RTO Marketing Compliance: The Complete Guide Under the 2025 Standards

Last Updated: May 2026 · By Ehtisham Saeed, RTO Marketing Specialist

Marketing without compliance is just expensive risk management for someone else’s audit.

Here is the deal: the regulatory ground moved under every Australian RTO on 1 July 2025. Most marketing agencies have not noticed. Most RTO websites have not updated. Most compliance consultants do not understand marketing well enough to flag the gap. See also: RTO Marketing Channels: How to Choose the Right Mix in 2026 (The 5-Pillar Method, Pillar 3).

That gap is now your single biggest commercial risk.

I’ll be direct about this. Across 200 RTO websites recently audited via the RTO Scanner, 83 percent had at least one prohibited phrase live on the page. Phrases that breach the Information and Transparency Practice Guide. Phrases that would not pass an ASQA performance assessment. Phrases your competitors are also using, which is why nobody flagged them.

This guide closes that gap.

In this pillar, you will get the complete framework for RTO marketing compliance under the 2025 Standards. What changed. What ASQA actually reviews. The prohibited phrases. The third-party trap. The CEO’s personal liability under the 2026 Annual Declaration on Compliance. And why compliance is the foundation every other marketing layer depends on. See also: How Australian RTOs Are Actually Winning in 2026.

Let us get into it.

What Is RTO Marketing Compliance and Why It Changed in 2025

RTO marketing compliance is the discipline of producing, distributing, and maintaining marketing materials that meet the legal and regulatory obligations placed on Australian Registered Training Organisations. It covers your website, ads, social media, email, brochures, broker materials, and anything else that promotes a training product on your scope of registration. See also: How to Differentiate Your Training Organisation in 2026.

The framework changed on 1 July 2025. That is the date the Standards for RTOs 2025 came into full regulatory effect. The 2015 Standards were retired. Clause 4.1, which governed marketing for the previous decade, is no longer the operative provision. If your marketing policy still cites Clause 4.1, your policy is out of date.

The 2025 Standards are not a single document. They are three separate components, and marketing rules sit inside one of them. See also: RTO Marketing KPIs: The 8 Numbers Every Australian Training Organisation Must Track in 2026 (Pillar 4).

The three components are the Outcome Standards, the Compliance Requirements, and the Credential Policy. Marketing-specific provisions live in the Compliance Requirements, Part 2, Division 1, Information and Transparency. That is where ASQA looks first when assessing your marketing.

The shift is not cosmetic. The 2015 Standards asked process questions. Did you have a marketing review policy? Did you have a checklist? The 2025 Standards ask outcome questions. Does your marketing accurately reflect demonstrable student outcomes? Can your students prove they understood what they enrolled in? That is a meaningfully harder bar.

The shift also reframes who is liable. Under the 2015 framework, marketing breaches were treated as administrative non-compliance. Under the 2025 framework, marketing accuracy is part of self-assurance, which the CEO must personally declare to ASQA every year.

For a broader definitional foundation, read What Is RTO Marketing. This pillar builds on that base by going deep on the compliance layer specifically.

The commercial context matters too. NCVER data shows 925,600 students enrolled in nationally recognised qualifications January to September 2025, a 6.9 percent decline year on year for government-funded RTO enrolments. The pie is shifting. Fee-Free TAFE under DEWR has reshaped price expectations across whole qualification categories. Private RTOs that grow in this environment are the ones whose marketing accurately and confidently differentiates against TAFE without breaching the Information and Transparency Practice Guide. The RTOs that struggle are the ones whose marketing was written before 1 July 2025 and now carries hidden compliance liability while the market gets harder.

Why Generic Marketing Agencies Are Now Exposed

Most Australian marketing agencies do not specialise in regulated industries. They built playbooks for ecommerce, real estate, professional services, generic education. They do not know what the National Register is. They do not know what an RTO code does. They have never heard of the Information and Transparency Practice Guide. They cannot tell you the difference between a training product on scope and one that has been superseded.

That ignorance was tolerated under the old Standards because Clause 4.1 was forgiving. It is not tolerated under the 2025 Standards. ASQA now reviews your live website during performance assessments. They check social media. They look at the Google Ads ad copy. They cross-reference everything against your scope on training.gov.au.

If the agency you hired wrote your course pages without understanding the National Register, you are about to find out what that costs.

Why Pure Compliance Consultants Miss the Other Half

The mirror image is also true. Pure compliance consultants understand the Standards. They know the legislation. They have read every Practice Guide.

What they cannot do is write a course page that converts. They cannot run a Google Ads campaign that returns positive ROAS. They cannot build a lead nurture sequence that turns a Facebook click into an enrolled student. The compliance vocabulary is fluent. The marketing vocabulary is not.

The result is that most Australian RTOs end up with two parallel systems that do not talk to each other. The marketing team produces material that converts but breaches the Standards. The compliance team rewrites it into something that meets the Standards but does not convert. Neither side wins. The student suffers either way.

This is the gap. Compliance is the foundation everything else stands on. Marketing is the structure that grows enrolments. They are not separate disciplines. They are the same discipline practised by people who understand both.

The Three Documents That Define RTO Marketing Compliance Today

Before you can audit your marketing, you need to know which document governs which question. Most RTOs do not. They quote the wrong source, cite the wrong clause, or worse, rely on agency advice that references the 2015 framework that no longer applies.

Here is the structure that matters for marketing.

Document 1: The Outcome Standards (Quality Expectations)

The Outcome Standards define what quality looks like across training, assessment, governance, and student support. Marketing-relevant content here is mostly indirect. The Outcome Standards establish the principle that students must make informed enrolment decisions, which is what your marketing is supposed to enable.

Key Outcome Standard for marketing context: students must be supported to choose appropriate training products. Your marketing is the front door of that choice.

The legal authority is the National Vocational Education and Training Regulator (Outcome Standards for Registered Training Organisations) Instrument 2025, available on the Federal Register of Legislation.

Document 2: The Compliance Requirements (Operational Obligations)

This is where marketing rules actually live. Specifically, Part 2, Division 1, Information and Transparency.

The Compliance Requirements are the operational rulebook. They cover information management, marketing and advertising, AQF certification, NRT logo conditions of use, third-party arrangements, the Annual Declaration on Compliance, prepaid fee protection, and public liability insurance.

The marketing-specific clauses are the ones I will reference repeatedly throughout this pillar. They tell you what must appear on every advertisement, what must not appear, how third parties are handled, and what evidence ASQA expects you to retain.

