Guides

Auditor independence

Can an approved NDIS quality auditor also help me write my policies?

For providers keeping preparation support separate from an approved auditor.

Short answer: Keep preparation and the audit separate. An auditor can explain the audit process within a written scope. Ask whether anyone on the audit team helped prepare the policies or evidence they will assess. See the source.

The Commission's AQA expectations say an approved quality auditor must prohibit consultancy where it creates an actual or perceived conflict. That includes work for a provider it audits. It also includes a provider reasonably likely to seek an audit from that AQA.

Ask your proposed auditor how it applies that boundary before you engage anyone. The written engagement and the Commission's requirements are what count.

Keep preparation and audit separate

A preparation consultant describes how you operate. They prepare your policies and registers, organise the records you send and draft your written responses.

An approved auditor assesses your evidence in the audit process and makes its own decision.

Ask your proposed auditor for its current scope and its independence safeguards. Clearharbour is a compliance consultancy, not an approved quality auditor. We do not audit a provider we consult to.

Questions to ask in writing

1. Will you give general information about the audit process, or will you help prepare our documents?
2. Will anyone in your audit team have helped prepare or approve the policies or evidence they will assess?
3. What work is included in the auditor's written engagement, and what is excluded?
4. Who contracts with and pays the auditor? Keep the auditor's fee separate from preparation fees.
5. If another consultant prepares our material, how should we send it and who do we talk to?
6. What happens if our scope, support type, site, module or evidence volume changes?

Keep the written answers with your engagement documents and your scope record.

What preparation support should include

A preparation consultant starts with your real entity and how you work. The job may cover a pathway and a written scope. It may cover policies built for your service, a draft self assessment and an evidence index. It may cover interview prompts, written replies to auditor requests and an action tracker.

The consultant should label assumptions and ask you to approve the work. They should mark which files they drafted and which came from your real work.

No consultant signs your attestation. No consultant invents past evidence, backdates a record or decides what the auditor will accept.

What you should keep

• The auditor's written proposal, scope, fee and conflict explanation.
• Your preparation scope, exclusions, evidence owners and assumptions.
• A note of which files were drafted and which came from your real work.
• Written answers about changed scope, extra modules, sites or sampling.
• The final response you approved, plus the auditor's requests and reports.

Common mistakes

• Picking a preparation provider because it looks able to sway the audit decision.
• Treating general auditor guidance as approval of your policies.
• Not telling both parties when your service changes after the scope is agreed.

Sources

• NDIS Quality and Safeguards Commission, Types of audits, accessed 25 August 2026.
• NDIS Quality and Safeguards Commission, Regulatory expectations for approved quality auditors (AQA), version 1 (June 2026), checked 8 September 2026.