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Guided tools that build your NDIS policies and procedures from your answers. Created by an NDIS auditor.

Audit Preparation

Questions to ask before engaging a new NDIS auditor

by Penny Halpin |

Selecting an Approved Quality Auditor (AQA) is a significant decision for NDIS providers. Periods of sector change can understandably increase anxiety for providers, particularly when AQAs exit the scheme or providers are required to find a new auditor at short notice.

While AQAs are regulated and accredited through JASANZ, many of the requirements they must meet are not widely understood outside of the auditing world. Asking informed questions before signing a contract can help you assess your next potential auditor’s professionalism, independence, and audit approach.

Why due diligence matters

All AQAs are required to operate within a framework of accreditation rules, impartiality requirements, and oversight (check out the JASANZ Accreditation Manual for more info if you’re interested). However, the way those requirements are implemented in practice can (rightly or wrongly) vary between auditing bodies.

An ethical AQA will be able to answer reasonable due diligence questions clearly and without defensiveness.

Reluctance to engage with these questions can itself be informative.

Key questions to ask a prospective AQA

The following questions are appropriate for providers to raise when considering an audit engagement.

Auditor competence and experience

  • What professional backgrounds and experience do your auditors have?
  • How long have you been auditing in human services?
  • Do you audit against other human services or regulatory schemes?

These questions help establish whether the auditor will actually understand the operational realities of your service delivery, and not just standards in isolation.

Impartiality and independence

  • What strategies do you have in place to manage impartiality and conflicts of interest?
  • Do you enter into any arrangements with consultants or advisory services?
  • How are auditors supported to act without fear or favour?

Strong AQAs will be able to confidently articulate how independence is maintained at both organisational and auditor levels.

Financial governance

  • How are client funds managed and protected, particularly where prepayments are required?
  • What safeguards are in place if audits are delayed or cancelled?

These questions are particularly relevant where you are paying significant fees in advance of audit activity.

Audit decision-making and oversight

  • What do your auditors take into consideration when raising major non-conformities or critical risks? (If you’re unsure how these work, read our guide on what NDIS audit non-conformities mean).
  • How is auditor competence monitored and reviewed over time?
  • What internal review or moderation processes occur before a certification decision is finalised?

The answers to these questions will provide insight into the robustness of the AQA’s internal governance and quality assurance processes.

Audit team transparency and approach

  • Will we be provided with the auditors’ names and details prior to the audit?
  • How can concerns about auditor suitability be raised in advance?
  • How do you foster a respectful and collaborative audit culture?

Audit outcomes are influenced not only by technical interpretation of standards, but also by how audits are conducted in practice.

Interpreting the responses

There are poor practices in the sector, but there are also many ethical, professional, and highly competent AQAs who are in this work for the same reason you are – to make a difference and safeguard vulnerable people.

An AQA’s willingness to engage openly with these questions can provide valuable insight into their organisational culture, commitment to impartiality, and respect for providers.

A final note

Asking these questions is not confrontational, and is rather a reasonable and responsible step in selecting an organisation that will be making significant regulatory decisions about your services.

A professional AQA will recognise this and be more than happy to respond accordingly.

About the author

Penny Halpin

Penny is an NDIS Lead Auditor who has worked in certification since the first audits in 2018, and was previously a Senior Manager at an Approved Quality Auditor with technical review across thousands of audit reports. She built the Paperbark tools to help providers create documentation that reflects how they actually work.

More about Penny →