Restrictive Practices Compliance in Aged Care and NDIS: What Providers Must Get Right
Compliance
March 29, 2026
Why regulated care providers must move beyond audit cycles and build real-time compliance systems.
Few compliance areas carry as much regulatory weight — or as much potential for harm — as the use of restrictive practices. Under both the strengthened Aged Care Quality Standards and the NDIS Practice Standards, providers face increasingly rigorous obligations around authorisation, documentation, reporting, and reduction of restrictive practices. With the Aged Care Quality and Safety Commission and the NDIS Quality and Safeguards Commission both intensifying their focus on this area, getting it wrong means more than a compliance gap — it means failing the people in your care. This guide breaks down what providers across both sectors need to know to meet their obligations and, more importantly, to genuinely protect participants' and residents' rights.
What Counts as a Restrictive Practice?
A restrictive practice is any practice or intervention that restricts the rights or freedom of movement of a person. Both the aged care and NDIS frameworks recognise five core categories:
Chemical restraint — Use of medication to control behaviour, rather than to treat a diagnosed condition. This includes PRN psychotropic medications used primarily for behavioural management.
Physical restraint — Any physical or mechanical device that restricts a person's movement. Bedrails, lap belts, and secured wheelchair trays all fall into this category.
Mechanical restraint — A subset sometimes distinguished from physical restraint, involving devices specifically designed to restrict movement (e.g., posey vests, limb restraints).
Environmental restraint — Restricting a person's free access to all parts of their environment, including locked doors, fenced areas, or removal of personal items.
Seclusion — Confining a person alone in a room or area from which they cannot freely exit.
The critical point for providers is that many restrictive practices happen inadvertently. A locked garden gate, a recliner chair a resident cannot independently exit, or a sedating medication prescribed 'as needed' without a behaviour support plan — these are all potential restrictive practices that require formal authorisation and oversight.
The Regulatory Framework: Aged Care
Under the new Aged Care Act and the strengthened ACQS, restrictive practices are governed with far more specificity than under the previous standards. Key obligations include:
Prior authorisation — Restrictive practices must be authorised by an appropriate decision-maker, with informed consent from the resident or their representative wherever possible.
Behaviour support plans — Any ongoing use of restrictive practices must be supported by a comprehensive, individualised behaviour support plan developed by a qualified practitioner.
SIRS reporting — Unlawful or unauthorised use of restrictive practices is a reportable incident under the Serious Incident Response Scheme. Providers must report within 24 hours of becoming aware.
Regular review — Authorised restrictive practices must be reviewed at least every 12 months (many providers opt for quarterly reviews as best practice).
Reduction and elimination — Providers must demonstrate they are actively working to reduce and eliminate the use of restrictive practices over time. Maintaining the status quo is not acceptable.
The Commission has made it clear through recent compliance actions that paper-based authorisations sitting in a filing cabinet are not sufficient. Providers need to demonstrate an active, living system of oversight.
The Regulatory Framework: NDIS
For NDIS providers delivering behaviour support or supporting participants with complex needs, the obligations are equally stringent — and in some areas, more prescriptive. State and territory legislation adds additional layers.
Regulated restrictive practices — The NDIS Quality and Safeguards Commission requires that all regulated restrictive practices be authorised under the relevant state or territory legislation before they are used.
Behaviour support practitioners — Only practitioners who meet the Commission's capability framework can develop behaviour support plans that include restrictive practices. The practitioner must be deemed suitable by the Commission.
Lodgement of behaviour support plans — Plans containing restrictive practices must be lodged with the Commission. Interim plans must be lodged within one month, and comprehensive plans within six months of commencing support.
Monthly reporting — Providers must submit monthly reports to the Commission on the use of regulated restrictive practices, including any unauthorised use.
Reportable incidents — Unauthorised use of a restrictive practice is a reportable incident, with strict notification timeframes.
Providers operating across both aged care and NDIS face a dual compliance burden, as the frameworks differ in their terminology, authorisation pathways, and reporting obligations. This is one of the most common areas where cross-sector providers come unstuck.
Where Providers Commonly Fall Short
Based on Commission enforcement actions and audit findings, several patterns emerge consistently:
Chemical restraint blind spots — PRN psychotropic medications prescribed without a current behaviour support plan, or without documented evidence that non-pharmacological interventions were tried first.
Environmental restraints not recognised — Locked dementia units, restricted access to kitchens, or removal of call bells are sometimes not identified as restrictive practices at all.
Expired authorisations — Authorisation was obtained initially but has lapsed, and the practice continues without valid, current authorisation.
No evidence of reduction efforts — The practice has been in place for months or years with no documented attempts to trial alternatives or reduce its use.
Poor staff understanding — Frontline staff do not understand what constitutes a restrictive practice, leading to unauthorised use that goes unreported.
