Subcontracting Policy

Reviewed Jun 2020, Dec 2020, Jun 2021, Dec 2021, Updated Jun 2022, Reviewed Jul 2023, Dec 2023

Subcontracting Policy Statement

ACCM College does not subcontract to other suppliers for the delivery of training and assessment or student recruitment.

Specifically, ACCM College does not subcontract or outsource to other suppliers to deliver publicly available services under government funded contracts on our behalf, including:

Specifically, the Australian College of Commerce and Management does NOT sub-contract the recruitment and selection of participants into its publicly available training programs, nor use brokers, nor use online services that act as brokers

The College does engage a small number of additional assessors on a casual/contract basis to address overflow student assessment marking, or design of learning resources. Such assessors are governed by a written agreement that includes marking standards, moderation participation and audit requirements that must be maintained.

The College will from time to time sub-contact some aspects of services with specific employers under an official auspicing arrangement. Under these agreements some training may be delivered by that employer to its own employees on behalf of the College, for example. These are subject to written agreements, advice to regulators, and are strictly audited to ensure College standards are maintained.

No such arrangements are in place at this time.

ASQA Rules Regarding Sub-contracting and Third Party Arrangement

  • ASQA Policy

    The Australian Skills Quality Authority (ASQA), our National Regulator, has very specific requirements regarding Third Party arrangements.

    ASQA works with VET providers to make sure students achieve qualifications from quality courses that provide relevant skills.

    RTOs (VET providers) sometimes work with a third party for:

    • Marketing and recruitment services
    • Access to facilities and resources
    • Training and assessment of a training product.

    Training products are listed on a provider’s scope on the national register,

    Registered Training Organisations require a written agreement for a third party to advertise, offer or deliver any part of a training product on their behalf.

    The most current information on Third Party arrangements can be found on ASQA's website here ASQA Third Party Arrangements

    ACCM College is not engaged in any Third Party Arrangements at this time.

Specific State and Territory Rules on Subcontracting

  • NSW Smart and Skilled

    NSW Smart and Skilled requires:

    • Department approval of subcontracting guidance is found here Smart and Skilled Third Party Approval Policy
    • A specific Subcontracting Approval form must be submitted prior to commencing subcontracting activities and a subcontracting approval number obtained.

    Upon approval:

    • The subcontractor arrangement needs to be advertised
    • All students under the subcontracting arrangement must be advised.

    Current as of July 2023 


  • ACT Skilled Capital and User Choice


    Clause 8.1 of the ACT Training Initiative Funding Agreement states the mandatory terms and conditions regarding subcontracting.

    Circumstances in which the Territory considers the arrangement between a Training Provider and another party (either an RTO, other entity or individual) constitutes a subcontracting arrangement requiring written approval by the Territory include, but are not limited to:

    • Where the Training Provider engages an RTO that does not hold an Agreement or an organisation that is not an RTO, to conduct any training and/or assessment on its behalf
    • Where any day to day responsibilities for the management of training delivery and/or assessment, for example administration of student records, is deferred to another individual or organisation.

    The following instances do not, for the purposes of the Agreement, constitute a subcontract arrangement that require written approval by the Territory:

    • Trainers and/or assessors hired as contractors or under an employment agreement
    • Agencies, organisations or individuals contracted to deliver additional support, wrap around or work experience coordination services.

    To apply for written approval, both the Training Provider and the proposed subcontractor must complete an Application for Subcontracting Arrangement Approval (PDF 1.28MB). Skills Canberra will notify the Training Provider of its decision within 30 calendar days of receiving the application. Failure to receive approval from Skills Canberra prior to commencing the use of any subcontracted service will be considered a breach of the Agreement and will constitute a default under clause 14 of the Agreement.

    The written agreement between the Training Provider and the subcontractor for the intended subcontracting arrangement must establish the responsibilities of each party as per clause 8.3, for example, how the Training Provider will manage the subcontracting arrangement and ensure compliance with the Agreement. The written agreement may be the same agreement developed for Australian Skills Quality Authority's requirement under 2.3 of the Standards for Registered Training Organisations (RTOs) 2015.

    The written agreement must also include the names of all persons employed by the proposed subcontractor who will be involved in the training and/or assessment and their qualifications.

    The written agreement must be in place prior to commencing the subcontracted service.

    For more information, follow the below link:

    ACT Training Initiative Funding Arrangements


  • QLD - Skills Assure

    Skills Assure suppliers (SAS) entering into third party arrangements to assist with delivering services under their Skills Assure Supplier Agreement, will need to report these arrangements through the third party arrangements form. After making an initial submission as part of their application, suppliers are required to complete a new form:

    • No later than 10 business days after entering into a new third party arrangement.

    Suppliers must notify the department via email at

    • No later than 5 days following any change in control of the third party or termination of a third party arrangement
    • Where changes to existing third party arrangements are required.

    Where a third party has been involved in the delivery of any part of the training and/or assessment of a unit of competency for a student, the third party must be reported in the supplier's AVETMISS compliant data. Once the department is notified of a new third party arrangement, suppliers are set a third party reporting schedule. This schedule details the relevant purchasing contract schedule identifier (third party code) against each third party reported by a supplier in their third party arrangements form.

    For more information, visit the link below:

    Skills Assure Supplier - 3rd Party Arrangements

  • Skills Tasmania

    Skills Tasmania User Choice contract: under Schedule 2.1 clause 2.1 the College is not permitted (and so does not) sub-contract the recruitment and selection of participants into training programs.