Run service approval and Child Care Subsidy approval against the building, not after it
A finished, fitted-out, empty childcare centre carrying full finance waits 90 days for service approval and then 60 more for Commonwealth subsidy approval. Most of what both examine is knowable from the approved plans months earlier.
Steps this would change
Rationale
On the NSW childcare process the critical path runs 1,000 days, and the last 150 of them happen after the building is finished.
The sequence at the end is: occupation certificate, then service approval (90 days, statutory), then Child Care Subsidy approval (about 60 days), then open. The centre is complete throughout. It is staffed, or paying to hold staff it has hired. It is carrying finance and earning nothing.
Service approval. Examines the premises — layout, indoor and outdoor space per place, fencing, sightlines, amenities — and the nominated supervisor. Almost all of that is determined by the approved plans and could be assessed on the plans, with a physical inspection confirming that what was built matches. That is exactly how building certification already works, and the National Law already permits an application before the service commences operating. The proposal is that the assessment substantively begin at the construction certificate stage rather than at completion.
Child Care Subsidy approval. This one is harder to defend as sequential at all. It is a Commonwealth fitness-and-tax-record check on an operator whom the state regulatory authority has just examined, and it depends on the service approval only by convention. It could run concurrently and issue conditionally on service approval being granted.
The result is that a centre finished in March opens in March rather than August. Given the Commonwealth guaranteed 72 hours a fortnight to all eligible families from 5 January 2026, the gap between funded demand and available places is the whole problem, and 150 days per centre is a direct contribution to it.
Who acts: the states for service approval, the Commonwealth alone for the subsidy approval. The Commonwealth half needs nobody's agreement and is the cheapest thing on this page.
What is being traded away
Assessing plans is not assessing a building, and childcare is a bad place to learn that. Space per child, sightlines from the staff position, fencing that a determined three-year-old cannot pass — these are the things that turn out differently in the built room than on the drawing, and they are the things that matter. Any version of this reform has to keep a full physical inspection before the service operates, and must not let early assessment become a presumption that the inspection is a formality. If the reform saves time by making the inspection perfunctory, it should not happen.
Rework. A centre whose fit-out changes after an early assessment consumes regulator time twice, and regulator time in this sector is the scarce input that also has to be spent on assessment and rating and on compliance. Taking capacity from oversight of operating services to accelerate openings would be a bad trade, and it is the trade that will be made if this is implemented without extra resourcing.
Timing against a tightening regime. This is being proposed in the same period that the National Law is being deliberately strengthened after serious harm to children. The two are compatible — nothing here changes what is assessed, only when — but the sequencing of the public argument matters. A regulator asked to go faster in the same year it is asked to be more careful will reasonably want to know which instruction wins, and the answer has to be that care does.
Precedent
Provider approval already attaches to the operator rather than the premises and is recognised nationally and ongoing, so an existing provider does not repeat it. The same logic — assess what can be assessed early, confirm the rest on inspection — is ordinary practice in building certification.
Sources
- ACECQA, Guide to the National Quality Framework, applications and approvals — 60 day provider approval and 90 day service approval decision periods
- Department of Education (Cth), published guidance on the Child Care Subsidy approval process, including the Statement of Tax Record requirement from 1 April 2025
- Department of Education (Cth), 3 Day Guarantee, in effect from 5 January 2026