SIRS Reporting in Aged Care: A Complete Guide for Australian Providers
Compliance
March 9, 2026
Why regulated care providers must move beyond audit cycles and build real-time compliance systems.
The Serious Incident Response Scheme (SIRS) is one of the most consequential compliance obligations for Australian aged care providers. Introduced in response to the Royal Commission into Aged Care Quality and Safety, SIRS requires providers to identify, record, report, and manage serious incidents — with strict deadlines and detailed documentation requirements.
Since 1 November 2025, SIRS has expanded to cover home care and flexible care services alongside residential care. If you're an aged care provider of any kind, SIRS compliance is no longer optional — and the penalties for non-compliance are significant.
This guide covers everything you need to know.
What Is SIRS and Why Does It Exist?
The Serious Incident Response Scheme was established under the Aged Care Act to improve the safety of older Australians receiving aged care. It requires approved providers to:
Have a serious incident management system in place
Identify and record all serious incidents
Report reportable incidents to the Aged Care Quality and Safety Commission (ACQSC) within specified timeframes
Manage and resolve serious incidents, including root cause analysis and corrective actions
The scheme was born out of the Royal Commission's findings that serious incidents in aged care — including abuse, neglect, and unexplained deaths — were going unreported and unaddressed. SIRS puts a legal framework around incident management and holds providers accountable.
What Counts as a Reportable Incident?
Under SIRS, the following 8 categories of incidents must be reported to the ACQSC if they occur in connection with the provision of aged care:
Unreasonable use of force — pushing, hitting, kicking, rough handling of a consumer
Unlawful sexual contact or inappropriate sexual conduct
Psychological or emotional abuse — intimidation, humiliation, threats, verbal abuse
Unexpected death — a death that is not expected as an outcome of a diagnosed illness or condition
Stealing or financial coercion — by a staff member or another consumer
Neglect — failure to provide adequate care, nutrition, hydration, or medical attention
Inappropriate use of restrictive practices — chemical, physical, mechanical, environmental restraint, or seclusion used without proper authorisation
Missing consumers — an absent consumer where there is concern for their safety
Important: An incident is reportable regardless of who caused it — staff, another consumer, a visitor, or a family member. The test is whether it happened "in connection with" the provision of care.
Reporting Deadlines: Priority 1 vs Priority 2
SIRS classifies reportable incidents into two priority levels with different reporting deadlines:
Priority 1 — Report within 24 hours
An incident is Priority 1 if it:
Has caused or is causing a significant impact on a consumer
Involves the death or serious injury of a consumer
Involves sexual contact or assault
Requires emergency services or hospitalisation
Involves a missing consumer who has not been found
Priority 2 — Report within 30 days
All other reportable incidents that don't meet the Priority 1 threshold. These are typically lower-severity incidents, or incidents where the consumer's safety is not at immediate risk.
The clock starts when you become aware of the incident — not when the investigation is complete. Many providers get caught out here. You must submit the initial report within the deadline, even if your investigation is still ongoing. You can update the report later with additional findings.
Reports are submitted through the My Aged Care provider portal. The Commission has a SIRS decision support tool on their website that helps you determine whether an incident is reportable and its priority level.
Documentation Requirements
For each serious incident (reportable or not), providers must document:
Details of the incident — what happened, when, where, who was involved
Immediate actions taken — first aid, medical attention, securing the consumer's safety
Notifications made — to family, police, ACQSC, other authorities as required
Investigation findings — witness statements, evidence collected, timeline of events
Root cause analysis — what systemic factors contributed to the incident?
Corrective actions — what changes will be made to prevent recurrence?
Follow-up and review — were the corrective actions effective?
This documentation must be retained and available for auditors. The ACQSC expects to see not just individual incident records but also trend analysis — are you tracking incident types over time? Are certain units or shifts seeing more incidents? Are your corrective actions actually reducing incidents?
This is where most providers struggle. Individual incident forms are manageable; building a system that enables trend analysis and continuous improvement requires proper tooling.
Common SIRS Compliance Mistakes
Based on ACQSC compliance data and industry experience, here are the most common mistakes providers make:
1. Under-reporting. The most common issue. Staff don't recognise an incident as reportable, or there's a culture of "handling things internally." The ACQSC has been clear: under-reporting is taken very seriously and can result in sanctions.
2. Missing the 24-hour deadline. Priority 1 incidents require reporting within 24 hours of the provider becoming aware. Weekends, public holidays, and overnight incidents don't change the deadline. You need a system that alerts the right person immediately.
3. Incomplete root cause analysis. Writing "staff error" as the root cause is not acceptable. The Commission expects a genuine analysis of systemic factors — staffing levels, training gaps, environmental hazards, communication breakdowns.
4. No trend analysis. If you've had 15 falls in the same corridor over 3 months and your records don't show you've identified and acted on this pattern, that's a compliance failure.
5. Paper-based systems. Handwritten incident forms get lost, can't be searched, and make trend analysis impossible. The volume and complexity of SIRS documentation is pushing the industry toward digital solutions.
6. Treating SIRS as just reporting. SIRS requires a full incident management SYSTEM — not just a reporting process. This includes prevention, identification, management, reporting, and review. The reporting is just one element.
How Willow Helps With SIRS Compliance
Willow's compliance workspace includes purpose-built SIRS management features:
Automatic deadline tracking. When an incident is logged, Willow automatically classifies its priority level and tracks the reporting deadline — with escalation alerts to ensure nothing is missed.
Structured documentation. Guided incident recording ensures all required fields are captured — from initial details through to root cause analysis and corrective actions.
Trend analysis and dashboards. Willow automatically analyses incident data across your organisation — by type, location, time, severity — so you can identify patterns and demonstrate continuous improvement to auditors.
Audit-ready reporting. Generate SIRS compliance reports at the click of a button, showing your full incident management lifecycle for any time period.
Integration with your existing systems. Willow pulls data from your clinical care, rostering, and HR systems to build a complete picture — no double entry required.
SIRS compliance doesn't have to be a constant source of anxiety. With the right system in place, it becomes a structured, manageable process that actually improves the quality of care you deliver.
Book a 20-minute demo to see how Willow handles SIRS management.
Written by
James Driscoll
Writer
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