NDIS high intensity supports: do you need to be registered?

Short answer: not in itself, but it depends on the participant. In Australia, high intensity daily personal activities are not on the list of supports that require registration with the NDIS Quality and Safeguards Commission (the NDIS Commission). If you are not registered, though, you can only deliver them to a participant who self-manages or plan-manages their National Disability Insurance Scheme (NDIS) funding. Anything delivered to a participant whose plan is managed by the National Disability Insurance Agency (NDIA) requires registration, whatever the support.

The Commission's own guidance on the high intensity skills descriptors puts the first half of that plainly, under the heading "What about participant choice?": "The class of support 104 high intensity daily personal activities does not in itself require registration."

Last updated 26 October 2026. Jurisdiction: Australia, all states and territories.

Do you need to be registered to deliver NDIS high intensity supports?

Four questions decide it, and registration is only the first.

1. Is registration mandatory for this class of support? No, not in itself. High intensity daily personal activities are not on the NDIS Commission's list of supports that require registration. Question 2 is what usually decides whether you can take the work.
2. How is the participant's funding managed? Only participants who self-manage or plan-manage can choose an unregistered provider. NDIA-managed participants cannot.
3. If you are registered, is the support on your certificate of registration? A registered provider must not deliver a high intensity support that is not set out on its certificate.
4. Is your worker competent to deliver the support? This obligation does not depend on registration at all, and it is the one that causes harm when it is missed.

What the NDIS Commission says you must be registered for

The Commission publishes a closed list. Its registration page says "You must be registered to provide:"

• "specialist disability accommodation (SDA)"
• "specialist behaviour support services"
• "supports or services to NDIS participants with NDIA-managed funding, and"
• "plan management services"
• "supported independent living (SIL)"
• "NDIS digital platform services."

It adds: "You must also get registered if you plan to use regulated restrictive practices." And then the sentence that settles the question for everything else: "Unregistered providers can deliver supports and services to participants, except for those listed above."

High intensity daily personal activities are not on that list. Neither is personal care generally. Registration is mandatory because of who you deliver to and a handful of named higher risk supports, not because a support is clinically complex. The Commission writes the class of support as both 104 and 0104, depending on the page.

How the participant's funding is managed matters more than registration does

The Commission's registration page states that "Only participants who self-manage or plan-manage their NDIS funding can choose to get supports and services from unregistered providers." That one sentence does most of the work in practice.

Participant's funding	Can they use an unregistered provider?	What that means for high intensity supports
NDIA-managed	No	You must be registered, and the specific high intensity supports must be on your certificate of registration
Plan-managed	Yes	An unregistered provider can deliver them, subject to competence and the NDIS Code of Conduct
Self-managed	Yes	Same as plan-managed

So registration is not triggered by the support being high intensity. It is triggered by the participant's plan being managed by the NDIA, which is true of every support, not just complex ones. That is why this question comes before the clinical one. Our guide to becoming a registered NDIS provider sets out the rest of the registration decision, and our guide to becoming an independent support worker covers it from a sole trader's position.

If you are registered, your certificate limits what you can deliver

Registration cuts both ways. Being registered does not entitle you to deliver high intensity supports. It restricts you to the ones you have been assessed for.

The Commission states that to be registered for the class of support 104, "an applicant must be assessed against relevant NDIS Practice Standards contained in Module 1" of the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018. It then states the limit: "Registered NDIS providers must not provide high intensity daily activity supports that are not set out in their certificate of registration, in accordance with section 13C of the Provider Registration Rules."

Two practical consequences. First, if a participant asks you to start a support that is not on your certificate, the certificate has to change before you deliver it, not afterwards. Second, group 0104 sits on the certification side of the audit split: the Commission's table of registration groups records registration group 0104, High Intensity Daily Personal Activities, as requiring a certification audit, and the Commission says that "Providers requiring a certification audit provide more complex or higher risk supports and services". That is the larger two stage audit with an onsite component, not the desktop verification audit. Our verification audit guide explains the difference, and the Core Module self-assessment checklists cover the standards that apply before Module 1 is added on top.

Which list of skills descriptors is current, and why the counts differ

The competency expectation for these supports sits in a separate Commission document: "NDIS Practice Standards: High intensity support skills descriptors", Version 3, November 2022. The Commission says the reviewed version "came into effect from 1 February 2023".

