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Training “Under Direction”: The Supervision Arrangements Most RTOs Get Wrong
Credential Policy · Sections 1B–1D
Training “Under Direction”: The Supervision Arrangements Most RTOs Get Wrong
◆ Who owns this: Trainers, Supervisors & the Compliance Manager
The short version: the Credential Policy lets people who do not yet hold the full training and assessment credentials deliver training and contribute to assessment under direction, with conditions. It is a useful flexibility — and a frequent source of findings, because RTOs use it without documenting the supervision or respecting the limits on who can make assessment judgements.
“Under direction” is one of the most practically important and most misunderstood parts of the 2025 framework. Used correctly, it helps you grow your workforce. Used loosely, it puts invalid assessment judgements into your system.
How the Credential Policy structures this
The Credential Policy distinguishes between delivering training and assessment without direction (which requires the full credentials set out in section 1A) and delivering under direction (sections 1B–1D), which applies to people who do not yet hold those full credentials. The under-direction pathways include working under the direction of a suitably credentialled trainer/assessor and people actively working towards a training and assessment credential.
The detail matters: the policy was clarified during consultation specifically because wording around whether people under direction could make assessment judgements was causing confusion. The safe reading is that under-direction arrangements have boundaries, and assessment judgement is the boundary RTOs most often cross.
Where RTOs get exposed
- No documented supervision. “They work under our senior trainer” is not evidence. The arrangement, the supervisor, and the scope must be on paper.
- Assessment judgements by people not permitted to make them. This is the big one — it can render judgements invalid.
- Supervisor not actually credentialled to supervise. The person providing direction has to hold the right credentials themselves.
- Using it as a permanent workaround. Under direction is a pathway, not an indefinite substitute for credentialling your workforce.
The line that gets crossed most. A trainer working under direction quietly starts signing off assessment judgements because they are capable and it is convenient. Capability is not the test — permission is. If the policy does not permit that person to make the judgement, the judgement is exposed regardless of how good it is.
What good evidence looks like vs what fails
✓ Holds up
Written supervision arrangements naming supervisor and scope
A credentialled supervisor genuinely overseeing the work
Clear boundaries on assessment judgement, respected in practice
A pathway plan showing progress toward full credentials
Records that map who is under direction and for what
× Gets flagged
Informal “they’re supervised” with nothing documented
Under-direction staff making assessment judgements they cannot
A supervisor who is not credentialled to supervise
Under direction used indefinitely with no progression
No record of who is operating under direction
How to get it right
- Document every arrangement. Name the person, the supervisor, the scope, and the limits — in writing, kept current.
- Confirm the supervisor’s credentials. The person giving direction must hold the credentials the policy requires.
- Draw the assessment-judgement line clearly. Make sure everyone knows what under-direction staff can and cannot sign off, and enforce it.
- Treat it as a pathway. Pair it with a plan to reach full credentials, so it is genuinely transitional.
Using “under direction” correctly?
The free Risk Scorecard flags Credential Policy exposure — including whether your under-direction supervision would hold up.
Frequently asked questions
1. What does “under direction” mean in the Credential Policy?
It refers to delivering training and contributing to assessment while working under the direction of a suitably credentialled trainer and assessor, in defined circumstances set out in sections 1B–1D of the Credential Policy. It applies to people who do not yet hold the full credentials required to operate without direction.
2. Can a person working under direction make assessment judgements?
Under-direction arrangements have boundaries, and assessment judgement is the area RTOs most commonly get wrong. The policy was clarified to reduce confusion on this point. The safe approach is to confirm precisely what the person is permitted to do and to ensure assessment judgements are made only by those allowed to make them.
3. Does the supervisor need specific credentials?
Yes. The person providing direction must themselves hold the credentials required to deliver and assess without direction. A supervisor who is not properly credentialled undermines the whole arrangement.
4. How should under-direction arrangements be documented?
Record the person working under direction, the named supervisor, the scope of work, and the limits on assessment judgement — and keep it current. Informal or undocumented supervision is a common finding.
Sources: Credential Policy: Standards for Registered Training Organisations (training.gov.au), sections 1A–1D; DEWR consultation updates on the Credential Policy. Verified June 2026.
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