What the Act lists as grounds, what the annual report says, and what the published orders say about money and personal information.
NDIA guidance describes the role of a plan manager as financial administration of a participant’s plan funding. Providers send invoices to the plan manager, who verifies them with the participant and pays the provider on the participant’s behalf. Plan managers check that claims are in line with the plan, the budget and NDIS price limits, keep invoices and records for the claims they submit, and give the participant a monthly statement of spending and the remaining balance. The guidance says a plan manager should get the participant’s approval before submitting claims, so that what was delivered matches the invoice.
Paying an invoice without checking it against the support received can let an incorrect claim through and leave less funding for later supports. The NDIA gives a case in which a plan manager paid claims for more hours than were delivered, and afterwards put in a process to check every invoice.
A participant’s plan, invoices and payment records can reveal personal information about the supports they receive. The NDIS Code of Conduct requires providers and workers to respect the privacy of people with disability. The NDIS Practice Standards include an Information Management outcome, which says participant information should be identifiable, accurately recorded, current and confidential, and that participants are told how their information is stored and used.
Section 73ZN of the National Disability Insurance Scheme Act 2013 lets the Commissioner make a banning order against a provider (s73ZN(1)) or a worker or key personnel (s73ZN(2)) on these grounds:
Financial mismanagement, poor records and privacy breaches are not listed by name. They could be relevant through the contravention or suitability grounds, depending on the evidence. We make no claim about how often that has happened, because the report and register do not say. The NDIA lists claiming for supports that were not provided as an example of fraud. Billing for supports not delivered is the kind of conduct that can lead to a fraud investigation, and a conviction for fraud or dishonesty is an express ground.
The annual report says orders were issued for a range of suitability and compliance-related issues, including findings arising from fraud investigations. It gives one total and no breakdown.
The register describes what each order restricts, which is different from why it was made. We searched that text for key phrases. One order can match several rows.
The first two rows describe restrictions placed on a person, such as not accessing a participant’s personal or financial information. They do not show that the person misused information. The register text rarely states reasons, and the word “privacy” does not appear in the text of any of the 859 orders. So the register cannot show how many orders arose from financial or privacy failures.
The table below gives examples of how billing, recordkeeping and privacy failures can affect participants. The examples are illustrative. They are not drawn from any banning order.
| Risk area | Illustrative example | How it can affect participants |
|---|---|---|
| Financial management | A provider fails to reconcile invoices and payments, and a duplicate payment goes unnoticed. | A duplicate payment can leave less funding for future supports. |
| Financial information | Payment records are incomplete, so a charge cannot be matched to a service. | The participant may struggle to verify or dispute the charge. |
| Privacy | An invoice containing participant details is sent to the wrong recipient. | Personal information about the participant or their supports may be exposed. |
| Plan funds management | A plan manager submits a claim without checking the plan or getting the participant’s approval. | Funding may be used incorrectly, reducing what is available for eligible supports. |
| Claims misconduct | A provider knowingly claims for support that was never delivered. | The participant’s budget may be charged for a service they never received. |
A participant who sees an unfamiliar charge can ask their plan manager to explain the invoice and check it against the support received. Suspected fraud or misuse of plan funds can be reported to the NDIA, and concerns about provider conduct can be raised with the NDIS Commission.
Sources: NDIS Quality and Safeguards Commission, Annual Report 2025–26, table 2 and commentary (pages 59–60); the Commission’s compliance and enforcement actions register, retrieved 4 November 2026; the Commission’s NDIS Code of Conduct page and NDIS Practice Standards and Quality Indicators (November 2021, version 4); the NDIA pages What is a plan manager, Guide to working as a plan manager and What is fraud; and the National Disability Insurance Scheme Act 2013, section 73ZN (Compilation No. 28, registered 12 October 2026). Retrieved 13 November 2026. The Commission material is © Commonwealth of Australia and licensed under Creative Commons Attribution 4.0 unless stated otherwise (see the Commission’s copyright and disclaimer page). The counts, classifications and commentary on this page are our own analysis of that material, and the Commission has not reviewed or endorsed them.
Claims for supports not delivered can lead to a fraud investigation. Evidence Store & Audit Export keeps your records and audit evidence in one place so you can show what was delivered and paid.
See how Evidence Store & Audit Export handles thisGeneral information only, not legal advice. Spotted an error? Email [email protected].