NDIS registration is currently (as of April 2026) optional for counsellors delivering therapeutic supports, and you can work with self-managed and plan-managed participants without it. However, registration does help open the door to working with agency-managed participants, who can only use registered providers. It also signals to potential clients that your practice meets the NDIS Practice Standards.
For counsellors delivering therapy under 0128 Therapeutic Supports, you’ll complete a Verification audit as part of the registration process. This is not a multi-day site visit or in-person audit, but instead involces a desktop review of your evidence and documentation.
Counselling is not an AHPRA-regulated profession, so your audit evidence changes slightly from other therapists. Read on for the full process.
The Registration Group: 0128 Therapeutic Supports
Counselling services fall under the NDIS registration group 0128 Therapeutic Supports. This covers assessment, therapy, and capacity building delivered by allied health and therapeutic professionals, including counsellors.
Selecting only 0128 Therapeutic Supports when you complete your registration application with keep you on the Verification audit pathway.
A note on rehabilitation counsellors: Rehabilitation counselling is treated as a separate profession under the NDIS, with its own professional body requirement (membership with the Australian Society of Rehabilitation Counsellors or equivalent). The registration process is very similar, and you’d still register under 0128 and go through a Verification audit, but the professional membership evidence is different. This article focuses on general counsellors.
What Makes This Different: You’re Not AHPRA-Registered
Psychologists, OTs, physiotherapists, and several other allied health professions are regulated by the Australian Health Practitioner Regulation Agency (AHPRA). This means their qualifications, registration status, and ongoing professional obligations are managed through a national registration scheme with a single, publicly searchable register.
Counselling doesn’t sit under AHPRA so the process differs. The NDIS Commission’s Qualification and Professional Associations Required Documentation Guide (available at the bottom of this page) outlines the professional requirements for counsellors becoming NDIS-registered. This includes membership with one of three recognised professional bodies:
- Australian Counselling Association (ACA): membership at the appropriate level
- Psychotherapy and Counselling Federation of Australia (PACFA): as an accredited PACFA Registrant
- Certified Practising Counsellors Australia (CPCA): full membership
Your membership with one of these organisations is the evidence that replaces what AHPRA registration provides for other regulated professions.
This isn’t a disadvantage, and a Verification audit assesses the same four standards regardless of your profession. You do need to be deliberate about maintaining your professional membership and keeping your evidence current, because there’s no national register an auditor can check independently.
Verification vs Certification
There are two types of NDIS audits: Verification and Certification.
Certification is for higher-risk services (like personal care, behaviour support, or supported independent living). It involves site visits, record reviews, and interviews with management, workers, and participants. Providers going through this type of audit can expect to budget $8,000–$12,000 as a starting point.
Verification is for supports that have been deemed to be lower-risk (like therapy, cleaning, and home modifications). It’s a desktop audit, meaning the auditor reviews your documents remotely, and will typically cost between $900 and $1,500.
For counsellors delivering therapy under 0128 Therapeutic Supports, Verification is the required audit pathway.
When Your Audit Pathway Changes
Your audit pathway can change if you add on additional registration groups that trigger a Certification audit.
For example, if you want to work as a Behaviour Support Practitioner (conducting functional behaviour assessments and developing behaviour support plans under registration group 0110 Specialist Behaviour Support) you will undergo a much more extensive audit. Adding 0110 triggers a Certification audit against the Core Module plus the Specialist Behaviour Support supplementary module, with audit costs starting at $8,000–$12,000.
It’s worth understanding that the pathway to becoming a behaviour support practitioner is separate from your NDIS provider registration. The NDIS Commission assesses practitioner suitability against the Positive Behaviour Support Capability Framework, which is capability-based rather than tied to any specific qualification. Counsellors with relevant experience and training in positive behaviour support can apply, but it’s a distinct process that involves its own self-assessment and evidence portfolio. If this is something you’re considering, check out the Commission’s guidance on becoming a behaviour support practitioner before you decide which registration groups to include in your application.
If you’re weighing up whether to add behaviour support, our guide on the NDIS Certification vs Verification Audit explains the financial and operational differences between the two pathways.
The 4 Requirements for Verification
To pass a Verification audit, you’ll need to demonstrate you have appropriate processes in place for your business and the NDIS participants you work with. Read more here. The auditor will review four areas:
Human Resource Management: Evidence of your qualifications, professional body membership, NDIS Worker Screening Check, and right-to-work documentation. For counsellors, this means current membership with ACA, PACFA, or CPCA (and evidence that your membership is active and current). Auditors will also want to see evidence of clinical supervision and ongoing professional development as required by your professional body.
Incident Management: A process for responding when something goes wrong. For a counselling practice, this should reflect the kinds of incidents that actually can and do arise in your work, such as a client in crisis during a session, a disclosure of harm or abuse, a confidentiality breach, or a safeguarding concern.
Complaints Management: A clear, accessible process for clients to raise concerns and evidence of how you resolve them. Your professional body will have its own complaints and ethics process, but you still need a separate complaints process that meets the NDIS Practice Standards specifically.
Risk Management: How you identify and manage risks in your practice. Your risk register should reflect the actual risks you face as a counsellor, like breaches of confidentiality, managing boundaries and dual relationships, vicarious trauma and practitioner wellbeing, and supporting clients in acute distress.
NDIS Registration for Counsellors: Required Documents and Checks
Before you apply, gather the following evidence:
Professional Body Membership: Current, active membership with ACA, PACFA (as an accredited registrant), or CPCA (full membership). This is your primary credential, and if your membership has lapsed or is pending renewal at the time of your audit, you can’t demonstrate that you meet the qualification requirements. Keep your membership current and have evidence ready to show the auditor.
