A responsible-person register should help your governance team answer three practical questions: who holds the relevant responsibilities, when their suitability was reviewed, and what remains to be done after a change. A list of names alone cannot answer those questions.
This guide explains the legal reference points and suggests a practical review process for Australian aged care providers. It also shows what to inspect when evaluating responsible-person software. Guidance checked 25 September 2026.
Who belongs in a responsible-person register?
Section 12 of the Aged Care Act 2024 defines responsible persons. For non-government providers, it includes executive decision-makers and people with authority, responsibility or significant influence over planning, directing or controlling the provider’s activities. For all providers, specified nursing management and day-to-day operational roles are also included. Governing body members fall within executive decision-making.
Start with actual responsibilities. Review the organisation chart, delegated authority and service management arrangements. A job title is a useful reference, but it does not settle whether someone meets the definition. Record why each person is included and revisit that decision when their responsibilities change.
Use the statutory suitability matters
Section 13 sets out the suitability matters in paragraphs (a)–(k). They address service experience; aged care and NDIS banning orders; indictable convictions; civil penalties; insolvency; specified adverse findings and enforcement action; fraud, misrepresentation or dishonesty proceedings; corporate disqualification; applicable screening requirements; and matters prescribed by the Rules. Read the statutory text for the full scope and qualifications, including the treatment of spent convictions.
Use the legislation as the checklist authority. Record the information considered, the reviewer, the assessment date and the reasons for the decision. Where information needs clarification, assign follow-up and retain the eventual outcome rather than treating a partially completed checklist as a completed assessment.
Make annual review and change reporting routine
The Commission’s governance guidance requires suitability review at least annually and processes for responsible persons to report relevant changes. Screening requirements must also be met.
As a practical operating process, give each review an owner and a due date. Ask the person to confirm relevant changes, check the supporting records and record the provider’s decision. Set a route for changes between reviews so the next annual review is not the first time your team hears about an issue.
Keep declarations and screening evidence distinct from the suitability decision. A recorded declaration or a current check does not, by itself, document the provider’s consideration of every relevant matter. Confirm the evidence required under the current Rules; do not assume a generic checklist applies unchanged to every person.
Record notification separately from the change
The Commission requires notification when someone becomes or stops being a responsible person, or their suitability changes. Its responsible-person notification guidance explains the information and supporting documents to provide. The governance guidance states the deadline as 14 days from becoming aware of the change.
Record the change, when the organisation became aware, who will prepare the notification and who will approve it. Complete the notification through the Commission’s required channel, then retain the submission evidence. Updating your internal register is a separate action from notifying the Commission.
A useful review question is: could another authorised team member find both the change record and evidence that the required notification was completed? If not, make that handover clearer.
Use skills coverage to guide board development
A governing body skills matrix can help a board discuss recruitment and development. Record each member’s experience and proficiency, then review the collective coverage against the services your organisation provides.
Useful discussion areas include clinical oversight, finance, legal responsibilities, governance, risk, aged care operations and consumer perspectives. Treat gaps as a prompt for a documented development or recruitment decision. A skills matrix supports that discussion; it does not establish that all governing body composition requirements have been met. Confirm the requirements and any applicable exceptions for your provider.
A practical register review
Use these questions in a periodic governance review:
- Does the register reflect current responsibilities, including recent appointments and cessations?
- Is there a dated suitability decision supported by the information considered?
- Are declaration and screening records current and easy to locate?
- Are changes between annual reviews captured and assigned?
- Can your team distinguish notification still to do from notification already completed externally?
- Do any unresolved questions have a named owner and follow-up date?
These are suggested review questions, not a ranking of Commission findings or a substitute for your applicable obligations.
What to inspect in a Statura Care demonstration
Bring a sample appointment and subsequent cessation to a tailored demonstration. In the Responsible Persons module, review role and appointment details, suitability responses and notes, declaration and police-check dates, and recorded Commission notification dates.
Ask the presenter to show what happens when information is missing and how an overdue notification appears. Compare the assessment prompts with your approved statutory checklist and confirm who maintains that checklist. Your team completes Commission notification externally.
Then inspect the related governance workspace: record a member’s proficiency and see how a skills gap appears. This gives your team a concrete basis for assessing fit alongside the wider compliance workflow.