Version 3 is explicit about the count that matters: "There are eight skills descriptors that formally link to the HIDPAs" (high intensity daily personal activities). It carries a ninth descriptor heading, Epilepsy and Seizure Support, under "Additional support activities", and that section states "This skills descriptor is not formally linked to the HIDPA practice standards."

So you will see both eight and nine online, and both are defensible if you say which you mean. Nine descriptor headings, eight of them formally linked, is the accurate formulation. "Nine high intensity daily personal activities" is not.

The eight that formally link, as Version 3 names them, are Complex Bowel Care, Enteral Feeding Support, Dysphagia Support, Ventilator Support, Tracheostomy Support, Urinary Catheter Support (covering in-dwelling, in-out and suprapubic catheters), Subcutaneous Injections and Complex Wound Care Support.

There is a second, less obvious trap. A superseded Version 2 of the same document, dated November 2021, is still published on the Commission's website and still turns up in search results. It lists twelve descriptor headings against Version 3's nine and renames most of the rest, so a provider who builds a training matrix from it will build the wrong one. These are the four differences most likely to produce a wrong matrix.

Support area	Version 2, November 2021 (superseded)	Version 3, November 2022 (current)
Diabetes	A high intensity descriptor in its own right, "Manage diabetes"	No separate descriptor
Stoma care	A descriptor under additional support activities, "Stoma care"	No separate descriptor
Mealtime preparation	A descriptor under additional support activities, "Mealtime preparation and delivery"	No separate descriptor
Wound care	A descriptor under additional support activities, "Pressure care and wound management"	Complex Wound Care Support, one of the eight formally linked descriptors

Most of the remaining descriptors were also renamed between the two versions. Version 2 lists "High risk of seizure" under additional support activities, where Version 3 lists "Epilepsy and Seizure Support" in the same section. If your competency framework names a diabetes descriptor or a standalone stoma care descriptor, it was written against Version 2. Check the version line on any descriptor document before you build a training register from it.

One further naming point explains a lot of apparent contradictions. The descriptors document and the Commission's registration page use different words for the same supports: "Enteral Feeding Support" and "Dysphagia Support" in the descriptors, against "Enteral feeding and management" and "Severe dysphagia management" on the registration page. Both are current Commission pages, so if you tabulate them, label which source each column comes from.

Who can train a worker, and who signs off competency

This is where most of the confusion sits, so it is worth quoting the regulator directly.

On whether a clinician has to deliver the support, the Commission is unambiguous: "It is not a requirement that high intensity daily personal activity supports are delivered by a nurse or other health or allied health practitioner." Material telling you that you must employ a registered or enrolled nurse in order to deliver these supports is contradicting the Commission.

On training, there is a general rule and one exception:

• Most supports: "For most of the high intensity daily personal activity supports, worker training should be delivered by an appropriately qualified health practitioner or a person who meets the expectations of this skills descriptor."
• Severe dysphagia management: "For severe dysphagia management, training should only be delivered by an appropriately qualified health practitioner." The option of a non-clinician who meets the descriptor is not offered for this one support.

That asymmetry is easy to miss and it changes how you build a training matrix. Dysphagia is the strictest of the eight.

Responsibility sits with the provider. The descriptors document says "NDIS providers are responsible for ensuring workers have current skills and knowledge, and that the training of workers is documented and regularly audited", and the Commission's questions and answers add that "Providers should assess as appropriate all persons providing training on the high intensity supports."

On frequency, read the verbs carefully, because the descriptors document recommends rather than requires. For complex bowel care it says "It is recommended that a worker's competency to provide complex bowel care supports are reviewed annually", and it repeats the pattern for the other descriptors, including where "a worker has not delivered this support for a period of more than three months". The annual review and the three month gap are recommendations. That makes them a sensible default to adopt and document as your own standard, rather than a rule you are breaching if you set a different documented interval for a good reason.

What the Commission does not do is name a profession that must sign off a worker as competent. Its questions and answers go to who may deliver the training, and expect a provider to be able to show that a trainer is competent, but they do not say who assesses the worker. So your own competency framework is where that decision gets made, and it should say who assesses, against what, and how the result is recorded.

Nursing delegation is a different question with a different answer

A great deal of confusion comes from treating two separate frameworks as one.

The skills descriptors are an NDIS instrument. They describe the skills and knowledge a worker should have, and the Commission says a nurse is not required to deliver the support. Nursing delegation is a different matter: where a registered nurse delegates a clinical task to a support worker, that delegation is governed by nursing regulation and by the law of the state or territory where the support is delivered, not by the NDIS Practice Standards.