Qualifications: Your counselling qualification (diploma, bachelor’s degree, or postgraduate qualification, depending on your professional body’s membership requirements). Your professional body membership demonstrates that your qualification meets the required standard, but auditors may still want to sight the underlying qualification.
Clinical Supervision and Professional Development: Evidence that you’re meeting the supervision and CPD requirements set by your professional body. Each body has different requirements , make sure you know what yours expects and can show evidence that you’re participating in CPD.
Insurance: Professional indemnity insurance is essential. Public liability insurance is also required unless you are delivering services entirely virtually and never see participants in person (discuss this with your auditor if you believe it applies to you). Unlike AHPRA-regulated professions, there’s no national registration scheme that mandates minimum insurance levels, so check what your professional body requires and confirm with your insurer that your cover is appropriate for NDIS service delivery.
NDIS Worker Screening Check: Required for all counsellors delivering NDIS services, regardless of your professional body membership.
NDIS Worker Orientation Module: Certificate of completion for you and any staff.
Infection Control and PPE Training: Yes, even if you operate from a private office. This might be relatively simple (e.g. hand hygiene, cleaning protocols, what to do when you or a client is unwell) but you need evidence that you’ve considered infection control in your service environment.
Operational Documents: Policies and procedures covering the four Verification areas above. These should describe how your counselling practice actually operates, not how a generic disability support service operates.
Common Mistakes Counsellors Make
Letting professional membership lapse
For AHPRA-regulated professions, registration is tied to a national scheme with clear renewal dates and public visibility. For counsellors, maintaining professional body membership is your responsibility, and there’s no external register prompting you to renew. If your ACA, PACFA, or CPCA membership lapses, you can’t demonstrate you meet the NDIS qualification requirements.
Documents that describe someone else’s service
This is the most common issue across all allied health audits. Many NDIS policy template packs available online are built around personal care and support work. If your incident management procedures cover medication errors and falls prevention but say nothing about managing a client who discloses suicidal ideation or a safeguarding concern, your documentation isn’t really reflecting your practice.
Auditors can tell when a provider has purchased a generic pack and just changed the business name on the cover page, so make sure you review each document you’ve purchased and update it to match how you operate.
Risk registers full of irrelevant risks
A risk register that lists participant transport incidents and community access hazards isn’t useful for a counselling practice. The risks you manage are different, like confidentiality breaches, managing professional boundaries, working with clients who have complex trauma histories, and vicarious trauma and burnout for practitioners. Your register should describe the risks that are genuinely present in your service and any strategies you have in place to manage them.
Not understanding how NDIS service agreements differ from private practice
If you’re moving from private practice or Medicare-funded work, your existing intake forms and consent documents might not cover everything an NDIS service agreement needs. You’ll need to address NDIS-specific elements: how pricing works under the NDIS Price Guide, your cancellation policy, how you manage different plan management types (agency-managed, plan-managed, self-managed), and what happens when a participant’s plan is reviewed or their funding changes.
The Registration Process
Step 1: Start Your Application
Log in to the NDIS Commission Portal and start a New Application. Enter your business details and select 0128 Therapeutic Supports as your registration group. You’ll complete a self-assessment against the relevant NDIS Practice Standards and may be prompted to upload your evidence documentation.
Step 2: Receive Your Initial Scope of Audit
Once you submit your application, the system generates an Initial Scope of Audit. This confirms whether you require a Verification or Certification audit. If you’ve selected only 0128 Therapeutic Supports, you’ll be on the Verification pathway.
Step 3: Engage an Approved Quality Auditor
You must engage an independent Approved Quality Auditor (AQA) from the list published by the NDIS Commission. Send them your Initial Scope of Audit and request a quote for a Verification audit.
Verification audits typically cost between $900 and $1,500 depending on which auditor you choose.
Step 4: Submit Your Documents
Your auditor will request your policies, insurance, professional body membership evidence, screening checks, and other documentation. They’ll review everything against the NDIS Practice Standards and identify any gaps. If a major non-conformity is found, you’ll have up to 3 months to provide additional evidence before the auditor can finalise your report.
Step 5: The Decision
Once the auditor completes your report, they’ll then submit their recommendation to the NDIS Commission. The Commission assesses your application and audit result, then makes the final decision on your registration.
Frequently Asked Questions
Do I need additional qualifications beyond my counselling membership?
No. Your current membership with ACA, PACFA, or CPCA (combined with evidence of clinical supervision and professional development) demonstrates you’re qualified to deliver therapeutic supports under the NDIS. You don’t need any other NDIS-specific qualifications to register under 0128.
Can I charge more if I’m registered?
No. The NDIS Price Guide sets maximum prices for therapeutic supports. Registration doesn’t change what you can charge, but it does expand your potential client base to include agency-managed participants. Counsellors have their own line items in the NDIS pricing arrangements, separate from psychologists, so double check these and make sure you’re billing under the right support item numbers for your profession.
What about psychotherapy? Is it covered under the same registration?
If you’re a psychotherapist registered with PACFA as an accredited registrant, you’re covered under the same counsellor requirements in the NDIS qualification guide. The 0128 Therapeutic Supports registration group covers your services. The distinction between counselling and psychotherapy as professional disciplines doesn’t change the NDIS registration pathway.
How long does it take?
The Verification audit itself can usually be completed within a few days once you submit your documents. If the auditor identifies gaps, you may need to provide further evidence. Once your audit report is finalised, NDIS Commission processing can take several weeks or months depending on their current backlog.
What’s the difference between ACA, PACFA, and CPCA?
All three are recognised by the NDIS Commission as acceptable professional bodies for counsellors, they just have different membership requirements, CPD obligations, and supervision expectations. The NDIS doesn’t prefer one over another as long as you have active membership. If you’re not yet a member of any of them, research which one aligns with your qualifications and career before applying.
