Provider briefing · Residential aged care · Registration renewal
The AECT & CDECT: two workbooks that now decide your renewal
Under the Aged Care Act 2024, renewal is no longer a paperwork exercise. Before assessors set foot in a home,
the Commission reads two evidence workbooks — one about your organisation's systems, one about whether those
systems are actually alive in each home. Most providers say they are not ready: in an April 2026
poll of 200 organisations, 83% admitted they still had work to do before their first audit under the new model,
and only 17% felt "very prepared". This briefing explains what the tools demand, where providers are falling
short, and what to assemble before the audit initiation email arrives.
Research current as of: 19 October 2026Applies to: Residential aged care — registration Category 6 (tools shared with Categories 4 & 5)Compulsory from: 1 November 2025
83%
of providers still had work to do before their first audit under the new model
Mirus Australia poll, 200 organisations — reported by HelloCare, 28 Apr 2026
17%
felt "very prepared" and confident about facing their first audit
Same poll — 76% were only "somewhat prepared" and a further 7% were underprepared
78%
had not yet had an audit or site visit under the new model — their systems were untested
Mirus Australia poll, Apr 2026
3%
felt fully prepared before the new Act commenced — readiness was already low at the starting line
Mirus Australia poll, 230 organisations — Australian Ageing Agenda, 20 Oct 2025
These are sector polls with self-selected respondents — providers' own self-assessment, not a Commission measurement. The Commission has published no readiness statistic of its own (see open questions).
Two tools, two different questions
The AECT asks: does your organisation have the systems? The CDECT asks: are those systems real in this home, on this floor, for these residents? A strong answer to the first and a weak answer to the second is exactly how non-conformance happens.
AECT
Audit Evidence Collection Tool
Level
Provider level. Completed once as part of the audit program — not once per home.
Purpose
Collects evidence about your systems and processes, how you deliver safe, quality care to older people, and how you meet your registration requirements — outcome by outcome against the strengthened Aged Care Quality Standards.
Used in
Registration, renewal and variation audits in categories 4, 5 and 6 — a separate version for each audit type. Compulsory for renewal from 1 November 2025.
How you get it
The Commission sends it in the audit initiation "request for information" email — for renewal, together with the new step-by-step guide (Bulletin #9-2026).
CDECT
Care Delivery Evidence Collection Tool
Level
Service level. For Category 6, completed once for each residential care home — and renewal audits visit every Category 6 home.
Purpose
Collects evidence about the home itself and how the provider's systems and processes are used and embedded at that service — whether they are consistently applied in practice.
Used in
Renewal audits only. The Commission emails a separate request before each home's audit, reviews the completed CDECT, then holds an online opening meeting before the site visit.
What it feeds
The on-site audit of that home: interviews with residents and representatives, staff interviews, observations and file reviews.
In plain terms: the AECT is your organisation's story, told once, at head-office level. The CDECT is the
fact-check, repeated home by home. Assessors are employed to find daylight between the two —
and the graded assessment is built to punish it.
Commission rule
Are providers ready? The numbers say no
There is no Commission-published readiness figure — but two Mirus Australia polls, before and after the new Act commenced, tell a consistent story: full readiness has stayed a small minority position, and the hurdles are stacking rather than shrinking.
Self-assessed readiness for the new audit model
Share of organisations, by how prepared they said they were. Two separate Mirus Australia polls.
April 2026 — six months after commencement · 200 organisations
Very prepared — 17%Somewhat prepared — 76%Underprepared / not ready for a site visit — 7%
October 2025 — just before commencement · 230 organisations
Fully prepared — 3%Well prepared, minor gaps — 48%Significant work required — 44%Limited preparation / unprepared — 5%
Other findings from the same research:
67% named "all of the above" as their biggest hurdle — documentation, continuous improvement, complaints management and daily care expectations arriving at once. Of those naming one hurdle, documentation and continuous improvement (11%) and interpreting what "good" means under the new Standards (10%) led.
Only 9% felt very confident in their total compliance.
Governance and compliance was the area most at risk of unintended consequences (28%), and regulatory compliance readiness the single most challenging preparation area (31%) — both squarely AECT territory.
Only 5% believed government and regulators were strongly ready to support providers; 64% called that support "patchy or unclear".
"Nearly eight in ten providers haven't yet had an audit under the new model, and three-quarters are openly telling us they still have work to do going into their first one. That's not a confidence problem, it's a readiness problem."
— Tyler Fisher, Head of Data and Insights, Mirus Australia (via HelloCare, 28 April 2026)
Sector data Mirus Australia polls reported by HelloCare and Australian Ageing Agenda. Self-assessed readiness for the new regulatory model generally — not AECT completion specifically.
How the renewal audit unfolds
Renewal invitations can arrive anywhere from 6 to 18 months before your registration expires. Audits are announced and run in three stages — and the workbooks are due in stage one, before anyone visits.