The legal authority is the National Vocational Education and Training Regulator (Compliance Standards for NVR Registered Training Organisations and Fit and Proper Person Requirements) Instrument 2025, also on the Federal Register of Legislation.

Document 3: The Credential Policy (Trainer and Assessor Qualifications)

The Credential Policy specifies the qualifications trainers, assessors, and validators must hold. It is mostly outside the scope of marketing compliance, but it intersects in one important place.

Your marketing cannot promote training delivered by someone who does not hold the required credential. If your website features a trainer profile, the trainer must actually be qualified to deliver the units listed on that page. Mismatch is a compliance breach. See also: The 4 RTO Buyer Types: Who Actually Enrols in Australian Vocational Training (Pillar 2).

The Credential Policy lives on the National Training Register at training.gov.au.

The Practice Guide That Sits On Top of All Three

ASQA also publishes Practice Guides alongside the Standards. These are not legislation. They are ASQA’s interpretation of how providers should meet the Standards.

The single most important Practice Guide for marketing is the Information and Transparency Practice Guide. It is what ASQA assessors actually read during performance assessments. If you read only one document on this list, read that one. We cover it in detail in the next section.

Quick check before you keep reading: pull up your current RTO marketing policy. Does it cite the 2025 Standards or the 2015 Standards? Does it reference the Information and Transparency Practice Guide? Does it list the Compliance Requirements Part 2 Division 1? If the answer to any of those is no, your policy is out of date and your marketing is exposed.

The Information and Transparency Practice Guide: What ASQA Actually Reads

The Information and Transparency Practice Guide is the operational document ASQA assessors use to interpret the Compliance Requirements during performance assessments. Most RTO operators have never read it. Most marketing agencies have never heard of it.

Read it. Then read it again with your website open in another tab. You will find at least three things to fix in the first ten minutes.

The Practice Guide is structured into three main parts: Requirements, Risks to Mitigate, and Self-Assurance Questions. Plus example activities ASQA considers acceptable evidence of compliance.

The Marketing Requirements Verbatim

Pulled directly from the Information and Transparency Practice Guide. These are the requirements you are measured against.

An NVR registered training organisation must ensure any advertisements or marketing materials published or disseminated by the organisation, a third party, or an expert engaged by the organisation:

• Include the organisation’s registration code or a link to the part of the National Register where the organisation’s registration code is located.
• Where the advertisements or marketing materials refer to the organisation’s services, accurately represent those services, including by distinguishing the types of training and assessment that will result in the issuance of AQF certification documentation from any other training and assessment delivered by the organisation or a third party.

Where the advertisements or marketing materials refer to a training product, the RTO must ensure they:

• Include the code and title of the training product as published on the National Register.
• Accurately represent the training products on the organisation’s scope of registration.
• Only refer to a training product that is no longer current while it remains on the organisation’s scope of registration and new enrolments are permitted.
• Only represent that completion of a training product will lead to a licensed or regulated outcome where this has been confirmed by the relevant industry regulator.

Where advertisements or marketing materials refer to services that an RTO has engaged an expert or third party to deliver, the organisation must ensure the advertisements or marketing materials identify which services will be delivered by the expert or third party.

That is the rulebook. Five paragraphs. Most RTOs cannot show me a current ad that meets all five.

The Seven Self-Assurance Questions ASQA Expects You to Answer

This is the part nobody talks about. The Practice Guide does not just give you requirements. It tells you what questions ASQA wants answered. If your CEO cannot answer these seven questions during an opening meeting, you are already losing the assessment.

1. How do you ensure that marketing and advertising materials are quality assured against the Compliance Requirements before being distributed?
2. How will you maintain evidence of all your RTO’s marketing and advertising materials if copies are requested by ASQA?
3. Do you offer any training that is not nationally recognised? If yes, how are you distinguishing between that training and Nationally Recognised Training in your advertising?
4. How are you ensuring students are fully informed of any funding arrangements associated with their training, and any associated conditions?
5. How often are you checking your advertising and marketing materials to ensure they remain accurate and current? How do you ensure your third parties dispose of outdated materials when new ones are produced?
6. Are you offering licensed or regulated courses? If yes, how do you ensure that your staff only represent that completion of a training product will lead to a licensed or regulated outcome where this has been confirmed by the relevant industry regulator?
7. Where financial support arrangements are available, how do you ensure that the marketing and advertising of those arrangements is clearly stipulated?

Print these seven questions. Hand them to your CEO. Watch what happens. Most CEOs cannot answer more than three from memory. That is the gap ASQA is now testing for.

The Risks the Practice Guide Flags Explicitly

The Practice Guide also flags risks ASQA expects you to mitigate. The two biggest:

Failing to ensure that your advertising and marketing content complies with Australian Consumer Law. Marketing compliance is not just ASQA. The ACL applies to every Australian business, and it prohibits misleading or deceptive conduct. We cover this in detail in Section 4.

Making verbal or written guarantees that a VET student can complete a training product in a manner inconsistent with section 185 instrument requirements, or will obtain a particular employment outcome where obtaining such an employment outcome is not within the organisation’s control. This is the prohibited phrase clause that catches more RTOs than any other. We unpack it next.

The Prohibited Phrases and Misleading Claims That Get RTOs Deregistered

Across the 200 RTO websites I have personally audited via the RTO Scanner, 83 percent had at least one phrase that would fail ASQA review. Most of them did not know. Their marketing agency wrote the copy. The compliance manager never reviewed the website. The CEO assumed someone was checking.

Nobody was.

The prohibited phrases fall into five categories. I’ll cover each one and give you what to remove and what to use instead.

Category 1: Employment Outcome Guarantees

This is the single largest source of marketing breaches in Australian RTO content.

The Practice Guide is explicit: an RTO must not guarantee that a student will obtain a particular employment outcome where obtaining such an employment outcome is not within the organisation’s control. Almost all employment outcomes are not within an RTO’s control. You do not employ the graduate. The employer does. You do not control the labour market. Industry does.

Phrases to remove from your website immediately:

• “Guaranteed employment after completion.”
• “100 percent job placement.”
• “Get your dream job in [industry].”
• “We guarantee you will be employed.”
• “Become a [job title] in 6 months.”
• “Our graduates always find work.”

