Compliance

RTO Doctor focusses on an area of compliance that appears to be troubling providers each month. 

This month’s focus is one of those policies at the back of the Australian Qualifications Framework (AQF) that we seem to find many providers are asking, what’s that?  This month, we look at the ‘AQF Qualifications Issuance Policy’.

The purpose of the AQF Qualifications Issuance Policy is to ensure that:

  • graduates receive the certification documentation to which they are entitled
  • AQF qualifications are correctly identified in certification documentation
  • AQF qualifications are protected against fraudulent issuance
  • a clear distinction can be made between AQF qualifications and non-AQF qualifications
  • certification documentation is used consistently across the education and training sectors, and
  • graduates and others are confident that the qualifications they have been awarded are part of Australia’s national qualifications framework – the AQF.


This policy covers all nationally accredited education and training within the Australian Qualifications Framework; from secondary school certificates of education through to Doctor of Philosophy.  It covers the issue of qualifications, statements of attainment, accredited units regardless of where or how they were delivered and assessed.  In other words, it doesn’t matter if the qualification or unit was assessed in a classroom in Brisbane, a homeless shelter in Dehli India, online or offshore – there is a set standard that applies to the issuance of an AQF qualification that must be maintained.  The terminology is not sector specific and all terms are defined for ease and consistency of understanding in the AQF Glossary of Terminology.  Accrediting bodies are responsible for the monitoring and regulation of compliance with this policy.  While the AQF policy is not sector specific, this article will refer only to VET qualifications and units of competency.

There are 5 sections to this policy, each of them outlined below.  While this article discusses the basics, for more comprehensive information, you are encouraged to take a look at the policy either in the AQF (page 67), download the policy from the AQF website http://www.aqf.edu.au and/or check your organisation’s policy and procedure.

  1. Issuing AQF qualifications
  2. Responsibility for issuing and authenticating AQF qualifications
  3. AQF qualification titles
  4. Use of titles by graduates
  5. Issuing statements of attainment


Issuing AQF Qualifications
All students who have completed a VET qualification are entitled to receive the following two documents:

  • Testamur
  • Record of results

If any part of the qualification has been delivered and/or assessed in a Language Other Than English (LOTE), the testamur or record of results must contain a statement to this effect.  

The testamur must either state the following exact wording ’The qualification is recognised within the Australian Qualifications Framework’ or as an alternative, the use of the AQF logo as approved by the AQF Council.  Under no circumstances may this wording or logo be used for non-accredited training.

Each testamur must contain certain specific information sufficient to ensure authentication and to reduce fraud.  The information must correctly identify the following:

  • Issuing organisation
  • Name of the graduate entitled to the qualification
  • Qualification by its full code and full title
  • Date of issue
  • Name of the person within the organisation authorised to issue the documentation
  • Authenticity of the document to reduce fraud (such as issuing organisation’s seal, corporate identifier or a unique watermark).

Responsibility for issuing and authenticating AQF qualifications
Qualifications under the AQF can only be issued by organisations authorised by legislation to do so; in the VET sector, for nationally accredited training, this is a Registered Training Organisation (RTO).  In order to issue AQF qualifications, any organisation delivering and assessing qualifications must adhere to any government regulatory and quality assurance requirements (in some cases where external course accreditation is required, this must also be adhered to).  Compliance with these quality assurance requirements is monitored by regulatory authorities.

The issuing organisation is responsible for ensuring authenticity of verification of a graduate’s certification documents and is also responsible for ensuring that it has in place mechanisms to held reduce fraudulent behaviour associated with the unauthorised reproduction and use of AQF qualifications that it issues.

The RTO must have a policy that permits the replacement of certification documentation and it is also required to ensure the authenticity and verification of any replacement certification documentation.  This is enhanced by the RTO having a register of AQF qualifications.  The AQF Qualifications register Policy requires that RTO’s:

  • Maintain a register of all AQF qualifications that they are authorised to issue and
  • Maintain a register of all AQF qualifications they issue to graduates.

AQF qualification titles
Titles of AQF qualifications represent the qualification type, level and field of study of the qualification and provide the basis for national and international recognition. AQF qualifications have titles that are unambiguous and the wording is consistent.  In the VET sector, the most common qualification titles are represented as follows:

  • Certificate I in …
  • Certificate II in …
  • Certificate III in …
  • Certificate IV in …
  • Diploma of …
  • Advanced Diploma of …

An RTO who uses numeric data in the qualification title would be in breach of this section of the AQF Qualifications Issuance Policy.  In our experience, it is common for RTO’s and trainers/assessors to state for example ‘Certificate 2′, ’Certificate 3′ or ‘Certificate 4′; it should be noted that these forms of titles are inconsistent with the AQF.

Use of titles by graduates
Not a major issue for the VET sector, none the less, this section is around the use of post-nominals (abbreviations) for qualifications gained after the graduates title and name.  There is further advice about those who have been awarded a Doctoral degree being permitted to use the title ‘Doctor’ and that those who receive an ‘Honorary Doctorate’ are not to use the title ‘Doctor as it is an honorary award.  Any such award (honorary) must also specify that it is an honorary award.

Issuing statements of attainment
The issuing of a statement of attainment recognises that students may have completed one or more units as part of a study program however may not have completed an entire qualification.  A record of results may also be issued with a statement of attainment, this option is completely optional and at the discretion of the RTO.  Further, like a testamur, a statement of attainment may only be issued by an organisation who is authorised by legislation to do so (in other words, an RTO).  

In order to issue an AQF statements of attainment, any organisation delivering and assessing accredited units of competency and issuing a statement of attainment must adhere to any government regulatory and quality assurance requirements (in some cases where external course accreditation is required, this must also be adhered to).  Compliance with these quality assurance requirements is monitored by regulatory authorities.

The statements of attainment correctly identify the person receiving the statement of attainment, the accredited unit codes and full titles, as well as the date issued.  Accrediting authorities may require an RTO to include additional information and the regulatory authorities responsible for policy development in this area would communicate this.  The statement of attainment must not be in a form that it can be mistaken for a testamur and must include the following statement ‘A statement of attainment is issued when an individual has completed one or more accredited units’.

A common resource being used by regulatory authorities to determine compliance is the ‘NSSC Sample forms of testamurs and statements of attainment for AQF qualifications’.  At RTO Doctor, we encourage providers to download a copy of these guidelines and to map testamurs and statements of attainment to these to ensure consistency with regulator expectations.

If any of the accredited units have been delivered and/or assessed in a Language Other Than English (LOTE), the statement of attainment must contain a statement to this effect. The issuing organisation is responsible for ensuring authenticity of verification of a student’s statement of attainment and is also responsible for ensuring that it has in place mechanisms to held reduce fraudulent behaviour associated with the unauthorised reproduction and use of AQF statements of attainment that it issues.