Transitioning from Clause 1.7 to Outcome 2.2
Clause 1.7 was the shorthand many RTOs used under the 2015 Standards for the duty to identify learner needs before or at entry. Since 1 July 2025, the 2025 Standards are in full effect, and this requirement is now captured primarily under Outcome 2.2 (Pre-enrolment review).
The core mandate has shifted from "identifying support" to performing a "suitability review". Current ASQA guidance says providers must review each prospective student's LLND proficiency and digital literacy in the context of the training product before enrolment or commencement, and decide how that review will be evidenced.
What Evidence Will ASQA Usually Review?
During audit, self-assurance activity, or internal compliance review, ASQA may ask to see:
- A Suitability Review tool that is contextualised to the qualification
- Evidence the tool was administered to each learner (completed assessments, records of administration)
- Evidence of suitability mapping — how did you determine what LLND skill level is required by the qualification?
- Records of identified gaps — which learners had gaps and at what skill level?
- Support provided — what support was offered or arranged for learners with identified gaps?
If these records are thin, inconsistent, or missing across a sample of learners, the provider's position becomes much harder to defend.
Common Failure Patterns
Across RTOs, the recurring risks are usually operational rather than theoretical:
Finding 1: Generic or Untailored Suitability Tools
Using a generic LLND questionnaire that is not mapped to the specific qualification's Performance Criteria. A defensible process reflects the actual suitability demands of the units being delivered.
Finding 2: Assessment Administered but Not Analysed
Many RTOs administer LLN assessments but have no documented process for analysing results or identifying gaps. Collecting a form is not the same as conducting an assessment.
Finding 3: No Evidence of Support
Even where gaps are identified, RTOs often fail to document what support was provided or offered. Evidence of referral to a Learning Support team, adjustment of delivery mode, or additional resources is usually needed.
Finding 4: Review Conducted After Enrolment Commencement
Current ASQA guidance (Outcome 2.2) points squarely to pre-enrolment review. Administering a suitability check weeks into training is much harder to justify.
What "Contextualised" Means
A defensible Suitability Review tool is contextualised to the industry and qualification. This means:
- Questions should use workplace vocabulary from the relevant industry
- Scenarios should reflect the work context of the qualification
- The literacy demands of questions should match the literacy demands of the training content
A community services LLN assessment should reference care environments. A construction assessment should reference site documentation. A generic assessment that could apply to any qualification does not meet this standard.
Building a Compliant Suitability Review System
A compliant system under Outcome 2.2 has four components:
- Review design: Questions mapped to the qualification's ACSF/LLND peak levels, contextualised to the industry
- Administration process: Clear process for when and how the review is administered (before enrolment)
- Suitability analysis: Documented comparison of learner results against qualification requirements
- Support pathway: Documented process for what happens when gaps are identified
All four components need to be in place - and evidenced - for a strong compliance position.
Practical Steps for RTOs
If you are reviewing your pre-enrolment LLND process now, start here:
- Map the peak ACSF levels required by each qualification on your scope
- Review your current assessment tool against those levels — is it contextualised and matched?
- Check your administration process — is it happening before learners start training?
- Review three to five recent enrolment files and trace the LLN assessment process from assessment to support provision
- Document any gaps and create a remediation plan before your next audit
Getting this right is primarily a systems and process challenge. The tools exist to make it manageable - the key is building the right process around them.