The 1 October 2026 SIL registration deadline: who's caught and what to do

If you deliver supported independent living and you're not registered with the NDIS Quality and Safeguards Commission, there's a date you need in your calendar: 1 October 2026.

This one isn't a proposal. It isn't a consultation, a discussion paper, or something flagged for the future. It's law, it's already in force, and it's roughly ten weeks away.

Here's the plain version of who's affected, what "applied" actually means, and what to do if you've left it late.

What changed on 1 July 2026

Two things happened at once, and they're easy to confuse.

First, SIL became a support you must be registered to deliver. Mandatory registration for supported independent living providers — and for NDIS digital platform providers — began on 1 July 2026. SIL also got its own new registration group (0138), replacing the old arrangement where it was claimed under 0115.

Second, SIL got its own Practice Standards. A new module — Module 5A — was created specifically for SIL. It sits on top of the Core Module, not instead of it, and it covers four areas: supported decision-making, safeguarding, practice governance, and agreements about tenancy, housing and support arrangements.

Both changes came from the same instrument, made on 24 June 2026 and commencing 1 July 2026. Neither depends on the reform Bill currently before Parliament. They are already law.

One consequence worth stating clearly: SIL is a certification pathway. Not verification. If you were expecting the lighter audit, that isn't the situation.

So who has to do what?

There are three groups, and the answer is genuinely different for each.

You were delivering SIL before 1 July 2026, and you're not registered

This is the group the 1 October date is for.

You did not have to be registered on 1 July. The Commission was explicit about this — providers already delivering SIL in an unregistered capacity weren't required to be registered on day one. But you do have to take action during the transition period.

Specifically: you need to have applied for registration by 1 October 2026 if you want to keep delivering SIL after that date.

Note the word. Applied — not approved, not audited, not certified. You need your application in.

If it's in before 1 October, you can keep operating while it's assessed. The new SIL Practice Standards then apply to you from whichever comes first: the day your application is decided, or 1 October 2026. So if your application is still being assessed on 1 October — which for many will be the case — the standards apply to you from that date regardless.

If you haven't applied by 1 October, the position is blunt. The Commission's own words are that unregistered SIL providers must apply by 1 October 2026 or stop providing SIL — and must cease providing it if registration is refused.

The money stops too, and on a specific date. The NDIA has told plan managers that from 1 October 2026 they should reject invoices for SIL supports from providers who are neither registered nor have applied, and that a provider who doesn't apply by then can only claim for services delivered up to 30 September 2026. So there's no quiet grace period where the invoices keep clearing while you sort out the paperwork.

You're already a registered provider and you deliver SIL

You need your registration varied to include the new class of support. The SIL Practice Standards formally apply to you from the day the Commissioner decides that variation.

But — and this is the part most commentary is getting wrong — you don't get a compliance holiday in the meantime. The Rules include a provision requiring already-registered providers to comply with the SIL standards during the interim period, as though they were already specified for the class of support.

In practice: if you're registered and delivering SIL, treat Module 5A as applying to you now.

You're a new entrant

The standards applied from 1 July 2026. There's no transition arrangement for you. You register, you're audited against the Core Module plus Module 5A, certification pathway.

What "applying" actually involves

Registration isn't a form you fill in on a Sunday afternoon. The application itself is manageable; what sits behind it is the work.

You'll need to self-assess against every applicable Practice Standard and quality indicator — that's the Core Module plus Module 5A for SIL — and then engage an approved quality auditor to assess you against them. The auditor is independent, you pay them separately, and their fee is on top of any help you get preparing.

What that means practically is that your policies, procedures, registers and evidence need to exist and be findable before the audit, not promised during it. Auditors assess evidence of practice, not intentions.

For SIL specifically, a lot of that evidence is gathered per house rather than per organisation. Emergency arrangements coordinated across the people living in one home. Conflict and safeguarding tracked at house level. Consultation with existing residents before someone new moves in. A corporate policy folder doesn't demonstrate any of that.

If you've left it late

Ten weeks is not comfortable, but it's not nothing either. In rough order of what matters:

1. Confirm whether you're actually captured. "Supported independent living" has a specific meaning in the registration groups. If you deliver support in someone's home but not SIL as defined, your position may be different. Get this right before you spend anything.

2. Get the application in. The deadline is on applying, not on being approved. Everything else can continue while it's assessed. If you do one thing this month, do this one.

3. Work out which pathway and modules apply. SIL means Core plus Module 5A, certification. If you also deliver high-intensity daily personal activities, there may be more. Getting the scope wrong is expensive because it changes what the auditor tests.

4. Find the gaps in your evidence before your auditor does. The four SIL standards ask for things a lot of providers have been doing informally for years — supporting people to make decisions, keeping homes safe, matching housemates thoughtfully — without recording it. Under an audit, undocumented good practice looks the same as no practice.

5. Book your auditor early. There is a finite number of approved quality auditors and a large number of SIL providers coming through the same window at the same time. Availability, not readiness, is a genuine risk here.

When you'll actually be audited against Module 5A

This is the question everyone asks and most commentary dodges. Here's what's actually published.

If you're on the certification pathway — which SIL is — a mid-term audit must commence no later than 18 months after the beginning of the period your registration is in force. That's in the Approved Quality Auditors Scheme Guidelines, pointing at the Provider Registration and Practice Standards Rules. So there is a timetable.

But a mid-term audit doesn't re-test everything. It assesses three things: the provider governance and operational management standards, anything you're already under a corrective action plan for, and anything else the Commissioner names in a written notice to you.

Module 5A is not automatically on that list.

So on the published arrangements: the SIL standards get tested at recertification, not at your mid-term audit — unless the Commissioner writes to you and puts them on it. That last part is a real mechanism, not a theoretical one, and it's individual to you.

Two honest caveats. There are carve-outs from the mid-term audit requirement, including one for a "transitioned provider", and whether that catches you depends on how you came into registration — worth asking your auditor directly. And a surveillance audit can satisfy the mid-term requirement if it meets the same conditions, in which case you won't have a separate one.

What none of this supports is the confident claim that you have until your next scheduled renewal and can relax. The Commissioner can put Module 5A on your mid-term audit in writing. If someone tells you otherwise, ask them where that's published.

And one thing we can't tell you

Whether the SIL market changes again. The NDIA is consulting until 31 October 2026 on whether to commission part of the SIL market for participants needing 24/7 supports. Consultation opened on 1 July and closes 31 October, per the Department's published reform timeline. No decision has been made. It doesn't change anything about the October registration deadline, but it's worth knowing that a conversation is happening.

The honest summary

If you delivered SIL before 1 July 2026 and you're unregistered, apply before 1 October 2026. That's the action. Everything else — the standards, the evidence, the audit — follows, and there's time to do it properly if you start the application now.

If you're already registered and delivering SIL, you're expected to be meeting Module 5A already, whatever your variation status says.

And if anyone is selling you a 2027 deadline as though it's certain, check what's actually law first. Quite a lot of what's circulating right now is still a Bill before Parliament.

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Not sure where you sit? Our free compliance health check asks a few questions about your services and documents — including a specific check against all four SIL Practice Standards — and comes back with a written gap report in two business days. No obligation, and the fix-list works whether or not you ever hire us.

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Bowerbird Compliance provides general information and document-preparation services. We are not lawyers and do not provide legal advice. Registration and audit outcomes are determined by the NDIS Commission and approved quality auditors.