Meeting a skills descriptor is not the same as holding a valid delegation, and a delegation does not remove the descriptor expectation. If a health practitioner is directing a support, get that direction in writing, record who gave it and when it was reviewed, and take clinical and legal advice on the delegation itself. It is outside what any template or NDIS guide can settle for you.

Claiming a high intensity item is not the same as being able to deliver it

The NDIS pricing documents list separately priced high intensity support items alongside the ordinary personal support items. The price limit tells you the maximum you can charge. It does not establish that your worker is competent, that the support is safely planned, or that it is on your certificate if you are registered. Those come from the Practice Standards and the skills descriptors. Before you claim, use the pricing document in force on the day the support was delivered; our guide to NDIS price limits and the pricing determination explains which document that is and why the legal basis changed in 2026.

What still applies if you are not registered

This is the part most coverage leaves out, and it is the part that matters most to a sole trader.

In its summary of the instruments that apply to high intensity supports, the Commission describes the NDIS Practice Standards and Quality Indicators as "Must be met by registered NDIS providers" and "Advisory for unregistered providers". So an unregistered provider is not audited against Module 1.

The NDIS Code of Conduct is different. It binds registered providers, their key personnel and workers, and equally "unregistered NDIS providers, their key personnel and NDIS workers", among others. Its third element requires a provider or worker to "provide supports and services in a safe and competent manner with care and skill". Delivering enteral feeding or complex bowel care without demonstrable competence is a Code of Conduct problem whether or not you are registered, and the Commission can take action on it.

In practical terms, an unregistered provider delivering high intensity supports should treat the skills descriptors as the yardstick a regulator would use to judge "safe and competent", even though the Practice Standards themselves are advisory for you. The same logic applies to behaviour support: see our guide to implementing a behaviour support plan, where registration is mandatory for a different reason. Also worth reading are our guides to the NDIS Code of Conduct, worker screening clearances and how long NDIS providers must keep records.

Could registration become mandatory for high intensity supports?

Possibly, but nothing has been made yet.

The NDIA has published that "The 2026-27 Budget funded the expansion of mandatory registration from 1 July 2027 to all high risk supports." That is a funding commitment and a statement of intent. The only two things that page names as requiring registration are supported independent living supports and NDIS digital platform providers. Beyond "all high risk supports" it does not say which supports are in scope, and it does not use the words "high intensity". The Commission's current list of supports requiring registration, quoted above, does not include high intensity daily personal activities, and no rule or Commission page we can find names registration group 0104 for mandatory registration, whatever date you may see published elsewhere.

The useful preparation is the same either way: hold the documentation and the competency evidence a certification audit would ask for, because if the expansion does reach personal care, that evidence is what you will be assessed on. The SIL mandatory registration change that commenced in 2026 is a reasonable guide to how much notice providers get.

In a supported independent living setting, an older NDIA page on roster of care submissions also describes the evidence the NDIA looked for about high intensity support needs, including how recent the reports should be. That page is dated 2023 and the NDIA's current guide does not repeat it: see is a SIL roster of care required, and who submits it.

What a provider delivering high intensity supports usually needs in place

The list below is practical rather than a statement of legal requirements. These are the artefacts a certification auditor is likely to ask a registered provider for, and the records that make the Code of Conduct duty demonstrable for an unregistered one.

• A written policy and procedure for each high intensity support you actually deliver, not a generic clinical policy.
• A participant specific plan for each support, developed with the participant and the health practitioner involved in their care.
• A competency assessment record for each worker for each support, naming who assessed them, against what, and when.
• A training record showing who delivered the training and what qualified them to deliver it, with the stricter rule applied to severe dysphagia.
• A documented reassessment interval. Adopting the Commission's annual and three month reassessment recommendations is the straightforward option.
• A written order or delegation record wherever a health practitioner is directing the support.
• Incident and emergency procedures specific to the support, and a route into your reportable incident and complaints processes.
• Monitoring records showing the support was delivered as planned, for example administration records and monitoring charts.
• If you are registered, a certificate of registration that actually lists every high intensity support you deliver.

Medication related supports overlap here. Subcutaneous injections and enteral routes are high intensity supports with their own training expectations, on top of the ordinary medication rules; see the six rights of medication administration.

Templates for this topic

The High Intensity Supports Add-On Module is organised as a framework set plus one group per support area: for each area, a policy and procedure, a participant plan, a competency assessment and a monitoring record, such as HI-01-03 Complex Bowel Care Competency Assessment. It is an add-on and assumes you already hold core module documentation, which is in the NDIS Provider Core Library. An unsigned competency assessment is not evidence of anything.