Phrases that are compliant:

• “This qualification prepares students for roles in [industry].”
• “Recent graduates have moved into roles such as [examples].”
• “Students have reported positive employment outcomes after completion.” (Only if you have evidence on file.)
• “This course aligns with industry roles in [sector].”

The principle: describe what the qualification prepares students for. Do not promise an outcome you do not control.

Category 2: Course Completion Guarantees

The second prohibited guarantee category. RTOs must not represent that a training product can be completed in a manner inconsistent with the requirements set out in the section 185 instrument. In plain English: you cannot promise students a faster, easier, or watered-down version of the qualification than the training package allows.

Phrases that breach:

• “Complete your Cert IV in 3 weeks.”
• “Fast-track your qualification.”
• “Get qualified in record time.”
• “Self-paced, finish in days.”
• “Easy assessment, no exams.”

If your training product has minimum volume of learning requirements set in the training package, your marketing cannot suggest those requirements can be skipped. Self-paced is allowed. Self-paced over a period shorter than the training package allows is not.

Category 3: Funding and Fee Claims

This category has multiplied since Fee-Free TAFE arrived. Many RTOs ran rapid funding-related campaigns without checking whether their language matched the funding contracts they signed.

Phrases that breach:

• “Free training” without disclosing eligibility conditions.
• “Government-funded course” without specifying which funding body and which program.
• “$0 upfront” without disclosing the actual fee structure.
• “Skills First funded” on courses that are not on your funding contract.
• “Smart and Skilled approved” without confirming current contract status.

The compliant approach: name the funding program (Skills First, Smart and Skilled, Certificate 3 Guarantee, Jobs and Skills WA, Free TAFE), state the eligibility conditions, and provide a clear path to the official program website. The Practice Guide explicitly requires you to disclose any funding arrangements and associated conditions clearly.

Category 4: Course and Qualification Claims

The trap here is using shortened or marketing-friendly versions of qualification titles. The Practice Guide requires you to use the code and title of the training product as published on the National Register. That is the full official title. Not the marketing version.

Phrases that breach:

• “Cert III Aged Care” instead of the full title CHC33021 Certificate III in Individual Support.
• “Diploma of Business” without the code and current version.
• “Forklift Licence Course” instead of the relevant unit code and title.
• References to superseded training products that are no longer accepting new enrolments.

The compliant approach: use the full National Register title and code on every page. You can use plain-language descriptions in marketing copy, but the official code and title must appear. For deeper coverage of training.gov.au listing requirements, read Training.gov.au Listing Optimisation.

Category 5: Licensing and Regulated Outcomes

The fifth prohibited category. The Practice Guide says you can only represent that completion will lead to a licensed or regulated outcome where this has been confirmed by the relevant industry regulator. Confirmed in writing, on file, retrievable.

Phrases that breach:

• “This course gets you your forklift licence” without WorkSafe confirmation.
• “Become a registered nurse” for a course that is not AHPRA-aligned.
• “Obtain your White Card” without confirming the issuer accepts your delivery.
• “This qualification leads to your real estate licence” without state authority confirmation.

Licensing rules vary by state, by industry, by year. The compliant approach is to state the qualification prepares students to apply for the relevant licence, and to direct prospective students to the issuing authority for current eligibility requirements. Never promise a licence you cannot directly issue.

The Australian Consumer Law Layer Most Agencies Miss

Marketing compliance is not just ASQA. The Australian Consumer Law applies to every commercial promotion in this country. ASQA does not enforce the ACL. The ACCC does. But ACL breaches in your marketing can also surface as ASQA findings under the Compliance Requirements.

The ACL prohibits misleading or deceptive conduct in trade or commerce. Your marketing is trade. Your enrolment promises are commerce. If your messaging would mislead a reasonable prospective student, you have an ACL exposure regardless of what the Standards say.

The Spam Act adds another layer. Email and SMS to prospective students requires consent, unsubscribe options, and accurate sender identification. RTOs that buy lead lists or send broadcast SMS without proper consent are exposed twice: ASQA via marketing accuracy, ACCC via the Spam Act.

The compliant approach is treating ACL and Spam Act compliance as part of the same review process you run for ASQA compliance. They are different regulators measuring overlapping conduct. One review, three frameworks. For deeper compliance monitoring guidance, read ASQA Marketing Compliance Monitoring.

What Must Appear on Every Piece of RTO Marketing Material

The Practice Guide gives you a checklist. Every piece of marketing material must include these elements. Not most. Not when convenient. Every piece. Every time.

Let me walk through each one with the compliant pattern and the typical breach pattern.

Element 1: Your RTO Code

Every advertisement must include your RTO registration code or a link to your listing on the National Register. The code is the primary identifier ASQA uses to verify everything else you claim.

Compliant: “Provider Code 12345” or “RTO 12345” displayed in the footer of every page, every brochure, every ad creative.

Common breach: brochures and Facebook ads that omit the code entirely. Course pages that bury the code in a privacy policy. Vehicle wraps and event signage with no code visible.

The fix is structural. The RTO code goes in your website footer template, your email signature template, your ad creative templates, your brochure templates. Not added per piece. Built into the template so it cannot be omitted.

Element 2: The Training Product Code AND Title

Where you reference a specific training product, the full code and title from the National Register must appear. Both. Not the code alone. Not the title alone. Both.

Compliant: “BSB50420 Diploma of Leadership and Management” displayed clearly on the course page.

Common breach: marketing pages that use only the marketing-friendly name. “Leadership Diploma” or “Diploma of Leadership” without the code. Or worse, references to superseded versions like “BSB51918” that no longer accept new enrolments.

The fix is checking your scope on training.gov.au quarterly and updating any superseded codes immediately. Many breaches are not bad faith. They are stale content. Set a quarterly review cadence and they disappear.

Element 3: Scope Alignment

Your marketing must accurately represent training products on your scope of registration. You cannot market what you cannot deliver. You cannot imply you deliver what is not on your scope.

Compliant: a course catalogue that matches your training.gov.au scope exactly, with each course pointing to the official code.

Common breach: showing courses on your homepage that are no longer on scope. Listing future courses you plan to add but have not yet been approved for. Marketing CRICOS courses without CRICOS approval. Marketing higher education products without TEQSA registration.

The fix is a quarterly scope reconciliation. Pull your current scope from training.gov.au. Pull your current website course catalogue. Compare. Remove anything off scope. Add disclaimers to anything pending approval.

