Managing Conflict of Interest as an NDIS Provider
How to identify, disclose and manage NDIS provider conflict of interest — with a register, worked examples and audit-ready records that keep you compliant.
What counts as a conflict of interest
The rules that actually bind you
The conflict every provider is asked about: coordination plus delivery
How to identify conflicts before they bite
The conflict-of-interest register
Managing a conflict: how it plays out in practice
Advertising, inducements and gifts
Documentation, service agreements and audits
Common mistakes providers make
Your next step
Frequently asked questions
Does an NDIS provider conflict of interest mean I can't offer both coordination and support delivery?
No. Offering both is not banned, but it is closely scrutinised because the coordinator influences what the participant buys. You must disclose the dual role in writing, present genuine alternatives, guarantee that declining your services carries no penalty, and record the participant's own decision. Where you can separate coordination from delivery, that is the lowest-risk structure — and reforms scheduled from 2027-2028 are moving the scheme in that direction.
Do conflict-of-interest rules apply to unregistered NDIS providers?
Yes. The NDIS Code of Conduct binds every provider and worker, registered or not, and it requires honesty, transparency and acting in the participant's interest. The NDIS Practice Standards conflict requirements apply specifically to registered providers and are tested at audit. With mandatory registration expanding to high-risk supports from 1 July 2027, confirm current scope on ndiscommission.gov.au.
What should a conflict-of-interest register actually contain?
At minimum: the date declared, who declared it, the participant(s) affected, whether the conflict is actual, perceived or potential, a plain description, the management action taken, manager sign-off, and a review date. Attach supporting documents such as the written disclosure the participant received. A controlled spreadsheet is acceptable — the key is that it is current, dated and reviewed alongside your other compliance records.
Can I accept gifts or offer discounts to NDIS participants?
Offering cash, rebates or gift cards as an inducement to sign or switch is treated as improper and can breach the Code of Conduct. A modest thank-you gift from a participant is usually acceptable, but anything of real value should be declared and, above a set threshold, declined. Put a written gifts-and-benefits threshold in your policy so staff are not deciding case by case.
What will an auditor ask about conflict of interest?
Expect three things: your written conflict-of-interest policy, your live register, and a specific worked example — often the case where you provide both coordination and a funded support. The assessor is checking that the control you describe on paper is one you actually operate, so gaps between policy and register are a common non-conformity. Keep records long-term, as a 7-year retention duty is proposed under current reforms.