I know this is painful. It has nothing to do with helping students or their learning. It's just something we have to do.
I had that quiet word to teachers when I was a principal. I suspect you have too (or at least considered it). The NCCD Guidelines say schools are not required to collate NCCD evidence into one document. But they do because, if audited, schools must locate the evidence. What leadership teams tell me they are doing: spending weeks with IT modifying their SIS or LMS as a single source of truth for the evidence. Then they carve out staff meetings for teachers to backfill the system.
What the NCCD documents say about creating evidence
The official position is consistent across the Guidelines and the Department's fact sheet.
| What the document says (verbatim) | Where |
|---|---|
| "Evidence of adjustment(s) provided for students with disability should be collated during the course of implementing the adjustments, not created separately." | Guidelines, C.5.1, p.25 |
| "Evidence to support the NCCD should be drawn from classroom practice already in place" | Evidence Requirements for the NCCD fact sheet, p.2 |
| "Schools are not required to collate the evidence into one document." | Fact sheet, p.2 |
| "the evidence will be reviewed in whatever existing form(s) is held by the school" | Fact sheet, p.2 |
| "Duplication of evidence into other forms (for example, from paper to electronic), different formats (for example, an alternative template) or to other locations (such as a school portal or similar), is not required by the Department of Education at class, school or system level." | Fact sheet, p.2 |
| "The Department of Education strongly encourages school staff responsible for gathering evidence not to create unnecessary documentation." | Fact sheet, p.3 |
Why schools build a source of truth anyway
I have talked with dozens of schools that have built their own system for collating the evidence teachers collect. Learning Support and IT spend weeks modifying the student information system, the learning management system or the diocese platform to be "the source of truth" for NCCD evidence.
Once the system exists, a staff meeting each term is set aside for teachers to go back through their own lesson plans, emails and notes to find what they need, enter it into the system, and write down where the original lives in case the school is audited.
Maybe you can relate.
The evidence sits in multiple, siloed places. Consider just some of the evidence sources listed in the Guidelines (C.5.1, pp.25 to 26):
- an individual learning plan,
- a timetable showing a specialist support,
- an email to a parent, a note from a review meeting,
- a functional needs checklist
In a school, those generally live in a unit planner on a Word doc in SharePoint, in a child's profile in the LMS, in a teacher's inbox, and in a communication book that went home in a school bag on Friday. Some evidence might still be on a teacher's pile of post-its that they plan to enter when they get the time.
For schools that have not set aside meetings each term, teachers have not appreciated the last-minute scramble to collate evidence. In Reddit prior to census, a few indications of teacher feelings emerged:
I've got 12 NCCD kids. Most in the school and I'm not exaggerating. I get 20 minutes a day. I asked for release time to complete my NCCD properly and got given crickets.
I get zero time, none of us do. It's just another new added requirement. I have 18. We have to record all interactions that provide proof the students get their IEPs met throughout the year, not just this week.
I had the head of special ed come to me today asking for evidence. First time they have talked to me this year, and I have 7 substantial support students with no teacher aide or support…
School leaders knew they needed the evidence from teachers to recover funding for the adjustments that these teachers have made. If the teachers aren't able to get the information to the leaders to collate, they risk hundreds of thousands of dollars in recovery funds per school.
What the audit asks a school to produce
Auditors want to see that evidence includes documentation covering four areas: identified need, adjustments, consultation and collaboration, and monitoring and review.
Independent Schools Victoria's 2026 guidance to its schools on the post-enumeration audit puts the student-level test in one line: "Whole-school adjustments are only enough if you can clearly show what each student got, when, how and how often."
The consequences of a level the school cannot substantiate are listed in B.1.3, p.10. The Department may take:
- Being unable to calculate the student with disability loading for a school for a year,
- Action to recover overpayments of disability loading funding, and
- Consideration of compliance action under the Act against an approved authority.
The audit accepts any format. It requires no new documentation. But you must produce evidence on demand.
