It introduces broader protections, wider reporting pathways, heavier record-keeping and communication obligations, and very real penalties for getting it wrong. The kicker? From 1 November 2025, many providers may need to operate under two overlapping regimes: the Aged Care Act 2024 (Cth) (Aged Care Act) and the Corporations Act 2001 (Cth) (Corporations Act), for incorporated entities. Treating this as a simple policy refresh is a fast route to breaches, staff confusion, reputational damage and regulatory pain.
This deep-dive outlines the common pitfalls we’re seeing as providers prepare for the new framework, and the practical steps to manage risk without overwhelming your people.
Providers that are incorporated under the Corporations Act must meet obligations of both the Aged Care Act whistleblowing framework and the Corporations Act framework. These regimes do not map neatly.
Do you create two separate policies, or one integrated policy that clearly delineates which rules apply in which scenarios? Either can work, but only if it’s explicit, simple for frontline staff, and backed by training and tools. The worst outcome is a blended, vague policy that leaves all stakeholders guessing.
External reporting under the new framework: The new Aged Care Act contemplates four external reporting channels, each with different triggers and expectations:
Pitfall to avoid: Failing to map when an issue stays internal vs moves to an external channel, and who decides, creates delay, double-handling and regulatory risk.
The Act’s internal recipient categories are intentionally broad:
That breadth sounds consumer-friendly, but operationally it’s hazardous. It means many untrained people could become first-line recipients of protected disclosures they’re not equipped to handle.
Practical answer: Establish a clear “primary front door” for all concerns in the form of a managed hotline backed by a skilled triage team, so that frontline staff can direct (or, with consent, lodge on behalf of) the reporter. That prevents missteps, preserves confidentiality, and reduces the load on your scarce experts.
Pitfall to avoid: Trying to satisfy these obligations with emails, shared drives and ad-hoc spreadsheets. It won’t scale, and it won’t stand up in an audit or investigation.
A robust model draws a bright line between internal handling and external escalation, while making it simple for residents, families and workers to speak up safely.
From first contact to closure, every step should be time-stamped, documented and reviewable:
All of our programs are powered by Core+, a secure, cloud-based ethics reporting and case management platform designed for 24/7 access across any device. Fully customisable, Core+ adapts to your organisation’s structure, industry and legal obligations.
Built for trust and security, it enables two-way anonymous communication, keeping reporters safe while allowing genuine dialogue and follow-up. The integrated case management system captures every interaction with indelible audit logs, ensuring compliance and transparency.
With search, reporting and dashboard capabilities, Core+ gives your team real-time insights to strengthen risk management, track trends and demonstrate due diligence – everything you need to manage disclosures confidently and compliantly.
Pitfall to avoid: Generic e-learning that teaches definitions but not what to do next.
Outcome: Less risk, less noise for your compliance team, and a defensible, humane response for residents and families.
The intent of the reform is right: make it safer and easier to speak up and ensure providers act. But the breadth of the Aged Care Act’s whistleblowing framework, combined with ongoing Corporations Act duties, if applicable, creates real operational traps. You don’t need a bigger compliance team; you need a smarter operating model: one front door, clear pathways, fit-for-purpose tooling, and people trained to use them. We can help!
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