ArticleCompliance & StandardsGovernanceAged Care Act
Open Disclosure Isn't a Paperwork Exercise Anymore. It's Being Assessed.
Since the Strengthened Aged Care Quality Standards took effect on 1 November 2025, open disclosure has moved from "good practice" to something the Aged Care Quality and Safety Commission actively checks for.
Published 7 July 2026• 4 min read
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Open Disclosure Isn't a Paperwork Exercise Anymore. It's Being Assessed.
During assessment contacts, assessors can ask to see your open disclosure policy, review incident records for evidence disclosure actually happened, and interview residents and families directly about their experience. Providers who can't demonstrate a systematic, consistent approach risk a finding of non-compliance, and not because a policy document is missing. Because the practice on the ground doesn't match it.
For facility managers and L&D leads, that's a meaningful shift in what "training staff on open disclosure" needs to achieve. A policy sitting in a folder won't survive a resident interview that contradicts it.
What open disclosure actually means, and what it doesn't
The Aged Care Quality and Safety Commission defines open disclosure as the open discussion a provider has with people receiving care when something goes wrong that has caused harm, or had the potential to cause harm. That's a deliberately broad bar, and it's not limited to major incidents. The Commission's own guidance gives examples ranging from a failure to prevent infection spread, to a meal that didn't meet someone's cultural dietary needs, to a staff member speaking to a resident in a way that wasn't acceptable. Harm, in this framework, includes physical, psychological and social harm, not only clinical injury.
It's worth being explicit with staff about what open disclosure is not. It is not an admission of legal liability, and expressing genuine regret that something happened isn't the same as admitting negligence. That distinction is often where staff hesitate: a fear that being honest with a resident or family will expose the organisation legally. Getting this right in training removes a real barrier to staff actually doing it.
Where it sits in the Standards
Open disclosure isn't a standalone requirement tucked into a compliance appendix. It's assessed across multiple Standards. Standard 1 requires that older people are treated with dignity and that communication is open, honest and culturally appropriate; open disclosure is a direct expression of that. Standard 2 requires effective governance, including incident management and continuous improvement, and open disclosure is treated as evidence of a genuinely transparent safety culture rather than a defensive one. Under the new Aged Care Act, whistleblower protections have also expanded: since 1 November 2025, residents, family members, and anyone significant to a resident can make a protected disclosure about misconduct or harm, to a wider group of recipients than previously allowed.
Taken together, this is a system explicitly designed to make it harder for issues to stay quiet, and easier, in theory, for staff to raise them without fear.
The staff psychological safety angle managers tend to miss
Here's the part that often gets left out of open disclosure training: it can't work if staff don't feel safe raising the initial concern internally. An organisation can have an excellent external-facing open disclosure policy for residents and families, and still have a culture where a support worker who flags a near-miss to their supervisor feels like they're informing on a colleague or risking blame.
The Commission's guidance is explicit that for serious incidents, initial disclosure to the resident or family should happen within 24 to 48 hours, which means the internal reporting chain has to move fast too. That's only realistic if frontline staff trust that raising an issue leads to a learning response, not a punitive one. Building that trust is a leadership and culture task as much as a training one, but training is where it starts: staff need to understand, concretely, that flagging a near-miss protects residents and protects them, rather than exposing them to blame.
This links directly to the Code of Conduct introduced under the Aged Care Act, which requires every aged care worker to act with integrity, honesty and transparency, treated as an enforceable expectation tied to their registration and ongoing employment rather than an abstract value statement.
Practical steps for getting this genuinely embedded
- Separate "disclosure to families" training from "disclosure doesn't replace SIRS reporting." Staff need clarity that open disclosure and Serious Incident Response Scheme reporting are related but distinct obligations, each with its own trigger and timeline.
- Rehearse the actual conversation, not just the policy. Role-playing a disclosure conversation, including the discomfort of saying "we got this wrong" without over-promising or admitting liability, builds confidence that a written procedure alone doesn't.
- Audit your incident records for disclosure evidence, not just incident closure. If your records show an incident was resolved but don't show that the resident or family was told what happened, that's the exact gap an assessment contact will surface.
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