Q: Can A Cert 3 Open and Close With Someone Who Is Working Towards Their Qualification

A: Under the National Quality Framework (NQF), every time a centre-based early childhood service is open—whether at opening, throughout the day, or at closing—there must be at least one Responsible Person physically present and on duty.

 Who Can Be a Responsible Person?

Regulation 118 of the Education and Care Services National Regulations specifies that a Responsible Person must be one of the following:

1. Hold an approved early childhood teaching qualification (ECT)
2. Hold an approved Diploma level qualification in early childhood education and care
3. Hold an approved Certificate III level qualification in early childhood education and care
4. Be actively working towards one of the above qualifications, provided they:

• Are enrolled in an ACECQA-approved course,
• Can supply documented evidence of commencement and satisfactory progress, and
• Are meeting the course’s enrolment requirements.

Applying This to Opening and Closing

• If you’re a Certificate III qualified educator, you can be the Responsible Person at opening and closing (and throughout the day), provided you’re the only one nominated on shift or the others present also meet one of the four criteria above.

• If your colleague is actively working towards their Certificate III qualification (or higher), they can also count as a Responsible Person so long as they maintain enrolment and progress evidence (e.g., transcripts, letters from the training organisation).

Practical Steps for Compliance

1. Nominate at least one Responsible Person per shift in your staff roster.
2. Ensure each person nominated holds, or is actively working towards, an ACECQA‐approved ECT, Diploma or Certificate III.
3. Keep up-to-date staff records showing qualifications and “actively working towards” evidence (e.g., enrollment confirmation, progress reports).
4. Review documentation each study period (semester or trimester) to confirm ongoing progress.
5. If a colleague defers their study, obtain formal written evidence of satisfactory progress and enrolment maintenance.

Can A Responsible Person Change On A Day to Day Basis

Yes, the Responsible Person can vary each day—or even each shift—so long as there is always at least one person on duty who meets the National Quality Framework requirements (Approved Provider, Person with Management or Control, Nominated Supervisor, or suitably qualified person in day-to-day charge).

How to Manage Daily Changes

• Nominate and roster a Responsible Person for every opening, shift change, and closing period.
• Ensure each person:
  • Is over 18 years old and holds (or is working towards) an ACECQA-approved qualification, AND
  • Has consented in writing to act as Responsible Person.
• Display the name (and photo, if used) of the current Responsible Person at the main entrance immediately upon any change.
• Document each handover:
  • Record date, time, outgoing and incoming responsible persons in your staff register or a dedicated responsible person register.
  • Keep a signed log or digital entry to demonstrate continuity of supervision.

Does a Responsible Person Need to Be Registered?

Under the Education and Care Services National Law and Regulations, there is no separate “registration” process for a Responsible Person in the way that services register with ACECQA. Instead, the key obligations are:

• An Approved Provider must nominate and obtain written consent from each Responsible Person (Approved Provider, Nominated Supervisor or Person in Day-to-Day Charge).
• Nominated Supervisors must be formally notified to the regulatory authority via the NQA IT System within the specified timeframes (at least 7 days before they start, or within 14 days afterwards).
• All Responsible Persons must be listed in an onsite Responsible Person Register and their names displayed at the service entrance during operating hours.

Roles and Notification Requirements

Keeping Compliant Records

• Maintain a Responsible Person Register that logs each person’s name, qualification status, consent and the exact times they’re on duty.
• Display the name and position of the current Responsible Person at the main entrance so families and authorities can easily verify compliance.
• For Nominated Supervisors, ensure you upload any changes through the NQA IT system within the required timeframe.

Key Takeaways

• A Certificate III educator can open/close the service as a Responsible Person alongside someone working towards their Cert III (or higher).
• “Actively working towards” counts for Responsible Person duties—just be diligent in collecting and updating evidence.
• Proper record keeping and naming of Responsible Person(s) on rosters ensure you meet Regulation 118 at all times.
• There is no standalone ACECQA “responsible person registration.”
• You must nominate and obtain written consent, keep internal records, and display the Responsible Person on duty.
• Only Nominated Supervisors require formal notification to the regulatory authority

Reference:
Responsible Person Requirements For Approved Providers, ACECQA