Conflict of Interest: The Complete Support Coordinator Guide (2026)
A support coordinator conflict of interest guide covering the rules, disclosure, brokerage risks and NDIA scrutiny in 2026 — stay compliant and keep choice re
What a conflict of interest actually is
The rules that bind you
The biggest conflict: delivering or owning other supports
Referrals without steering: protecting choice and control
Brokerage and multi-support arrangements under scrutiny
Gifts, inducements and shared ownership
How to disclose and document: a worked example
Common mistakes and edge cases
Why this is tightening: the reform context
Your conflict-of-interest checklist
Frequently asked questions
Can a support coordinator also provide other NDIS supports to the same participant?
It is not outright banned, but it creates a conflict of interest you must actively manage: disclose it in writing before any referral, offer genuine alternatives, document the participant's free choice, and never make coordination conditional on using your other service. Because it is hard to defend at audit and is a focus of current NDIA scrutiny, many coordinators avoid the arrangement. Specialist support coordinators face the strictest expectations.
Do conflict-of-interest rules apply if I'm not a registered provider?
Yes. The NDIS Code of Conduct binds every NDIS worker and provider regardless of registration status, and it requires honesty, integrity and respect for the participant's decision-making. Standard support coordination registration is paused (as at December 2025), but that does not switch off your conduct obligations. Keep a conflict register and written disclosures even while unregistered.
Are referral fees or commissions allowed between NDIS providers?
No. Paying or receiving a fee, commission or kickback to direct a participant to a provider corrupts the referral and breaches the Code of Conduct. It can trigger NDIA and NDIS Commission action. This holds regardless of what the payment is called, including 'marketing', 'admin' or 'partnership' fees.
How should I document a conflict of interest?
Disclose it to the participant before the relevant decision, in plain language and in writing, and record it in a file note: the date, the conflict, the alternatives you offered, and the participant's independent choice in their own words. Keep a copy in a standing conflict-of-interest register and in the participant's file. If it isn't written down, at audit it effectively didn't happen.
Will the 2028 commissioned panel change conflict-of-interest rules?
The open market for support coordination is due to be replaced by a commissioned panel from 1 July 2028 under the 2026 reform bill, and independence from other supports is widely expected to be a condition of panel access. Design consultation runs in the second half of 2026. Verify dates against health.gov.au/securingtheNDIS and the Federal Register of Legislation, as elements depend on passage.