Conflict of interest
A conflict of interest in the NDIS is a situation where a provider's or worker's own financial, business or personal interests could influence, or appear to influence, the advice or supports a participant receives. Registered providers must proactively manage and document actual and perceived conflicts.
Also called: Conflicts of interest, COI, Conflict of interest policy NDIS, Perceived conflict of interest
Key takeaways
- The Core module requires registered providers to proactively manage and document perceived and actual conflicts of interest.
- SIL providers that also provide a participant's tenancy must have a conflict of interest policy and separate service and tenancy agreements.
- The SDA and specialised support coordination modules each have a specific conflict of interest outcome.
- Every provider and worker must act with integrity, honesty and transparency under the NDIS Code of Conduct.
- Managing a conflict means disclosing it, offering real alternatives and recording the participant's choice.
What is a conflict of interest in the NDIS?
A conflict of interest in the NDIS is a situation where a provider's or worker's own interests — financial, business or personal — could influence, or look like they influence, the advice or supports they give a participant. Conflicts are not banned outright, but registered providers must identify them, manage them proactively and document how, and every provider must act with integrity, honesty and transparency under the NDIS Code of Conduct.
The classic NDIS examples involve one organisation holding several roles in a participant's life: a support coordinator recommending their own organisation's services, a SIL provider that is also the participant's landlord, or an SDA provider whose housing comes with a particular support provider attached. In each case the participant's choice and control is what is at risk.
A conflict can be actual (the interest exists and affects a decision) or perceived (a reasonable person could think it does). The Practice Standards treat both seriously.
Where conflict of interest rules appear
There is no single "conflict of interest rule". The obligation appears in several places across the NDIS framework, each aimed at a different risk:
| Where | What it requires | Who it applies to |
|---|---|---|
| Core module: governance and operational management | Perceived and actual conflicts of interest are proactively managed and documented, including through organisational policies | Registered providers assessed against the Core module |
| SIL module: agreements about tenancy, housing and support | Policies on how conflicts are identified and managed where one provider delivers both SIL and tenancy, made available in an accessible form; separate service and tenancy agreements | Registered SIL providers (group 0138) |
| SDA module: conflict of interest | A participant's choice of other NDIS supports is not limited by their choice of SDA dwelling; conflicts are proactively managed and documented | Registered SDA providers |
| Specialised support coordination module: conflict of interest | Participants get transparent, factual advice about their support options; conflict of interest policies are explained to each participant | Registered specialist support coordination providers |
| NDIS Code of Conduct | Act with integrity, honesty and transparency | All providers and workers, registered or not |
Sources: the Commission's Core module governance standards, the SIL Practice Standards, the online NDIS Practice Standards and the NDIS Code of Conduct. The underlying rules are in the Provider Registration and Practice Standards Rules and the Quality Indicators Guidelines.
Common conflicts of interest in the NDIS
| Situation | The risk | How it is usually managed |
|---|---|---|
| Support coordinator recommends own organisation | Participant steered away from other options | Disclose, give transparent options, record the choice |
| SIL provider is also the landlord | Changing support provider could cost the home | Separate agreements; support to change SIL provider |
| SDA linked to a support provider | Housing choice limits support choice | SDA module: choice of other supports must not be limited |
| Worker supports a relative or friend | Personal ties affect boundaries and reporting | Declare, supervise and review |
| Gifts from participants or families | Perceived favouritism or exploitation | Gifts policy and register |
Other situations that often need managing include a worker providing paid support to a relative or close friend, staff accepting gifts or benefits from participants or families, a manager involved in hiring a family member, and a provider that both assesses a participant's needs and delivers the supports recommended. None of these is automatically a breach; each needs to be recognised, disclosed and handled in a way the participant can see.
Conflicts also arise in money and oversight roles. A plan manager that also delivers supports to the same participant is approving payment of its own invoices, so the participant needs to know and the organisation needs controls that separate the two. Independence matters for regulators too: an auditor assessing a provider against the Practice Standards should not be the same organisation that wrote that provider's policies.
How providers manage conflicts of interest
Auditors look for a policy that is used, not just written. A practical approach:
- 1IdentifySpot actual and perceived conflicts through declarations and reviews.
- 2DiscloseTell the participant in their preferred language and communication mode.
- 3Offer alternativesGive real options, including other providers.
- 4Decide and separateSeparate roles or agreements where the risk is high.
- 5DocumentRecord the conflict, options offered, the choice and who decided.
- 6ReviewCheck the register and patterns at governance meetings.
- Disclose early: ask workers, managers and board members to declare interests at induction and when circumstances change.
- Keep a register of declared conflicts, the decision on each and who made it.
- Separate roles where the risk is high, such as separate staff for coordination and service delivery, or separate tenancy and service agreements.
- Tell participants in their preferred language and communication mode, and offer real alternatives, including other providers.
- Record choices: when a participant chooses your services after being told about the conflict, note the options they were given.
- Review the register and policy as part of governance reporting.
In SIL homes, make the separation visible in your paperwork: a service agreement for supports and a separate tenancy agreement, each explaining that one does not depend on the other. The free NDIS Practice Standards self-assessment includes the governance and SIL indicators that cover conflicts of interest.
Conflict of interest vs related concepts
Conflict of interest overlaps with, but differs from, several other obligations. NDIS compliance is the wider set of legal obligations; a conflict of interest policy is one part of governance within it. The Code of Conduct sets the integrity duty that applies even to unregistered providers. And supported decision-making is the positive side of the same coin: helping a participant make their own choice, rather than having a provider with an interest make it for them.