Element 4: Distinguishing Nationally Recognised From Non-Accredited Training

If you offer both nationally recognised training and other types of training (short courses, induction programs, custom training that does not result in AQF certification), your marketing must clearly distinguish the two.

Compliant: a clear page section labelled “Nationally Recognised Training” with the NRT logo correctly applied, and a separate section for “Short Courses” or “Custom Training” without the NRT logo.

Common breach: applying the NRT logo to a generic “Training Programs” page that mixes accredited and non-accredited content. Using the logo on social media posts that promote a non-accredited webinar. Including the logo in an email about a corporate workshop.

The fix is structural separation. Different page templates for accredited versus non-accredited. Different ad campaigns. Different email lists where appropriate. The NRT logo only appears next to AQF certification-eligible products. For the full NRT logo rules, read NRT Logo Conditions of Use.

Element 5: Third-Party Identification

Where the advertisement promotes services delivered by an expert or third party, the marketing must identify which services that expert or third party will deliver.

This is one of the most-breached requirements I see. RTOs hide third-party arrangements behind generic language. “Our team delivers.” “Our experienced trainers.” “Our partner network.” None of that satisfies the Practice Guide if the work is actually being done by another party.

Compliant: “This program is delivered in partnership with [Partner Name]. [Partner Name] provides [specific services]. [Your RTO] retains responsibility for assessment and AQF certification.”

Common breach: silence about the third-party arrangement entirely. Co-branded marketing where the partner appears equal to the RTO without role separation. Broker marketing in the broker’s name with no RTO identification.

We cover this in detail in Section 6 because the third-party trap is the single biggest deregistration risk in 2025.

Element 6: Funding and Fee Disclosure

Where financial support arrangements are available, the marketing must clearly stipulate the arrangement, eligibility conditions, debts students will incur, and how those debts will be repaid.

Compliant: a funding section that names the program (Skills First, Smart and Skilled, Free TAFE), lists eligibility criteria, states whether co-contribution applies, and links to the official program page.

Common breach: “Government funded” or “Subsidised training” without naming the program. “Free training for eligible students” without explaining eligibility. Hidden fees disclosed only at enrolment.

The fix is treating funding disclosure like a privacy policy. Build it once, link to it from every relevant course page, update it quarterly when programs change. Do not rely on individual pages remembering to mention funding rules.

Element 7: Consent for Individuals Featured

Where your marketing includes named individuals (testimonials, case studies, student photos, trainer profiles, employer endorsements), you must have prior consent on file. The Practice Guide expects you to retain evidence of that consent.

Compliant: signed consent forms or recorded video releases on file for every named or photographed individual. Consent specifying scope (which materials, which platforms, which duration). Consent renewable for major republications.

Common breach: testimonials repurposed from old emails without explicit marketing consent. Stock photos labelled as students. Video footage from events used in ads without participant consent.

The fix is a consent management workflow. Built into your enrolment process or your testimonial collection process. No consent on file means the testimonial does not run. No exceptions.

The Third-Party Marketing Trap: How Brokers Can Deregister Your RTO

The 2025 Standards changed third-party arrangements more substantially than any other area of marketing compliance. Most agencies have not understood the change. Most RTOs are still operating under the 2015 framework.

I’ll be direct about this: the third-party marketing trap is the single biggest deregistration risk facing Australian RTOs in 2026.

What Changed in 2025

Under the 2015 Standards, third-party arrangements were treated as a contractual matter. You signed an agreement with the broker. You filed it with ASQA. You moved on. As long as the broker was technically authorised, marketing breaches by the broker were treated as administrative issues.

Under the 2025 Standards, that approach no longer works.

The 2025 framework treats third-party marketing as a transparency obligation. The written agreement is not just a contractual instrument. It is the blueprint ASQA uses during a performance assessment to understand the arrangement. The agreement must operationalise transparency, not just authorise the partner.

The phrase “we have a contract” is now insufficient. ASQA wants to see whether the contract has actually operationalised transparency, whether the parties do what the contract says, and whether the RTO can show that students received and understood the disclosures the contract requires.

That is a meaningfully different bar.

What a Compliant Third-Party Agreement Looks Like Now

The agreement must describe scope. Specifically: which services the third party will deliver (training, assessment, marketing, recruitment), where the RTO’s responsibility begins and ends, and how branding boundaries work.

The agreement must oblige the third party to use only RTO-approved marketing artefacts. The third party cannot improvise. They cannot add their own claims. They cannot run their own ads in their own name promoting your RTO’s training.

The agreement must commit both parties to inform students in writing about role separation. Students must know which entity is the RTO, which entity is delivering, and which entity is issuing the AQF certification. That communication must happen in writing, before enrolment, with retention of evidence.

The agreement must allocate recordkeeping responsibilities and specify that all AQF certification is issued by the RTO. The third party cannot issue testamurs. The third party cannot put their name on the certification. Even if they delivered the training. Even if they assessed the student.

The agreement must reference withdrawal rights where marketing breaches occur. If the broker promotes the training in a way that breaches the Practice Guide, the RTO must have the contractual right to suspend the arrangement immediately. Not at the next renewal. Immediately.

The agreement must align to the RTO’s risk and continuous improvement system. Partner performance must feed RTO governance. The RTO cannot say “the broker handled it” if the broker breached the Standards. The RTO is always accountable.

The 30-Day Notification Rule

The Compliance Requirements include an obligation to notify ASQA of third-party arrangements within 30 days of entering them. The 30 days runs from the agreement date, not the marketing launch date.

This catches RTOs that signed agreements years ago and never notified ASQA. It also catches RTOs that have informal recruitment arrangements they have not treated as third-party agreements. If a person or entity is recruiting students on your behalf, in exchange for any commercial benefit, that is a third-party arrangement. It needs to be in writing. It needs to be notified.

Co-Branding and Brand Boundaries

Old practice tolerated ambiguous co-branding. Your RTO logo and the partner logo side by side, no role separation, no clear identification of who issues the AQF certification.

The 2025 framework reverses the presumption. Branding and documentation now exist to make the RTO’s legal accountability unmistakable. Any arrangement that risks confusion must be redesigned or documented to remove doubt.

Practical rule: if a prospective student looking at the marketing material cannot tell within five seconds which entity is the RTO and which entity is the third party, the material breaches transparency.