What it costs a school
I often think about what the source-of-truth project costs in staff hours. Or just as bad — the hours chasing evidence pre-census.
Consider that the Learning Support Leader is likely the person in the school most qualified to be observing students with needs and coaching teachers. Actual support may be put on hold to document support.
Staff meetings are precious time to move forward a school's strategic plan or to upskill teachers. Some are used for compliance requirements such as WH&S updates. And now we have meetings to copy and paste evidence into a source-of-truth. Recent bargaining agreements in Victoria and elsewhere have cut the numbers of hours teachers are required to attend meetings. What gets bumped?
Then there is the cost to culture when leaders have to use phrases like, "I know it doesn't contribute to learning. We just need to do it." Culture cost isn't tracked.
But how, without more staff?
Teachers that I know who have burned out from admin don't narrow it down to one thing. Their descriptions are more similar to "death by a thousand cuts".
It's tough to reconcile two concurrent truths from the NCCD documents:
"Recording the adjustments to be provided to a student is sufficient."
AND audit reviews requesting "evidence of supports delivered, aligned with both the frequency and intensity of the level of adjustment reported."
Teacharo was built to help.
Frequently asked questions
Do schools have to create new evidence for the NCCD?
No. The NCCD Guidelines: Effective 2026 Onward say "Schools are not required to create new or additional evidence for the purposes of the NCCD" (B.1.1, p.9). Evidence should be collated while adjustments are implemented, "not created separately" (C.5.1, p.25).
Can we use existing classroom records as NCCD evidence?
Yes. The Guidelines name an individual learning plan or similar, timetables showing adjustments or specialist supports, emails to parents demonstrating consultation, notes showing monitoring and review, and functional needs checklists (C.5.1, pp.25 to 26).
Do we have to put all NCCD evidence in one document or one system?
No. The Department's fact sheet says "Schools are not required to collate the evidence into one document" and that duplicating evidence into other forms, formats or locations is not required at class, school or system level.
Does the audit accept evidence in any format?
Yes. For the non-government Census Post-Enumeration, "the evidence will be reviewed in whatever existing form(s) is held by the school" (fact sheet, p.2). The school still has to produce it for the four evidence areas.
What does the Census Post-Enumeration check?
It validates that the student counts a non-government school reported are accurate and appropriate for funding, and it "sights NCCD evidentiary documentation" (Guidelines C.6.4, p.28). Individual student records may be collected and reviewed.
What happens if we cannot substantiate a student's level at audit?
The Guidelines list three possible results: the Department being unable to calculate the disability loading for that year, action to recover overpayments, and consideration of compliance action against the approved authority (B.1.3, p.10).
How much documentation is too much?
The Department's fact sheet gives examples. Recording an adjustment in the program is sufficient; post-lesson annotations, narrative explanations, photographs and voice recordings where notes exist are "in excess of what is required" (p.3).
How we check this guide
Last reviewed 9 September 2026 against the NCCD Guidelines: Effective 2026 Onward and the documents below. Reviewer: Janet Moeller, former principal, founder of Teacharo. Every quotation is verbatim from the document named.
Sources:
- NCCD Guidelines: Effective 2026 Onward (PDF), Sections B.1.1, B.1.3, C.5.1, C.6.4, C.6.5, C.7.
- NCCD Guidelines page, including "Clarification: Evidentiary requirements for the 2026 NCCD".
- NCCD Quick Guide 2026 (PDF), Step 6: Quality assurance.
- Evidence Requirements for the NCCD, Australian Government guidance for schools in the non-government sector (fact sheet, 3 pp.).
- Examples of evidence to support a student's inclusion in the NCCD, v2.0, 2022 (PDF).
- Notice for schools and school principals 2026 (NCCD Portal), on the principal's responsibility to verify documented evidence.
- Independent Schools Victoria, 2026 Post-Enumeration Audit: Updated Guidance for Schools.