Outside School Hours Care (OSHC) compliance: what's actually required

Outside School Hours Care (OSHC) is one of the most misunderstood corners of the childcare sector when it comes to compliance. Many people assume that because OSHC is an approved education and care service under the National Quality Framework, it carries the same qualification rules as long day care or preschool. It does not. OSHC sits in its own regulatory pocket: no national qualification requirement for educators, but the full weight of Working With Children Check, child-protection and first aid obligations still applies, layered with state-specific rules that vary widely.

For services and the people who work in them, that combination is a genuine trap. It is easy to over-focus on qualifications that may not be required, while under-managing the screening and training obligations that absolutely are. This guide untangles the patchwork.

Why OSHC sits in its own category

OSHC services that are approved under Family Assistance Law are generally approved as centre based day care under the National Law. That means they are regulated education and care services, administered by the regulatory authority in each state and territory under the same National Law and National Regulations framework as other approved services. The National Quality Framework covers OSHC alongside long day care, family day care and preschool.

The difference shows up in qualifications. There is no national qualification requirement for educators caring for school age children in OSHC services. ACECQA confirms this directly. That single fact drives most of the confusion: the National Quality Framework applies, but the qualification mechanism that defines centre-based ECEC roles simply is not switched on at the national level for OSHC.

The qualification patchwork by state

Because there is no national rule, states and territories fill the gap differently. This is where careful checking matters.

• No qualification requirement: NSW and Tasmania set no qualification requirement for educators in OSHC services.
• State-specific requirements: Other jurisdictions impose their own. In South Australia, for example, from 10 May 2024 the educator required to meet the ratio for children over preschool age must hold an ACECQA approved diploma qualification or equivalent, or a higher qualification, from the ACECQA OSHC qualifications list, with additional qualified educators able to hold a Certificate III or equivalent, or higher, in a relevant field.

The practical takeaway: do not assume a Certificate III or Diploma is mandatory, and do not assume nothing is required either. The only safe approach is to confirm the rule for your specific state or territory with the relevant regulator before you hire or roster someone into a qualified position.

What is required everywhere: screening and child protection

Regardless of qualification rules, every OSHC service carries the same non-negotiable safeguarding obligations.

• Working With Children Check: Everyone working or volunteering in an OSHC service must hold a current, valid Working With Children Check from their state or territory screening authority. Checks are state-based, named differently across jurisdictions, and verified through different portals, with national Working With Children Check reform underway to improve consistency between them. See Working With Children Check by state for the jurisdiction-by-jurisdiction detail. Working With Children Check assessments consider the holder's relevant criminal history as part of the check, but the relationship to a standalone police check varies by jurisdiction: Victoria, for example, treats the Working With Children Check and a police check as separate. Confirm your state or territory's requirement before deciding whether a separate police check is needed in an OSHC setting.
• Child protection training, in two layers: like the rest of the sector, OSHC staff complete the federal Foundations of Child Safety training, and in some states a state-specific child protection course on top, for example VIC PROTECT (Early Childhood Sector) in Victoria or Keeping Children and Young People Safe in the ACT. The state training is in addition to the federal training, not instead of it, and several courses must be refreshed periodically.
• First aid and CPR: OSHC services have first aid, CPR, anaphylaxis and asthma emergency obligations consistent with education and care settings. ACECQA accepts either First Aid for Education and Care (HLTAID012) plus CPR (HLTAID009), or general First Aid (HLTAID011) plus CPR (HLTAID009) plus separate Anaphylaxis Management and Emergency Asthma Management. Currency dates matter: CPR in particular needs frequent renewal. See First aid and CPR requirements for care workers.

These obligations apply to casuals, relief educators and volunteers, not just permanent staff. A relief educator covering a single afternoon session still needs a valid Working With Children Check and the required training in place.

The register layer

OSHC also intersects with the national early childhood worker register reforms reshaping the childcare sector. Educators and services need to understand how OSHC workers fit into register obligations, including what gets recorded and where it is lodged. For the full picture of how the register works and what it asks of services, see the national early childhood worker register explained.

Why OSHC compliance is hard to manage

Pulling the threads together, an OSHC service is juggling:

• A qualification rule that may or may not exist depending on the state, and may differ by role within the service.
• A Working With Children Check obligation that is universal but state-specific in how it is issued, named and confirmed.
• Child protection training in two layers (federal Foundations of Child Safety, plus a state course where one applies) and first aid, each with their own currency dates and renewal cycles.
• A casualised, high-turnover workforce, including relief educators and volunteers, all of whom carry the same screening obligations.
• Register obligations layered on top.

Most services manage this on spreadsheets, which works until a Working With Children Check lapses unnoticed or a relief educator is rostered before their training is current. The risk is not the absence of records: it is records that quietly go out of date.

Authoritative sources

• ACECQA: qualifications for working in OSHC services
• ACECQA: what is the National Quality Framework
• National Office for Child Safety: Working With Children Check reform

How Koora helps

Koora is a Career Passport platform built for the Australian care sector, including childcare and OSHC. A worker's Career Passport carries their checks and credentials in one portable place. Koora verifies Working With Children Checks at source against the relevant state portals, and reviews supporting credentials such as qualifications, first aid and training records. Working With Children Check status is monitored at source, and Koora tracks expiry dates and flags upcoming lapses, so an approaching Working With Children Check or CPR certificate expiry surfaces before it becomes a gap.

Compliance status in Koora is current-state: it shows where a worker stands at the moment the report runs, across the OSHC obligations that actually apply in your jurisdiction. Koora pre-clears credentials so your team starts from a clearer position, but the legal obligation to sight evidence and decide who can work in your service stays with you as the provider. That rigour is the point: convenience that removes the sighting decision would also remove the safeguard.

For services already running other systems, Koora integrates via API and webhooks, and can build a direct integration for a rostering or HR tool such as Deputy or Employment Hero on request, so compliance status can flow alongside the way you already operate. Koora connects alongside the systems you already run, it does not replace them.

OSHC compliance will probably always be a patchwork. Koora's job is to make that patchwork legible, current and portable, so a confusing set of state rules does not turn into a missed renewal.