1
Initiation
The Commission emails the audit type, the AECT with key documentation to submit, and — for each home — a separate request to complete a CDECT. It also asks who from your governing body and senior management will attend meetings. The AECT deadline is the date in that email — there is no standard public timeframe.
2
Delivery
Two parts. The provider audit reviews and analyses your AECT and meets your governing body on governance, clinical quality and staffing. The home audits then test, through interviews, observations and file reviews, whether those systems are embedded and consistently applied.
3
Reporting
A preliminary conformance rating per Outcome, a closing meeting, then the final report — which goes to the provider and the registration team. Audit reports inform the decision to register you, and whether conditions apply.
The "golden thread" assessors followSector framing — Anchor Excellence
Policy — AECTHead office submits its central systems and processes.
→
Practice — CDECTEach home submits local data proving the policy is in use there.
→
Proof — Site auditA nurse interviewed on the floor describes a process that matches the policy.
A break anywhere in that chain is the pathway to non-conformance. The framing is a consultant's model, not the Commission's wording — but it matches how the Commission describes its own test: whether AECT-described systems are embedded and effective in practice.
Inside the workbooks
The Commission describes the tools at a high level in public; the detailed structure below comes from a sector webinar presented with Commission representatives, and is labelled as such. Sector detail
The AECT is an Excel-style workbook: a guidance tab, a Supporting Document List — described as the master list of 48 policy, procedure and evidence document types, each mapped to the Standards and Outcomes it evidences — and then one worksheet per Quality Standard, with an outcome-by-outcome response grid. Each worksheet opens with that Standard's intent and its expectation statement for older people.
A residential (Category 6) provider completes all seven Standards:
1The Individual2The Organisation3The Care and Services4The Environment5Clinical Care6Food and Nutrition7The Residential Community
Every Outcome response needs four kinds of evidence — plus the document numbers from the Supporting Document List that back it:
1 · Systems and processes
What you have established and implemented to meet this Outcome — the policy and the machinery behind it.
2 · Review and monitor
How you check it is working, across every location and service. This is the column providers most often leave thin — and conformance, on the Commission's own definition, requires evidence of checking, not just doing.
3 · Practice examples
A specific, real example of your system improving care for an older person. Generic examples are a named weakness in AECT responses.
4 · Innovation
How contemporary, evidence-based practice has driven continuous improvement for this Outcome.
Treat the AECT as a genuine self-assessment in your own words — the pattern of a conformant response is policy → practice → evidence. Source: NATSIFACP Support Hub webinar, 12 August 2026, presented with ACQSC representatives listed as contributors. Sector detail
The CDECT–Residential collects evidence about the residential care home: how the provider's systems and processes are used at that service, so the Commission can judge whether they are consistently applied across homes. Sector advisers describe it as the "lived experience" tool — structured, service-level data that auditors analyse to test whether the central AECT narrative is true in practice. A home's local falls data proving the provider's falls policy is in use is the classic example.
What is confirmed:
Renewal audits only; once for each Category 6 service; every Category 6 home is audited (unlike Categories 4/5, where a sample of locations is used).
The Commission sends a separate email before each home's audit, reviews the completed CDECT, and holds an online opening meeting before the visit, a brief entry meeting on arrival, and a closing meeting at the end of on-site activity for that home.
One consultant source warns that day-of-audit records may be requested for production within one hour — a consultant claim, not verified in Commission material.
Not published The item-by-item contents of the CDECT–Residential workbook — its sections and fields — are not public. No public copy was found in this research, and there is no verified basis for claiming the CDECT itself asks for care-minute data or restrictive-practice consent records. Those are evidence types assessors may test on site and through other reporting — they should not be attributed to the CDECT.
Where providers fall short
The failure mode is rarely a missing policy. It is inconsistency — a claim in the AECT that the CDECT data, the roster, or a staff member's answer doesn't support. These are the gaps named in sector and Commission-adjacent sources.
"We have a policy" — and nothing after it
Responses that describe a policy existing but not how it is implemented or reviewed in practice. On the Commission's definitions, conformance means a system that is set up, applied, monitored and continuously improved — a policy alone answers only the first of those.
The missing "review and monitor" column
No internal audits, file audits, survey results, incident or complaint trend data attached to the Outcome. Conformance needs evidence of checking, not just doing — and this is the column most often left empty.
Evidence that doesn't match itself
Document numbers in the response that don't match the document actually attached, or titles recorded differently across Outcomes. An evidence-mapping failure reads to an assessor as a system nobody owns.
Generic practice examples
Textbook descriptions instead of a specific, real example — a named situation, a changed care plan, a measurable result. Assessors compare the example against the home's records; an invented-sounding one damages the credibility of everything around it.
Governance documentation
Standard 2 sits in every AECT, and governance was the top risk area (28%) in the October 2025 poll. A Commission prudential review reported in Bulletin #9-2026 found only 4 of 25 Support at Home providers fully compliant, with undocumented and out-of-date systems among the examples — a different program, but the same documentation discipline the AECT tests.