This applies to:

• Co-branded brochures and flyers
• Joint websites or co-hosted course pages
• Shared Facebook or Instagram pages
• Email campaigns sent from the partner’s domain
• Event signage and banner displays
• YouTube channels and video content

Why the RTO Always Carries the Risk

The most important point in this section. Under the 2025 Standards, the RTO is always accountable for marketing breaches by third parties. There is no broker defence. There is no “the agency did it” defence.

If the broker runs a Google Ad with a prohibited employment guarantee, ASQA holds the RTO accountable. If the agent promotes a superseded course code, ASQA holds the RTO accountable. If the partner forgets to use the NRT logo correctly, ASQA holds the RTO accountable.

This means the RTO needs systems to monitor partner marketing in real time. Not at quarterly review. Real time. The RTO Scanner can scan partner websites the same way it scans your own. The same prohibited phrases. The same compliance checks. Run partner sites quarterly at minimum.

Self-Assurance: The 2025 Continuous Compliance Expectation

Self-assurance is the single biggest cultural change the 2025 Standards introduced. It is also the change most Australian RTOs have not adjusted to.

Under the 2015 framework, compliance was reactive. ASQA notified you of an upcoming audit. You scrambled to prepare. You produced evidence. You were assessed. You returned to operations until the next audit.

Under the 2025 framework, compliance is continuous. The CEO must declare every March that the RTO has monitored its own compliance throughout the year. Not just when ASQA asked. Throughout the year. Every year.

What Self-Assurance Means in Practice for Marketing

Three operational shifts.

First, ongoing review cadence. Marketing compliance is not a once-a-year sweep. It is a quarterly review minimum. Monthly is better. The Practice Guide explicitly asks how often you check your advertising and marketing materials to ensure they remain accurate and current.

If your answer is “annually” or “before audits”, you are not self-assuring. You are reactive.

Second, documented evidence trail. Self-assurance must be evidenced. The CEO cannot just claim it. There must be artefacts: review logs, screenshot archives, partner audit reports, scope reconciliation records, prohibited phrase scans.

If ASQA asks during a performance assessment “show me how you have monitored marketing compliance over the past 12 months”, you need a folder. Not a story. A folder.

Third, corrective action documentation. When you find a breach during self-review, you must document the finding, the corrective action, and verification that the action worked. This is the loop that proves self-assurance is real.

Found a prohibited phrase on a course page? Document it. Removed the phrase? Document it. Verified the page is now compliant? Document that too. The audit trail is what makes the system defensible.

The Quarterly Review Cadence That Works

The simplest pattern that meets the Practice Guide expectations:

• Monthly: spot-check 2-3 active marketing pieces against the Practice Guide checklist. New ads, new course pages, new social posts. Document the review.
• Quarterly: full website audit using the RTO Scanner or equivalent. Cross-reference against current scope on training.gov.au. Verify NRT logo usage. Check funding disclosures. Document the audit.
• Quarterly: third-party partner audit. Same checks applied to partner websites and ads.
• Annually: full marketing compliance review. Policy refresh. Training for marketing and compliance teams. CEO sign-off on Annual Declaration on Compliance evidence.

For deeper coverage of monitoring systems, read ASQA Marketing Compliance Monitoring. For the broader framing of compliance as the foundation of marketing strategy, read The RTO Compliance Marketing Layer in the 5-Pillar RTO Marketing Method.

The 2026 Annual Declaration on Compliance: The CEO’s Personal Liability

The 2026 Annual Declaration on Compliance was the first full reporting cycle under the 2025 Standards. The submission window ran from 3 March 2026 to 31 March 2026. ASQA emailed every RTO CEO a unique weblink. The CEO had four weeks to declare.

If you missed it, this is what you missed. And what you face again in March 2027.

What the CEO Actually Declares

The Annual Declaration on Compliance is a formal statement under Clause 15 of the Compliance Requirements. It can only be completed by the person legally responsible for the RTO’s registration. The listed CEO. Not the compliance manager. Not the marketing director. The CEO.

The CEO declares that the RTO has monitored its own compliance with the National Vocational Education and Training Regulator Act 2011, the Outcome Standards, and the Compliance Requirements. For 2026 specifically, the CEO declared compliance with the 2025 Standards because they took effect on 1 July 2025.

The declaration is a personal statement. The CEO is personally signing that the RTO is compliant. Not the company. The person.

Why Marketing Compliance Sits Inside This Declaration

The Compliance Requirements include the marketing rules in Part 2, Division 1, Information and Transparency. The CEO’s declaration covers compliance with the entire Compliance Requirements document. Marketing is in there.

If the CEO declares compliance and the RTO is later found to have ongoing marketing breaches, the declaration becomes evidence in the regulatory matter. The CEO declared compliance. The compliance was not real. That is a more serious finding than a marketing breach alone.

This is why marketing compliance has moved from a marketing team concern to a CEO concern. The personal declaration changes the accountability structure.

The Evidence File the CEO Should Have Before Signing

Practical rule: never sign the Annual Declaration on Compliance without an evidence file. The file should include, at minimum, the marketing-related artefacts:

• Most recent quarterly marketing audit reports.
• RTO Scanner reports or equivalent compliance scans.
• Partner marketing audit reports for the past 12 months.
• Records of any marketing breaches identified and corrected.
• Updated marketing compliance policy citing the 2025 Standards.
• Evidence of staff training on the Information and Transparency Practice Guide.
• Consent records for any named individuals in current marketing.
• Scope reconciliation report against current training.gov.au listings.

If the file is empty, the declaration is risky. If the file is incomplete, the declaration is risky. The CEO needs the evidence ready before signing.

What Happens If You Miss the Declaration

Late submissions are not accepted. ASQA states this explicitly. Missing the 31 March deadline can lead to regulatory action, including conditions on registration, sanctions, and in serious cases cancellation.

The declaration is not optional administrative housekeeping. It is part of the regulatory framework. RTOs that did not submit by 31 March 2026 are now classified as a higher risk in ASQA’s assessment model.

For the 2027 cycle, the operational rule is simple: prepare the evidence file by 31 January. Conduct the final marketing review by 15 February. Submit between 3 March and 15 March. Build a buffer. Do not approach the deadline.

What ASQA Actually Reviews During Performance Assessments

Most RTOs prepare for performance assessments by tidying up training and assessment files. They review TASs. They run validation sessions. They check trainer credentials. They forget that ASQA is also reviewing their public marketing the entire time.

Here is what ASQA actually does, based on the Q1 2025-26 Regulation Report and the published assessment process.

