responding to harm;

• understanding cultural safety;

• reporting pathways and complaint handling; and

• the importance of child-focused practice.

6. Develop an implementation action plan

Finally, pull this all together by creating a tailored action plan that sets out:

• key milestones and timelines;

• roles and responsibilities;

• measurable outcomes and indicators of success; and

• review and feedback mechanisms. 

Need help getting started? Now is the time to review your policies, consult your staff, and seek expert advice. The Child Safe Standards are coming, and your school’s readiness will make all the difference. If you need guidance or support in applying these strategies, please contact Jay or Megan in our Employment & Safety team to discuss your specific situation.