NDIS Conflict of Interest Policy: What It Must Cover

Conflicts of interest are a Core Module expectation for every provider and a particular focus for support coordination. Here is what a policy needs, where policies fall short, and how to tailor one to a business that delivers more than one kind of service.

Last updated: 8 October 2026

What it is and who needs it

A conflict of interest policy tells workers and participants how your organisation declares and handles situations where its own interests, or a worker's, could affect the advice or supports a participant receives. Every registered provider needs one. It matters most if you coordinate supports and also deliver them, or if you take referrals from or give them to related businesses. The expectations for coordinators are covered on our page for support coordination providers.

What it provides evidence for

In the Core Module's governance and operational management outcome, one indicator is that perceived and actual conflicts of interest are proactively managed and documented, including through organisational policies. Providers of specialised support coordination are also assessed against the conflict of interest outcome in the specialist support coordination module. The Commission's Code of Conduct guidance for providers sets the underlying expectation: declare and avoid real or perceived conflicts.

What auditors check

Auditors check that the policy is specific, that it is known, and that it has been used. They ask key personnel what conflicts the organisation has and where they are recorded. They look for evidence that participants were told about any interest you hold in a support option. They also ask workers how they would declare a gift or a personal connection, and what happens when a participant raises a concern.

Must-include checklist

A definition covering financial, business and personal interests, and perceived as well as actual conflicts.
Who must declare: key personnel, workers, contractors and board members.
When to declare, including at recruitment, at the start of each participant's supports and when circumstances change.
How a declaration is made, assessed, decided and recorded in the register.
Rules on giving, asking for and accepting gifts and inducements, and on referral arrangements with other providers.
How participants are told about any interest you hold in a support option, in a form they understand.
What you do when a conflict cannot be avoided, such as separating roles or offering an independent alternative.
For coordinators, how participants are helped to tell coordination apart from other funded supports.
Who reviews the register and policy, and how often.

Common mistakes

A one-paragraph statement. It says conflicts will be managed but not how.
An empty register in a business with obvious overlaps. If you coordinate and deliver supports, an auditor will not believe there is nothing to declare.
Disclosure only to the organisation. The standard is about the participant knowing, not just the manager.
Ignoring referrals. Arrangements with related providers are where many conflicts hide.
Never reviewed. The policy ignores new rules, such as the coming ban on kickbacks.

How to adapt it to your organisation

Map your actual relationships first: other businesses owned by your directors, providers you refer to often, family connections between staff and participants. Write the policy around those, not around a generic list. Decide who receives declarations and who decides what to do, and avoid a structure in which the person with the interest approves their own conflict. If you deliver several services, say how participants are kept free to choose providers without affecting the service they get from you. Put the disclosure into the documents participants already read, such as the service agreement and welcome information, and brief workers on what to declare. For plan management, the Department of Health, Disability and Ageing says the Government intends to eliminate conflicts of interest in that market, so check its explanation of the changes if you provide it.

How the package covers it

The Core Module documents in the package include a conflict of interest policy and register, and the Module 4 documents add the coordination-specific controls. See what is included and pricing. The register has to record your own declarations.

This page is general information based on NDIS Commission and government sources at the date shown. It is not legal or professional advice, and the rules can change. Check the NDIS Commission's current requirements and read our disclaimer. The checklists on this page describe good practice, not an official list of requirements, and our documents do not guarantee registration.

Frequently Asked Questions

Does only a support coordinator need a conflict of interest policy?

No. The Core Module expects every registered provider to manage perceived and actual conflicts of interest, including through organisational policies. Specialised support coordination adds its own conflict of interest outcome in Module 4, which is where the audit focus is heaviest.

What is the difference between a policy and a register?

The policy sets the rules: what counts as a conflict, who declares it and what happens next. The register is the record of conflicts actually declared and how each was managed. Auditors read the policy, then test it against the register and against what participants and workers say.

Do the new rules on kickbacks and inducements matter here?

Yes. The Securing the NDIS for Future Generations Act 2026 adds a prohibition on providers giving gifts or benefits that are reasonably likely to induce someone to engage them, with exceptions such as legitimate pricing practices. It starts on 20 November 2026, according to the Act's commencement table. Your policy should already say how gifts and referral arrangements are handled, and you should read the NDIS rules on legitimate pricing practices when they are made.