The Real Scale of ASQA Activity

The Q1 2025-26 Regulation Report shows ASQA completed 28 site visits and 82 performance assessments in a single quarter. Of those 82 performance assessments, 30 resulted in a finding of non-compliance. That is 37 percent.

Read that again. More than one in three performance assessments under the 2025 Standards resulted in a non-compliance finding.

The same quarterly report shows ASQA made decisions to cancel more than 7,500 qualifications and statements of attainment issued by critically non-compliant providers. Since late 2025, more than 36,000 students have received letters of intent to cancel their qualifications. More than 33,000 cancellations have been executed.

This is not the regulator from five years ago. The current regulator cancels qualifications. The current regulator deregisters providers. The current regulator publishes the data quarterly.

The Terminology Shift Most People Have Missed

Performance assessment outcomes are no longer described as “compliant” or “non-compliant”. The March 2026 ASQA Update introduced new language. Outcomes are now described as “Meets Requirements” or “Does Not Meet Requirements”.

The shift is not just cosmetic. It reflects the move to outcome-based assessment. ASQA is no longer asking if you ticked the box. ASQA is asking if you delivered the outcome the Standards require.

Performance monitoring activity, which is a softer touch ASQA may use without conducting a full performance assessment, does not result in a decision. Only performance assessments produce a “Meets Requirements” or “Does Not Meet Requirements” outcome.

The Website and Social Media Review You Cannot See

This is the part most RTOs do not realise is happening. ASQA reviews your website and social media before the on-site visit, during the assessment, and after.

The pre-assessment review is desk-based. The assessor pulls your website, your scope, your last published declaration, your training.gov.au listing, your social media profiles. They build a picture of your public-facing claims before they ever speak to you.

By the time the opening meeting happens, the assessor already has a list of things to verify. Course pages. Scope alignment. NRT logo usage. Third-party identification. Funding claims. Testimonial consent.

The during-assessment review continues. Auditors revisit pages they flagged. They check whether marketing claims match the evidence in student files. They cross-reference completion timeframes promised in marketing against actual student progression in the SMS.

The post-assessment review is part of monitoring. ASQA can revisit your website any time. Performance monitoring activities can be triggered by complaints, tip-offs, or anomalies in your declaration. Marketing material is the easiest evidence for a regulator to access without your knowledge.

The 2025-26 Risk Priorities That Affect Marketing

ASQA published six Regulatory Risk Priorities for 2025-26. Three of them have direct marketing implications.

Too-short learning. ASQA is targeting compressed delivery that does not plausibly produce competence. If your marketing promises a Diploma in three weeks, that is a flag. Marketing claims about course duration are now triangulated against actual student progression evidence.

Compromised assessment integrity, including AI. ASQA explicitly named AI-generated content and assessment integrity as a 2025-26 priority. RTOs using AI in marketing claims, AI-generated testimonials, or AI tools that produce assessment evidence are exposed. Revised Practice Guides addressing AI specifically are expected mid-2026.

Exploitative international recruitment. CRICOS-heavy providers are being triangulated against risk indicators using marketing, recruitment, and attendance data. Three industry verticals are under particular scrutiny: ECEC, Aviation, and high-risk work. If you operate in those verticals, expect tighter assessment scrutiny and more aggressive marketing review.

These risk priorities are not aspirational. They guide ASQA’s allocation of assessor resources. Your industry vertical, your delivery model, and your marketing claims all influence the probability of a performance assessment in the next 12 months.

What Happens After a “Does Not Meet Requirements” Finding

The current process from ASQA’s published guidance:

Step one. ASQA issues a non-compliance letter giving you 20 working days to respond. The letter contains an Evidence of Compliance template. You use the template to demonstrate you have rectified the non-compliance.

Step two. If you cannot rectify within 20 working days, you can request to enter an Agreement to Rectify (ATR). The ATR provides additional time for systemic issues. Six ATRs were finalised in Q1 2025-26 alone. Two providers returned to compliance through that process.

Step three. If you cannot rectify or your rectification is inadequate, ASQA may impose sanctions or conditions. Conditions can restrict your scope, restrict new enrolments, or require regular monitoring.

Step four. In serious cases, ASQA may cancel registration. Deregistration is the end. Recovery is rare.

Step five. ASQA may also cancel qualifications already issued by the deregistered provider. This is the cascade impact that affects students. More than 7,500 qualifications cancelled in a single quarter.

The Marketing-Compliance Tension and Why It Sinks Most RTO Campaigns

Here is the deal: most Australian RTOs have a marketing-compliance tension. The marketing team wants growth. The compliance team wants safety. Neither side is wrong. They are speaking different languages about the same problem.

The result is that good marketing campaigns get killed by compliance vetoes. Compliant marketing campaigns underperform because they are designed by people who do not understand how copy actually converts.

This section is the wedge. It is why I built Everyshot. It is why this pillar exists.

The Two Failure Modes

Failure mode one. Marketing-led RTOs produce campaigns that convert beautifully and breach the Standards. The course pages promise outcomes. The ads guarantee employment. The testimonials run without consent. Enrolments climb. Then ASQA arrives and the campaign becomes evidence in a non-compliance finding. Three years of growth get clawed back in a single quarter.

Failure mode two. Compliance-led RTOs produce campaigns that meet the Standards and convert nothing. The course pages read like legal disclaimers. The ads make no promises. The testimonials never get used because consent forms were never built. Enrolments stagnate. The RTO blames the market. The market is fine. The marketing is the problem.

Both failure modes are common. Both are unnecessary.

Why Pure Agencies Cannot Solve This

I’ll be direct. Generic marketing agencies cannot solve the marketing-compliance tension because they do not know what compliance actually requires. They have not read the Information and Transparency Practice Guide. They cannot tell you the difference between a current and a superseded training product. They do not understand third-party arrangements under the 2025 Standards.

What they can do is produce campaigns that perform. So they produce campaigns that perform. The compliance breaches are someone else’s problem until ASQA arrives.

If your agency cannot quote the seven self-assurance questions from the Practice Guide, your agency is exposing you. Not on purpose. They simply do not know what they do not know.

Why Pure Compliance Consultants Cannot Solve This Either

The mirror image. Pure compliance consultants know the Standards inside and out. They have seen every audit. They can recite Clause references in their sleep.

What they cannot do is write a high-converting course page. They cannot structure a Google Ads account that returns 3:1 ROAS on enrolments. They cannot build a lead nurture sequence that recovers enquiries that did not enrol on first contact.

