NDIS Restrictive Practice Reporting: What Implementing Providers Must Do

From 12 October 2026, the NDIS Commission has a new portal — and for a while, implementing providers will work in two. Which one you use depends on when the behaviour support plan, or the incident, was lodged.

Restrictive practices are also firmly on the Commission's radar. The first priority listed in its regulatory priorities for 2026–27 is:

NDIS providers who are implementing regulated restrictive practices and are not registered to do so.

The Commission's Behaviour Support Plan Quality Snapshot 2026 also rated 74% of the comprehensive plans it sampled as weak or underdeveloped.

If your team uses a regulated restrictive practice while delivering support, you're an implementing provider. This guide covers what the rules expect of you — and the reporting mistakes that are easiest to make.

What counts as a regulated restrictive practice?

The NDIS Commission regulates five types of restrictive practices:

1. Seclusion — a person is left alone in a room or place and isn't allowed to leave
2. Chemical restraint — a person is given medicine to stop or reduce their behaviour
3. Mechanical restraint — equipment or a device is used to stop or reduce a person's behaviour
4. Physical restraint — a person, or part of their body, is held so they can't move freely, to stop or reduce their behaviour
5. Environmental restraint — a person is stopped from having or doing certain things, or from going to certain places in their home or community

What implementing providers must do

The rules for implementing providers set out these obligations:

1. Be registered. It's a breach of the NDIS Rules for an unregistered provider to use regulated restrictive practices.
2. Get authorisation from the authorising body in the state or territory where the person lives, and lodge evidence of it in the NDIS Commission portal.
3. Accept the plan. Once the specialist behaviour support provider lodges the behaviour support plan, you accept it in the new portal. For plans lodged before 12 October 2026, you activate it in the existing portal.
4. Engage a specialist behaviour support provider in time. If a restrictive practice will be used on an ongoing basis, a plan must be developed: an interim plan within 1 month of when the practice was first used, and a comprehensive plan within 6 months.
5. Report monthly. Submit monthly reports on the use of regulated restrictive practices within 5 business days of month end — including months when a practice wasn't used. Report in the portal where the plan was lodged.
6. Keep written information about the use of regulated restrictive practices.

Which portal to use from 12 October 2026

Monthly reporting follows the plan, so a plan lodged before 12 October keeps being reported in the existing portal. Incidents lodged before 12 October stay in the existing portal, whether they're open or closed.

When use is unauthorised, it's a reportable incident

A restrictive practice is unauthorised if it:

• isn't in a behaviour support plan
• hasn't been authorised under the state or territory process, or
• isn't being used in line with the behaviour support plan

Unauthorised use is a reportable incident:

Timeframes run from when your organisation became aware of the incident. If you don't report within them, the Commission says this might result in an infringement notice or other compliance action. From 12 October 2026, lodge every new incident in the new NDIS Commission Portal.

The mistakes that are easiest to make

• Using a restrictive practice while waiting for authorisation or a plan — and not reporting it. Until it's authorised and in a behaviour support plan, any use is unauthorised, so it's a reportable incident. Using one while you wait also makes you an implementing provider, with all the obligations above.
• Skipping the monthly report when nothing happened. A month with no use still needs a report.
• A plan that was lodged but never accepted. You can only submit monthly reports against a plan you've accepted (new portal) or activated (existing portal).
• Rejecting a plan by mistake. In the new portal, a rejected plan can't be edited. The behaviour support practitioner has to lodge it again.
• Reporting in the wrong portal. Monthly reports follow the plan: plans lodged before 12 October 2026 are still reported in the existing portal.
• Mixing up the timeframes. 24 hours applies when the person was harmed. Otherwise it's 5 business days — but the clock still starts when you become aware.
• Recording it too late. If a worker only mentions an incident at the end of the week, the reporting window may already be closing.

A simple routine for your team

1. Record every use at the time, in line with the behaviour support plan.
2. Flag anything outside the plan immediately, so a manager can decide whether it's reportable.
3. Check the portal is up to date — authorisation lodged, plan accepted or activated, in the right portal.
4. Diarise the monthly report for the first week of every month, including nil months.
5. Review incidents together with the behaviour support practitioner, and record what changes.

How Comm.care helps

Comm.care doesn't lodge reports with the NDIS Commission or submit your monthly reports — you still do that in the Commission's portal. What it does is make sure the right people know, on the day, and that nothing gets lost between the shift and the report.

• Incident management (Quality Management System) — record each incident with fields for whether it's reportable to the NDIS Commission, the type of reportable incident, who it was referred to, and the date advised, then track the investigation and improvement
• Red flags — flag a reportable incident on the participant's timeline, and Circle members and managers get a push notification on the mobile app
• Care Instructions — keep the current behaviour support plan and strategies where every worker can find them on shift
• Progress notes — give workers a place to record changes in behaviour at the time of support
• Worker screening checks (Quality Management System) — make sure the workers supporting each person have current, approved checks

Incidents, risks, complaints and staff checks — all in one place. Less paperwork, less chasing.

FAQs

How quickly must unauthorised use of a restrictive practice be reported?

Within 5 business days of becoming aware of it. If it resulted in harm to the person, within 24 hours.

Do I need to submit a monthly report if no restrictive practice was used?

Yes. Monthly reports are required even when a practice wasn't used, within 5 business days of month end.

Who lodges the behaviour support plan?

The specialist behaviour support provider lodges it. The implementing provider then accepts it in the new portal — or, for plans lodged before 12 October 2026, activates it in the existing portal — and lodges evidence of authorisation.

Which portal do I use from 12 October 2026?

It depends on when the plan or incident was lodged. Plans and incidents lodged before 12 October stay in the existing portal, including their monthly reports. Everything lodged from 12 October, including all new incidents, goes in the new NDIS Commission Portal.

Can an unregistered provider use regulated restrictive practices?

No. It's a breach of the NDIS Rules, and it's the Commission's first-listed regulatory priority for 2026–27.

Does Comm.care submit reports to the NDIS Commission?

No. You notify the Commission and submit monthly reports through its portal. Comm.care helps you record, flag and track incidents so nothing is missed.

This article is general information, not legal or compliance advice. Always confirm your obligations with the NDIS Quality and Safeguards Commission.

Further reading

• Behaviour Support and SIL Providers: Why They Must Work as One Team
• NDIS Incident Reporting Best Practices