Data that doesn't reconcile
Service-level numbers are now cross-checked. As of June 2025, 40% of residential providers were not meeting targets for both total and RN care minutes (Ageing Australia) — and from 2026 the Care Minutes Performance Statement faces mandatory external audit, with the first audited statement due with the 2025–26 ACFR by 31 October 2026. That audit is a separate process from the AECT/CDECT, but it is exactly the kind of data a site audit can test against AECT workforce claims.
Getting ready — before the email arrives
Because the deadline is set in your individual initiation email and the Commission publishes no standard turnaround, the only safe strategy is to be substantially done before the invitation lands. The Commission itself sanctions the method: the AECT and CDECT can be used outside an audit for ongoing improvement (Bulletin #77), and it publishes a pre-audit readiness checklist, renewal audit guides and an Evidence Mapping Framework showing how conformance will be assessed.
Build your evidence register on the Supporting Document List
Assemble the policies, procedures and evidence documents for every Outcome. Record each document's exact title — and the page number where the evidence sits inside a larger document. Keep numbering and titles identical everywhere they are referenced.
Draft every Outcome response now — all four columns
Systems and processes; review and monitor; one specific, real practice example; innovation. Use the actions in the Commission's Evidence Mapping Framework as your evidence prompt for each Outcome.
Assemble monitoring evidence, not just policies
Internal audit results, file audits, satisfaction surveys, incident and complaint trends, continuous improvement records — the proof for the "review and monitor" column, for every Outcome.
Get every home CDECT-ready
A CDECT is required per home and every Category 6 home is visited. Local data and records showing each provider system in use in that home — retrievable quickly on audit day, not reconstructed the night before.
Prepare your governance layer
Identify the governing-body and senior-management representatives the Commission will ask for, and have board-level evidence of oversight of quality, clinical governance and risk ready to table.
Run a mock audit — and train for the interviews
Complete one Outcome fully before drafting the rest; have a colleague read responses as an auditor would — would they understand your systems from the response alone? Then prepare staff: assessors test the AECT narrative against what workers say, in rights-based language, on the floor.
Reconcile your data before assessors do
The Commission cross-references provider data — quality indicators, SIRS, staffing. Reconcile rosters, timesheets and payroll against care-minute claims; verify AHPRA registrations; align position descriptions with the direct-care roles you claim.
Don't wait for the step-by-step guide
The Commission's new AECT renewal guide (Bulletin #9-2026) explains how to complete each section — but it travels with the initiation email. A provider that hasn't been initiated may not hold a copy. Start assembling evidence without it; use it to polish, not to begin.
What's at stake
The tools are not administrative. Their outputs feed the graded assessment, your Star Ratings, and the registration decision itself. Commission rules
Scenario
Confirmed consequence
AECT not submitted by the deadline in your initiation email
"We can't do the audit without it." The Commission can withdraw your application. If renewal fails, registration expires at the end of the registration period and the provider cannot deliver funded aged care services.
Evidence shows gaps — not systemic, low risk
Minor non-conformance. The Commission monitors and works more closely with you until issues are fixed in a lasting way. The home's Star Ratings Compliance rating is capped at 2 stars (it can reach 3 once resolved).
AECT claims not borne out on site — systemic or high-risk gaps
Major non-conformance. Closer supervision; Compliance rating of 1 star. The audit informs the registration decision — possible conditions on registration and/or a shorter registration period (the default under the Aged Care Act 2024, s115, is 3 years).
Conformant on every Outcome and Standard
Conformance. Category 6 providers in renewal audits may then be invited to submit evidence for an Exceeding rating — excelling in active partnerships, in governance and clinical governance, and in the dining experience. All three criteria must be met.
Audit ratings are published and shown on the Find a provider tool via My Aged Care. Graded assessments roll out at registration renewal over the first three years from 1 November 2025.
What could not be verified
Honest gaps in the public record, as at 19 October 2026. Anything a consultant quotes on these points is going beyond published Commission material.
No fixed AECT deadline exists in public. No Commission page, bulletin or guide extract states a number of days or weeks to return the AECT. The rule is "by the deadline in your initiation email" — treat any standard timeframe quoted to you with caution.
The step-by-step guide itself was not opened. Its existence, purpose, distribution (sent with the AECT in the initiation email) and provider feedback survey are confirmed via Bulletin #9-2026; its detailed contents are not public beyond that.
The CDECT workbook's contents are not public. Purpose, frequency and timing are confirmed; its sections and fields are not. Claims that it requests specific data types (care minutes, restrictive-practice consents) are unverified.
No Commission readiness statistic exists. Every percentage on this page is a sector poll (Mirus Australia) based on self-assessment — there is no regulator-published "% of providers ready" figure.
Restrictive-practices consent records are a plausible audit-risk area under Standards 1 and 3, but no source was found naming them as a documented AECT/CDECT failure. Presented here as an open question, not evidence.
Sources
All pages read 19 October 2026. Commission material is labelled as rules; sector material is labelled as commentary or data wherever it is used above.