Pack, 45 templatesHigh Intensity Supports Add-On Module$199Template HI-00-01High Intensity Daily Personal Activities Policy$24.99Template HI-00-02Worker Competency and Training Framework$24.99Template HI-00-06Health Practitioner Delegation and Written Order Template$24.99

See every document and its current version on the What is in the High Intensity Supports Add-On page, or compare packs on which pack is right for you.

Templates are a starting point. Each one needs customising to how you work and putting into practice, and audit and claim outcomes depend on your practice and records, not on the documents.

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Frequently asked questions

Can an unregistered sole trader deliver high intensity supports?

Yes, to a participant who self-manages or plan-manages their NDIS funding. High intensity daily personal activities are not on the NDIS Commission's list of supports that require registration, and the Commission states that the class of support 104 does not in itself require registration. You cannot deliver any support to a participant whose plan is NDIA-managed unless you are registered. The NDIS Code of Conduct still requires you to provide supports in a safe and competent manner with care and skill, so you need to be able to show your competence either way.

Does a support worker need a nursing qualification for enteral feeding or subcutaneous injections?

No. The NDIS Commission states that it is not a requirement that high intensity daily personal activity supports are delivered by a nurse or other health or allied health practitioner. What is expected is that the worker meets the relevant high intensity support skills descriptor, that their training was delivered by an appropriately qualified health practitioner or a person who meets the descriptor, and that the provider can document it. Nursing delegation is a separate legal question governed by nursing regulation and state or territory law.

How often does high intensity competency have to be reassessed?

There is no legislated interval. The Commission's skills descriptors recommend that a worker's competency is reviewed annually, and that a worker is reassessed where they have not delivered the support for more than three months or where the participant's support needs change. Those are recommendations rather than rules, so the practical approach is to adopt them as your own documented standard and keep the records that show you follow it.

Is epilepsy and seizure support a high intensity daily personal activity?

Not formally. Epilepsy and Seizure Support appears in Version 3 of the skills descriptors under additional support activities, and the document states that this skills descriptor is not formally linked to the high intensity daily personal activity practice standards. There are nine descriptor headings in the document and eight of them formally link. Providers commonly deliver seizure support alongside other high intensity supports and should still have a plan, training and records for it, but it does not sit inside the Module 1 scope in the way the other eight do.

Sources

• NDIS Quality and Safeguards Commission, About registration (the list of supports requiring registration, and what unregistered providers can deliver), read 26 October 2026.
• NDIS Quality and Safeguards Commission, High Intensity Daily Personal Activities (registration group 104, section 13C, nurse not required, training rules, the 1 February 2023 effective date), read 26 October 2026.
• NDIS Quality and Safeguards Commission, NDIS Practice Standards: High intensity support skills descriptors, Version 3, November 2022, read 26 October 2026.
• NDIS Quality and Safeguards Commission, Frequently Asked Questions: Revised High Intensity Support Skills Descriptors, June 2023, updated May 2024 (the registration sentence, the assessment expectation, and the advisory status of the Practice Standards for unregistered providers), read 26 October 2026.
• NDIS Quality and Safeguards Commission, NDIS Practice Standards: skills descriptors, Version 2, November 2021 (the superseded list, still published), read 26 October 2026.
• NDIS Quality and Safeguards Commission, Registration groups or classes of support (the audit type required for each group), read 26 October 2026.
• NDIS Quality and Safeguards Commission, Understanding what is involved in an audit, read 26 October 2026.
• NDIS Quality and Safeguards Commission, NDIS Code of Conduct (who it applies to, and the elements), read 26 October 2026.
• National Disability Insurance Agency, Crackdown on sales of NDIS businesses as mandatory registration set to expand from 1 July (the 1 July 2027 Budget commitment). The page carries no publication date. Read 26 October 2026.

Related guides

• How to become a registered NDIS provider
• Verification audits: what they check
• What NDIS policies and procedures do you actually need?
• The six rights of medication administration
• Implementing a behaviour support plan
• NDIS price limits for 2026-27

Browse every guide by topic: NDIS compliance guides.

This guide is general information about Australian NDIS requirements as at 26 October 2026, not legal, clinical or financial advice. Requirements change, and the clinical delegation questions in particular depend on the law of your state or territory. Check the current NDIS Commission publications and take professional advice on your own circumstances.