Inconsistent documentation — Records are spread across clinical notes, incident reports, behaviour support plans, and medication charts with no consolidated view of a resident's or participant's restrictive practice profile.
The common thread? Fragmented systems and a lack of visibility. When authorisation documents live in one system, behaviour support plans in another, and incident reports in a third, it's almost impossible to maintain a complete, current picture.
Building a Compliant Restrictive Practices Framework
A robust approach to restrictive practices compliance requires more than policies — it requires operational systems that keep pace with real-time care delivery. Here's what best-practice looks like:
Centralised register — Maintain a single, up-to-date register of all restrictive practices currently in use, linked to the relevant authorisation, behaviour support plan, and review schedule.
Automated review reminders — Don't rely on staff memory or calendar entries. Build systematic alerts that flag when authorisations are approaching expiry or reviews are overdue.
Prescriber engagement — Work closely with GPs and psychiatrists to ensure chemical restraint is prescribed in line with best practice, with regular medication reviews and clear documentation of clinical rationale.
Staff education — Ensure every staff member — not just clinical leads — can identify a restrictive practice and knows the reporting pathway. Scenario-based training is far more effective than policy-reading exercises.
Reduction plans — For every authorised restrictive practice, document a clear plan for trialling alternatives and reducing or eliminating the practice. Review progress at governance meetings.
Governance reporting — Include restrictive practices data in board and management reporting, including trends over time, new authorisations, expired authorisations, and incidents of unauthorised use.
Technology plays an important role here. When authorisations, behaviour support plans, incident reports, and review schedules are connected in a single compliance workspace, providers gain the visibility they need to stay on top of obligations without relying on manual tracking.
Chemical Restraint: The Area of Greatest Scrutiny
If there is one area where regulators are applying the most pressure, it's chemical restraint. Australia's Royal Commission into Aged Care Quality and Safety was scathing about the overuse of psychotropic medications in aged care, and the regulatory response has been sustained.
Key expectations providers must meet:
Psychotropic medications must not be used as a first-line response to behavioural and psychological symptoms of dementia (BPSD). Non-pharmacological interventions must be documented and trialled first.
Where psychotropic medication is prescribed for behavioural management, it must be supported by a current behaviour support plan and authorised as a restrictive practice.
Medication reviews must occur at least annually (best practice is six-monthly) to assess ongoing need and appropriateness.
PRN administrations must be documented with the specific behaviour observed, the rationale for administering, and the outcome.
Providers should be auditing their psychotropic medication use proactively. A quarterly review of all residents on PRN psychotropics — cross-referenced against behaviour support plans and authorisations — is one of the most impactful compliance activities you can undertake.
Cross-Sector Providers: Managing Dual Obligations
Providers who operate across both aged care and NDIS face a unique challenge: the two regulatory frameworks use different terminology, different authorisation pathways, and different reporting obligations for what is fundamentally the same issue.
Practical tips for cross-sector providers:
Map the differences — Create a clear comparison document that shows the authorisation requirements, reporting timeframes, and documentation obligations under each framework. Train staff on both.
Use the stricter standard — Where requirements differ, default to the more rigorous obligation. This simplifies compliance and reduces risk.
Consolidate where possible — Use a single system for tracking restrictive practices across both service types, with framework-specific fields where needed. Separate systems create gaps.
Align governance — Ensure your clinical governance committee or quality team has oversight of restrictive practices across both aged care and NDIS services, with consolidated reporting.
This is an area where compliance technology can genuinely reduce burden. Manually maintaining parallel tracking systems for two regulatory frameworks is resource-intensive and error-prone. A unified compliance workspace that understands the requirements of both frameworks — and alerts you to obligations under each — is far more sustainable.
Getting Started: A Practical Checklist
If you're looking to strengthen your restrictive practices compliance, here's where to start:
Audit your current state — Identify every restrictive practice currently in use across your organisation. Include environmental and chemical restraints that may not be formally recognised.
Check authorisations — For every practice identified, confirm there is a current, valid authorisation in place. Flag any that have expired or were never obtained.
Review behaviour support plans — Ensure every person subject to a restrictive practice has a current, individualised behaviour support plan developed by a qualified practitioner.
Assess your documentation — Can you produce a complete picture of any individual's restrictive practice profile in under five minutes? If not, your systems need work.
Train your team — Run scenario-based training sessions that help staff identify restrictive practices they may not have previously recognised.
Set up governance reporting — Ensure restrictive practices data is a standing item on your governance meeting agenda, with trend reporting over time.
Plan for reduction — Document specific, measurable strategies for reducing each authorised restrictive practice, and review progress regularly.
Restrictive practices compliance isn't a set-and-forget exercise. It requires ongoing vigilance, systematic oversight, and a genuine commitment to rights-based care. The providers who get this right aren't just ticking regulatory boxes — they're delivering better outcomes for the people they support.
Written by
James Driscoll
Writer
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