- Highest-profile risk: referring to in-house services
- SDA module protects choice of other supports
- Helps the participant make the choice themselves
- Require COI policies where one provider gives SIL and tenancy
- Integrity, honesty and transparency duty
What participants should know
You are entitled to choose your providers. If a coordinator or provider recommends their own organisation, you can ask what other options exist and why they are suggesting theirs. If you rent from your SIL provider, the SIL Practice Standards say your tenancy and support agreements must be separate and that you can change your SIL provider without losing your home. If you think a conflict is affecting your supports, raise it with the provider, and you can also complain to the NDIS Commission.
Common mistakes
- Having a policy but no register, so there's no evidence conflicts were ever identified.
- Assuming disclosure is enough. The participant also needs real alternatives.
- One combined tenancy and support agreement in SIL homes the provider owns.
- Coordinators steering participants to in-house services without recording the options offered.
- Ignoring perceived conflicts because no one has acted improperly.
Example
Illustrative example (fictional). Riverbend Community Services offers support coordination, community access and in-home support. Its support coordinator, Jess, is working with a new participant, Omar, who wants help to join a weekend sports group.
Riverbend runs a weekend group program. Jess explains to Omar, in plain language, that Riverbend provides one of the options and that she works for Riverbend. She gives him three options, including two other providers, and the information he needs to compare them. Omar chooses one of the other providers because it is closer to home. Jess records the options offered and Omar's decision in his file.
At the next governance meeting, Riverbend reviews its conflict of interest register and notices that most of its coordination participants use its own in-home support. It adds a manager review of coordination referrals to in-house services and includes the data in its next board report.
Frequently asked questions
What is a conflict of interest in the NDIS?
It is a situation where a provider's or worker's own financial, business or personal interests could influence, or appear to influence, the advice or supports a participant receives, such as a support coordinator recommending their own organisation's services.
Can a support coordinator recommend their own organisation's services?
It isn't banned, but it is a conflict of interest that must be managed. The coordinator should disclose it, give the participant transparent information about other options, respect their choice and record what was offered.
Can a SIL provider also be my landlord?
Yes, but the SIL Practice Standards require separate service and tenancy agreements, a conflict of interest policy you can understand, and support for you to change your SIL provider without losing your tenancy.
Do NDIS providers need a conflict of interest policy?
Registered providers assessed against the Core module must proactively manage and document conflicts, including through organisational policies. The SIL, SDA and specialised support coordination modules add specific conflict of interest requirements.
What are examples of conflicts of interest in disability services?
Common examples are a coordinator referring to in-house services, a SIL provider that is also the landlord, SDA linked to a particular support provider, a worker supporting a relative, staff accepting gifts, and a provider assessing needs it will then be paid to meet.
How do you manage a conflict of interest in the NDIS?
Identify and disclose it, record it in a register, separate roles where the risk is high, explain it to the participant in a way they understand, offer real alternatives, document their choice and review conflicts as part of governance.
Related terms
- NDIS Code of ConductThe NDIS Code of Conduct is a set of eight legally binding rules of behaviour for all NDIS providers, their key personnel and workers, registered or not. It covers respect for rights, privacy, safe and competent support, integrity, raising concerns, preventing abuse and sexual misconduct, and fair pricing for goods.
- NDIS Practice StandardsThe NDIS Practice Standards are the quality and safety standards that registered NDIS providers must meet and are audited against. Grouped into core, verification and supplementary modules such as SIL, each standard has a participant outcome and quality indicators that auditors use to rate the provider.
- NDIS complianceNDIS compliance means meeting the legal obligations on NDIS providers and workers: the NDIS Act and Rules, the Code of Conduct and the NDIA's pricing and claiming rules, plus, for registered providers, conditions of registration such as the Practice Standards, audits and incident reporting.
- SIL Practice StandardsThe SIL Practice Standards are a supplementary module of the NDIS Practice Standards that registered supported independent living providers must meet from 1 July 2026. They add four standards to the Core module: supported decision-making, safeguarding, practice governance, and tenancy and support agreements.
- Specialist Disability Accommodation (SDA)Specialist Disability Accommodation (SDA) is NDIS funding for housing built to a specialist design standard for people with extreme functional impairment or very high support needs. SDA pays for the dwelling, not the support inside it: residents pay rent and living costs, and support is funded separately.
- Specialist support coordinationSpecialist support coordination is the third and highest level of NDIS support coordination. It funds a suitably qualified, experienced coordinator for participants in highly complex or risky situations, such as several service systems involved at once, and is usually time-limited to reduce that complexity.
- Support coordinationSupport coordination is NDIS capacity building funding for a coordinator who helps a participant understand and use their plan, connect with providers and community services, and build skills to manage supports. It has three levels: support connection, coordination of supports and specialist support coordination.
Go deeper
Sources
- ndiscommission.gov.au/rules-and-standards/ndis-practice-standards/core-module-provider-governance-and-operational
- ndiscommission.gov.au/rules-and-standards/ndis-practice-standards/sil
- ndiscommission.gov.au/rules-and-standards/ndis-code-conduct
- ndiscommission.gov.au/rules-and-standards/ndis-practice-standards
- legislation.gov.au/F2018L00631/latest/text
- legislation.gov.au/F2018N00041/latest/text
General information, not legal, clinical or financial advice. NDIS rules change — check the official source before you act.
Suppora editorial team
NDIS operations and compliance writers
The Suppora editorial team writes practical guides for NDIS providers, checked against the NDIS Commission, NDIA and Fair Work sources cited on each page.
- NDIS Practice Standards
- NDIS pricing and claiming
- SCHADS Award
- Incident management
- Supported Independent Living