Key personnel
NDIS Key Personnel: Who Counts and What's Required
Key personnel are the people the NDIS Commission holds particularly accountable for a provider's governance and conduct. Getting this list right — and keeping it current — matters throughout the registration lifecycle, not just at application.
Registration Requirements4 min readLast reviewed:
Takes about 60 seconds. No obligation.
Who this guide is for
- Directors and owners preparing a registration application
- HR or governance staff managing personnel records
- Businesses undergoing leadership changes
- Providers preparing for renewal or audit
Who typically counts as key personnel
Key personnel typically includes people with responsibility for, or significant influence over, the organisation's governance and operations — company directors, partners in a partnership, the CEO or equivalent senior manager, and any board members with decision-making authority.
For sole traders, the individual themselves is generally treated as key personnel. For larger organisations, the list can extend to state or divisional managers where they hold genuine control over service delivery decisions, though the exact boundary depends on your structure and should be confirmed against current Commission guidance.
Suitability information the Commission may ask for
Exact requirements vary, but commonly requested information includes:
- Proof of identity documents
- Details of relevant qualifications, roles and professional history
- Disclosure of any relevant criminal history or disciplinary findings
- Details of any prior involvement with providers that have had registration refused, revoked or suspended
- Declarations about bankruptcy, insolvency or disqualification as a company director, where relevant
Why suitability checks exist
Suitability checks are designed to give the Commission and participants confidence that the people steering an organisation don't present an unmanaged risk to safety, quality or the proper use of NDIS funding. This sits alongside, but is separate from, worker screening checks for individual staff delivering direct supports.
It's worth noting that key personnel suitability and NDIS Worker Screening Checks are two different mechanisms assessing different things — a director may need both if they also deliver direct supports.
Key personnel vs worker screening — what's different
| Aspect | Key personnel suitability | Worker screening check |
|---|---|---|
| Who it applies to | People with governance/control over the organisation | Workers in risk-assessed roles with participants |
| What's assessed | Identity, history, prior provider involvement, disclosures | Criminal history relevant to working with people with disability |
| Administered by | NDIS Commission as part of registration | State/territory worker screening units |
| Ongoing obligation | Report changes in key personnel | Maintain current clearances, renew before expiry |
Steps for managing a change in key personnel
- 01
Identify the change
Confirm whether the incoming or outgoing person meets the definition of key personnel for your structure.
- 02
Gather suitability information
Collect identity and disclosure information for the new key person before they take on the role where possible.
- 03
Notify the NDIS Commission
Report the change through the appropriate Commission process, generally within required timeframes.
- 04
Update internal governance records
Reflect the change in company registers, org charts and policy documents referencing key personnel.
- 05
Review insurance and authority documents
Check that insurance policies, bank authorities and contracts reflect the new personnel structure.
Delays in reporting can affect compliance standing
Failing to notify the Commission of key personnel changes in a timely way can itself become a compliance issue, separate from the suitability of the new person. Build personnel change reporting into your governance calendar.
Governance implications beyond the individual check
Key personnel requirements exist within a broader governance picture: the Commission is also interested in how your organisation makes decisions, escalates risk, and holds people accountable day to day. A well-documented governance structure — clear reporting lines, delegated authorities, and decision records — supports the individual suitability checks rather than sitting apart from them.
For growing organisations, this is also a good time to formalise what was previously an informal arrangement, since ad hoc governance is harder to evidence at audit.
Frequently asked questions
- Does every director automatically count as key personnel?
- Generally yes for company structures, though the precise scope can depend on the level of genuine influence each director has over the organisation's NDIS-related decisions.
- What if a key person has a past criminal record?
- A past record doesn't automatically prevent registration; the Commission assesses relevance and risk as part of its suitability assessment, so disclosure and context matter.
- Do I need to notify the Commission every time a manager changes?
- Only where that person meets the definition of key personnel for your organisation — routine staffing changes below that threshold generally don't require notification.
- Is a company secretary considered key personnel?
- This depends on the actual influence and role the company secretary has over the organisation's affairs, rather than the title alone.
- How is key personnel suitability different for sole traders?
- A sole trader is themselves the key person, so suitability information relates directly to that individual rather than a separate governance layer.
- Can a change in key personnel trigger a review of registration?
- It can prompt the Commission to reassess suitability, particularly for significant changes such as a new CEO or controlling director.
Official sources and further reading
Requirements change. Always confirm the current position with the relevant authority before making decisions.
Ready to move forward?
Get an indicative pathway in about a minute, or start your registration with personalised support for your documents, self-assessment and audit preparation.
NDIS Provider Registration is an independent service and is not affiliated with or endorsed by the NDIA or the NDIS Quality and Safeguards Commission. We provide application preparation and audit preparation support; independent auditor fees are separate and registration decisions are made by the Commission.