So they do what they know. They write policies. They run training sessions. They produce templates that meet the Standards and never get used because the marketing team does not know how to translate them into actual campaigns.

Two parallel systems. Neither can do the other side’s work.

The Combined Practitioner Lens

The solution is not finding a better marketing agency or a better compliance consultant. The solution is the practitioner lens that combines both.

A combined practitioner can:

• Write a course page that converts AND complies. Because they know the Practice Guide AND they know how prospects actually read course pages.
• Run Google Ads that convert AND comply. Because they know the prohibited phrase categories AND they know how Google Ads quality score works.
• Build email sequences that convert AND comply. Because they know the Spam Act AND they know what subject lines drive open rates.
• Audit partner marketing AND fix it. Because they know third-party arrangement rules AND they know how brokers actually operate.

This is the wedge. It is not a marketing service. It is not a compliance service. It is the integrated practice that makes both work together.

The Decision Framework for Resolving Marketing-Compliance Conflicts

When marketing and compliance disagree on a campaign, the decision framework is three steps.

Step one. Identify which specific Practice Guide requirement, Compliance Requirement clause, or ACL provision the compliance team is concerned about. Be specific. “It might breach” is not enough. Name the rule.

Step two. Test whether the proposed marketing copy actually breaches that specific rule. Most concerns turn out to be about phrasing, not substance. The substance can almost always be expressed in compliant language.

Step three. If the substance genuinely breaches the rule, the campaign cannot run as written. But the underlying marketing intent can still be expressed through different angles, different proofs, different framings.

Example. Marketing wants to claim “100 percent of graduates find work in their field”. Compliance correctly flags this as an employment outcome guarantee outside the RTO’s control. Step three. Restructure to “Graduates have moved into roles such as [specific job titles] at [specific employers, with consent]”. Same conversion intent. Compliant phrasing. Stronger because it is concrete.

This is what the practitioner lens does in practice. It does not kill the marketing. It makes the marketing accurate AND effective.

The Foundation Layer: Why Every Other Marketing Component Depends on Compliance

This pillar opened with a claim. Compliance is the foundation everything else stands on. Without it, every other marketing layer is wasted.

Now I’ll show you specifically what depends on what.

Web Design Without Compliance Is Pointless

You can build the most beautifully designed RTO website in Australia. Optimised page speed. Conversion-tested layouts. Polished video assets. Mobile responsive everywhere.

If the course pages promise employment outcomes, omit the RTO code, mislabel the training products, or hide third-party arrangements, the website fails an ASQA review. The conversion optimisation does not matter. The fast loading does not matter. The mobile-friendly design does not matter.

A non-compliant website is a liability with good UX.

For ASQA-compliant website foundations, read ASQA-Compliant RTO Website. For course page conversion under compliance, read RTO Course Page SEO.

Google Ads Without Compliance Is Subsidising Your Own Audit

Google Ads spend is the most aggressive way an RTO can advertise. It is also the easiest evidence trail for ASQA to access. Every ad you ran is logged. Every landing page you sent traffic to is archived. Every keyword you bid on is recorded.

If your ad copy contains prohibited employment claims, your spend has been documenting those claims. If your landing page omits the RTO code, every paid click is evidence of the breach.

The cost of a non-compliant Google Ads campaign is not just the ad spend. It is also the ASQA exposure that the spend created. RTOs have spent six-figure budgets on campaigns that became the foundation of their non-compliance findings.

SEO Without Compliance Is Building Authority on Liability

SEO success means more pages indexed, more search visibility, more organic traffic. If those pages contain non-compliant claims, SEO success means the breach is reaching more people.

The compliance breach is now durable. It is in cached pages. It is in archived content. It is in third-party scraping of your site. The Internet Archive has it. Google’s index has it. Bing has it.

You cannot delete your way out of widespread non-compliance. You can correct it going forward. The historical record stays.

Email Marketing Without Compliance Is Multi-Regulator Exposure

Email marketing involves three regulators simultaneously. ASQA cares about the marketing accuracy. The ACCC cares about misleading conduct under the ACL. The Australian Communications and Media Authority cares about the Spam Act.

One non-compliant email can produce three regulatory complaints. Each regulator can act independently. The fines are cumulative.

For email marketing automation built on compliant foundations, read RTO Email Marketing Automation.

Reputation Management Without Compliance Is Damage Control After the Fact

Online reputation is downstream of compliance. The reviews students leave after enrolment reflect what they were promised before enrolment. If the marketing oversold and the delivery underdelivered, the reviews suffer.

RTOs with poor Google reviews almost always have a marketing-delivery gap somewhere. The marketing promised more than the training delivered. Students felt misled. They left negative reviews.

The fix is not better review management. The fix is aligning marketing claims with delivery reality. Compliant marketing makes accurate promises. Accurate promises produce satisfied students. Satisfied students produce positive reviews.

For deeper coverage, read RTO Reputation Management.

Lead Generation Without Compliance Is Filling Your Pipeline With Risk

Every lead you generate creates a relationship that ASQA can scrutinise later. Every Facebook ad. Every Google Ad. Every SEO landing page. Every direct mail piece.

If the lead generation channel made a non-compliant promise, every enrolled student from that channel becomes potential evidence. The ASQA review will ask: how did the student understand the program before enrolling? What information did they receive? Was that information accurate?

If the answer involves prohibited phrases, the entire lead generation channel becomes exposure. The cost of fixing the lead generation is a fraction of the cost of defending the resulting enrolments.

For compliance-first lead generation, read RTO Lead Generation.

The 5-Pillar RTO Marketing Method Has Compliance as Pillar 5 for a Reason

The framework I use with every Everyshot client, the 5-Pillar RTO Marketing Method by Ehtisham Saeed, places compliance as the fifth pillar deliberately. Not because it is least important. Because it is the foundation that makes the other four work.

The five pillars are Positioning, Audience, Channel Mix, Measurement, and the Compliance Layer. Without the Compliance Layer, the other four pillars build on sand.

For the full method, read How to Build an RTO Marketing Strategy From Scratch. For the Compliance Layer specifically, read The RTO Compliance Marketing Layer.

Where to Go From Here

You have read the foundation. You now know what changed in 2025, what ASQA actually reviews, what the prohibited phrases are, how third-party arrangements work, what self-assurance means, and why the CEO carries personal liability through the Annual Declaration on Compliance.

