- Going to the bathroom
- Briefly stepping outside to speak with a parent
- Moving with the same group of children between the indoor and outdoor environments as part of your regular supervision
Keeping records of educators working directly with children
Guidance on the strengthened requirement to keep records of educators working directly with children.
What you need to know
- Under updates to Regulation 151 in effect from 24 April 2026, a record must be kept of the rooms and times that each educator is allocated and the Working with Children Check number of each educator.
- This is not a brand new requirement – it is a meaningful strengthening of existing safety measures.
- The record helps protect children. In serious cases or incidents, detailed and accurate documentation is incredibly valuable to support an investigation and outcome that keeps children safe.
- The NSW Early Learning Commission does not prescribe the use of any particular kind of record, and acknowledges that different ways of recording information will suit different services.
- Clear and accurate records are required to be kept about which group of children educators are primarily working with throughout the day.
- If you’re unsure, it’s best to record it. A short entry only takes seconds and missing information may be impossible to recover later.
What is changing and why
Since 2012, early childhood education and care services in NSW have been required, under Regulation 151 of the Education and Care Services National Regulations, to maintain a record of educators working directly with children. The purpose of this record is to assist approved providers and regulatory authorities in monitoring compliance with educator-to-child ratio requirements. This record may be a staff roster, time sheet, or an alternative method.
A strengthened provision has come into effect on 24 April 2026 that goes one step further. In addition to recording when educators work directly with children, the record must also include which group of children each educator is working with at any given time, as well as the educator’s Working with Children Check (WWCC) number.
The purpose of the change is to ensure there is always a clear, up-to-date record of which educator was working with which children, and when. This record serves a fundamental safeguard for children in your care.
A reliable, detailed record provides the information needed to act quickly and decisively to protect children. The record of educators working directly with children is one of the most important protective records your service maintains and in a serious matter may be used by regulatory authorities, the approved provider, and law enforcement agencies to conduct thorough and accurate investigations.
The Commission recognises that early childhood education and care services across NSW organise and respond to the needs of children in a wide variety of ways. Some services group children by age, others by family grouping, interests, or by a combination of approaches.
The Commission also recognises that many services will already have mechanisms in place that record the required information or could be adapted to record it. It is not necessary to use a particular template or a particular way of the recording the information.
Regardless of the model your service uses, what matters is that there is a clear record of which room (group of children) each educator was working with at any given time.
This guidance package explains what the new requirement means in practice, offers advice on how to communicate it to your team, and provides scenarios to support consistent, common-sense implementation.
Ways to comply
A best practice roster
Many services currently use a record of their roster to respond to the Regulation 151 requirement. Where a roster record is sufficiently detailed it is capable of also meeting the updated requirements.
The roster record would need to include (in an appropriate way) the names and WWCC numbers of educators. It would also need to include detailed information on who is working with which children at any point in the day (i.e. including staff breaks and beginning and end of day arrangements).
To be an accurate record, deviation from the roster (i.e. if arrangements shift in the course of the day, so that different educators are working with different children) must be recorded. Services should carefully consider how any deviations will be reliable and consistently recorded.
Other acceptable records
The Commission is aware that there are many other ways of keeping records of which educators are working with which children during the day. These can include:
- digital records based on swipe cards or other tracking, or where date is directly entered into tablets etc
- paper-based contemporaneous records that capture movements across all rooms or groups throughout the day
- annotated daily programs or planning documents, where they record which educator was working with which group of children at particular times.
Regardless of the format used, the key requirement is that the record reflects actual practice on the day, and makes it possible to clearly identify which educator was working with which group of children at any given time.
An optional template
To support your service to adjust to the strengthened requirements, a template for keeping the Educator Working Directly with Children Record has been developed. The template is in the form of a ‘sign-in-sign-out’ sheet that could be used by ‘room’ or group of children.
Using the template will ensure that the necessary information is captured and that the requirements of Regulation 151 are met – so long as it is stored with an accurate list of staff names and Working With Children Check numbers.
Using the template is not mandatory. Many services already use other records or systems that, if they capture the required information, will meet the requirements of Regulation 151. Services may also find that adapting the template to their unique circumstances may make it more accessible or effective for their staff.
The key requirement is that a record is kept that includes all the required information.
Download the template
Including WWCC numbers
Working with Children Check numbers need to be included in the record but should be treated as sensitive personal information and handled securely. This means that for services using paper-based sign-in/sign-out sheets (like the optional template) it is usually not appropriate to include each staff member’s WWCC number on the sheet.
Instead, when the sheets are collated (for example at the end of the week) a list of staff and the WWCC numbers should be included with the record. Digital records also need to include the WWCC in an appropriate way.
What this means for educators
The way this requirement is met will depend on the system your service uses to keep records.
In all cases, there must be a clear and accurate record of:
- when you are working directly with children, and
- which group of children you are primarily working with during that time.
This may be recorded:
- directly by you (for example, signing in and noting your room or group), or
- automatically through a system used by your service (for example, swipe cards or digital records).
What matters is that the record reflects actual practice on the day.
What this does NOT mean for educators
- You do not have to personally write down which group of children you worked with, if your service uses a system that already captures this information.
- You do not need to record brief or routine movements, such as:
- stepping away to use the bathroom
- briefly speaking with a parent or colleague
- collecting materials or answering the phone.
- You do not need to record every transition between physical rooms or indoor and outdoor spaces when moving with the same group of children.
- There does not need to be a minute-by-minute account of the day.
The guiding principle is straight forward: If someone needed to know which group of children you were working directly with for at a particular time of day, the record should be able to answer that question clearly.
Frequently asked questions
No. Routine, brief departures from your group don't need to be recorded.
Record each period working with a different group of children. If you spend meaningful time with more than one group across the day, that should be reflected in your entries.
No. you are not expected to record every transition throughout the session. What matters is that there is a clear record of which group of children you were primarily working with over a period of time. If your service operates as a single group, you can record that group for the session. If you are responsible for a particular space (for example, outdoor play, hall, or art area), you can record that instead.
Your professional judgement is important here. A lunch break, administrative time, or a sustained period working with a different group are all meaningful. A quick trip to get a supply from another room is not.
No you do not. In many services children are grouped by ‘rooms’. Your service may group children in some other way (or simply use different language like ‘class’, ‘age group’ etc). The key thing is to ensure that there is an accurate record of which group of children you were working with.
What matters is keeping a record of which educators are working directly with which children throughout the day. Some services make detailed forward-plans or rosters that include all meaningful changes (e.g. lunch cover, end of day groupings etc). If these are annotated at the end of the day with any unexpected changes, they can meet the requirement of Regulation 151. This approach is more likely to be practicable where there is a small number of staff.
Record it as soon as you remember, and note the approximate time. Honest, best-effort records are far better than gaps.
Scenarios
Scenario 1 – A day with one room and a lunch break
Does NOT need to be recorded
Should be recorded
- When you commence working with children: including the time and group/room you are working with (e.g. 'Wombats')
- Time of your lunch or other breaks
- Returning from a lunch break: recording the time and the group /room.
Scenario 2 – Educator covers a different room during a colleague's break
Does NOT need to be recorded
- Every transition between rooms throughout the day, such as briefly speaking to another educator or collecting resources
Should be recorded
- When you leave your primary group to work in another room/group for a period of time
Scenario 3 – Educator undertakes administrative or planning time
Does NOT need to be recorded
- Brief interruptions, such as stepping away when the phone rings
- Time spent completing a document such as an incident or medication record in the room while supervising children
Should be recorded
- Transition from working with children to dedicated office/admin time
Scenario 4 – Educator works across multiple groups throughout the day
Does NOT need to be recorded
- Brief moments of interactions with children from another group during a shared outdoor session
- Informal conversations or assistance provided to children passing through an area
Should be recorded
- Substantive period spent primarily working with a particular room or children
- If your role involves moving between groups in different spaces, your entries should clearly indicate this e.g. that you are working with both groups
Scenario 5 – OOSH with a single group
Does NOT need to be recorded
- Moving with the same children between indoor and outdoor spaces (e.g. from hall to oval)
- Routine transitions as a group through the session
Should be recorded
- The time you start and finish and any breaks
Scenario 6 – OOSH with multiple groups
Does NOT need to be recorded
- Brief interactions with children from another group
Should be recorded
- The periods you worked with each group of children
Scenario 7 – Educator stationed in a space during free-flow sessions (OOSH or other ECEC)
Does NOT need to be recorded
- The name of every child who enters or leaves the space
Should be recorded
- The periods you worked in a particular space (e.g. outdoor play, art area, hall etc)
In free-flow sessions, children move between spaces according to their interests. The Regulation 151 record captures where each educator was stationed and when, and the Commission recognises that in genuinely free-flow sessions it will be impractical for the record alone to clearly identify which children were in each space at a particular time.
Services should consider whether free-flow operation is genuinely unavoidable, or simply a default that could be revisited. A more structured approach to groupings, even a loose one, produces a more complete record and a more protective one. The more clearly a record can answer the question of which children were with which educator, the better placed a service is to respond quickly and thoroughly if something serious occurs.
Scenario 8 – Transport
Does NOT need to be recorded
- Records kept pursuant to Regulation 102 do not need to be duplicated
Should be recorded
- All transport in line with Regulation 102, including the children and educators involved
The guiding principle
Ask yourself: "If someone needed to clearly and quickly understand which children I was working with at any point during my shift today, could they read the working with children record and know the answer?"
If the answer is yes, then you have met the requirement. If there are any gaps, make sure to fill them in.
The strengthened Regulation 151 requirement can be flexibly implemented. It focuses on maintaining a reliable, up-to-date record that shows where educators were working, and which children they were with throughout the day.
During everyday service operation, this record helps ensure educator-to-child ratio compliance, supports supervision planning, and encourages professional reflection. In exceptional circumstances, when serious issues arise and children need protection, it can become one of the most important documents your service maintains.
We encourage all staff to approach this responsibility with the same care and professionalism that guides your work with children every day.