Three things to do this week.

Step One: Run a Compliance Scan on Your Own Website

The fastest way to see where you stand is to run the RTO Scanner on your own site. The scanner checks for the prohibited phrases I covered in Section 4. It checks for missing RTO codes. It checks for scope misalignment. It returns a compliance score and specific recommendations within five minutes.

Free. No login required for the basic scan. If you want to know whether the 83 percent statistic from earlier in this pillar applies to your RTO, run the scan.

Step Two: Read the Six Supporting Posts in This Cluster

This pillar is the head of a content cluster. The supporting posts go deeper on each topic.

• The Information and Transparency Practice Guide explained in plain English.
• The complete prohibited phrases list with regulatory basis and safer alternatives.
• The marketing compliance checklist for self-audit.
• Third-party marketing arrangements and the deregistration risk.
• The marketing-compliance decision framework.
• AI in RTO marketing and the 2026 compliance frontier.

These will publish progressively over the coming weeks. Each one extends a section of this pillar with the operational depth you need to act.

Step Three: Talk to a Practitioner Who Combines Both Disciplines

If your RTO has a marketing-compliance tension, an agency that does not understand the Standards, a compliance team that does not understand marketing, or both, the path forward is the combined practitioner lens.

That is what Everyshot does. RTO marketing built on the 2025 Standards. Compliance not as a constraint but as the foundation. Marketing strategy, website design, Google Ads, SEO, lead generation, email automation, all integrated with the Information and Transparency Practice Guide.

For a compliance-aware marketing strategy review, see RTO Marketing Strategy. For a full digital infrastructure assessment that scores your website, SEO, content, social, and lead generation against the 2025 Standards, see RTO Digital Infrastructure Scorecard.

Compliance is the foundation. Marketing is the structure. The 2025 Standards changed the foundation. If your structure is built for the old framework, the structure is unstable. The fix is rebuilding from the foundation up. That is the work this pillar exists to support.

Frequently Asked Questions About RTO Marketing Compliance

What is RTO marketing compliance under the 2025 Standards?

RTO marketing compliance is the discipline of producing and maintaining marketing materials that meet the Standards for RTOs 2025, the Information and Transparency Practice Guide, the Australian Consumer Law, and the Spam Act. It covers websites, ads, social media, email, brochures, and third-party marketing. The 2025 Standards came into full effect on 1 July 2025, replacing the 2015 Standards and Clause 4.1. Marketing rules now sit in the Compliance Requirements, Part 2, Division 1, Information and Transparency.

When did the 2025 Standards take effect for marketing?

The Standards for RTOs 2025 took full regulatory effect on 1 July 2025. Marketing-specific obligations are part of the Compliance Requirements component. The Information and Transparency Practice Guide was published alongside the Standards to support providers in understanding ASQA’s regulatory expectations. Any RTO marketing policy still citing Clause 4.1 of the 2015 Standards is out of date.

What are the prohibited phrases in RTO marketing?

The Practice Guide prohibits guarantees that a student will obtain a particular employment outcome where that outcome is not within the RTO’s control, and guarantees that a training product can be completed in a manner inconsistent with the section 185 instrument. In practice this rules out phrases such as guaranteed employment, 100 percent job placement, fast-track your qualification, complete in 3 weeks, and similar. Funding claims like free training without disclosing eligibility, and licensing claims without industry regulator confirmation, are also prohibited.

Does ASQA review my website before a performance assessment?

Yes. ASQA conducts a desk-based review of your website, social media, scope on training.gov.au, and previous Annual Declarations on Compliance before the on-site visit. Public-facing marketing material is the easiest evidence for the regulator to access without needing your cooperation. Assessors arrive at the opening meeting with a list of marketing claims to verify against your training and assessment files.

What happens if my RTO marketing fails an ASQA performance assessment?

ASQA issues a non-compliance letter giving you 20 working days to respond using the Evidence of Compliance template. For systemic issues you can request an Agreement to Rectify for additional time. If rectification is inadequate, ASQA can impose conditions or sanctions on registration. In serious cases, ASQA can cancel registration entirely and cancel qualifications already issued. The Q1 2025-26 Regulation Report shows ASQA cancelled more than 7,500 qualifications in a single quarter.

Who is responsible if a third-party broker breaches marketing rules?

The RTO. Under the 2025 Standards, the RTO is always accountable for marketing breaches by third parties. There is no broker defence. The written agreement must operationalise transparency, oblige the partner to use only RTO-approved marketing artefacts, and give the RTO withdrawal rights if breaches occur. RTOs must monitor partner marketing in real time, not just at quarterly reviews. The RTO must notify ASQA of third-party arrangements within 30 days of entering them.

What is the Information and Transparency Practice Guide?

The Information and Transparency Practice Guide is the operational document ASQA assessors use to interpret the Compliance Requirements during performance assessments. It is not legislation. It is ASQA’s published interpretation of how providers should meet the Standards. It contains the marketing requirements, the risks ASQA expects providers to mitigate, the seven self-assurance questions, and example activities ASQA considers acceptable evidence of compliance. Every RTO compliance manager and marketing manager should read it.

How often do I need to audit my marketing for compliance?

The Practice Guide explicitly asks how often you check your advertising and marketing materials to ensure they remain accurate and current. Annual review is not enough under the 2025 Standards. The minimum cadence that meets self-assurance expectations is monthly spot-checks plus quarterly full audits. New ads, new course pages, and new campaigns should be reviewed before publication. Partner marketing should be audited quarterly using the same checks applied to your own marketing.

What is self-assurance under the 2025 Standards?

Self-assurance is the 2025 framework’s shift from reactive compliance to continuous compliance. RTOs must actively monitor their own compliance throughout the year, document the monitoring, document any breaches found, and document the corrective actions taken. The CEO declares ongoing self-assurance every March via the Annual Declaration on Compliance. Self-assurance must be evidenced. Claims of compliance without supporting artefacts are not acceptable.

What does the CEO actually declare in the Annual Declaration on Compliance?

The CEO declares that the RTO has monitored its own compliance with the National Vocational Education and Training Regulator Act 2011, the Outcome Standards, and the Compliance Requirements. The declaration is a personal statement made by the person legally responsible for the RTO’s registration. It cannot be delegated to a compliance manager. The 2026 declaration was the first full reporting cycle under the 2025 Standards. The submission window runs from 3 March to 31 March each year. Late submissions are not accepted.