NDIS Behaviour Support Plans: Rules, Deadlines, Template

Updated 12 min readBy the Orangised team

The Short Answer

A behaviour support plan with a regulated restrictive practice must be written by an NDIS behaviour support practitioner the Commission has found suitable. The interim plan is due within 1 month and the comprehensive plan within 6 months of the provider being engaged. Plans are lodged with the NDIS Commission, and comprehensive plans are reviewed at least every 12 months.

On this page
  1. The short version
  2. Who can write a behaviour support plan
  3. An NDIS behaviour support practitioner
  4. A registered specialist behaviour support provider
  5. Interim vs comprehensive plans
  6. Two clocks, two start points
  7. When a participant changes provider
  8. What a plan must contain
  9. The legal minimum
  10. The five regulated restrictive practices
  11. Authorisation is a state or territory job
  12. A template outline you can use
  13. Lodging the plan with the Commission
  14. What implementing providers must do
  15. Reviews: at least every 12 months
  16. Common gaps the Commission finds

The short version

A behaviour support plan (BSP) sets out how a participant is supported when their behaviour puts them or others at risk. When the plan includes a regulated restrictive practice, the NDIS (Restrictive Practices and Behaviour Support) Rules 2018 kick in, and they put duties on two kinds of provider:

  • Specialist behaviour support providers write the plan through an NDIS behaviour support practitioner: interim within 1 month and comprehensive within 6 months of being engaged, lodged with the NDIS Commission, with the comprehensive plan reviewed at least every 12 months.
  • Implementing providers use it day to day: they get restrictive practices authorised by the state or territory, report monthly, and treat any use outside the plan as a reportable incident.

The Rules were last amended in December 2020 (F2018L00632), but the Commission's guidance has moved a lot in 2025 and 2026. This is general information, not clinical or legal advice.

Who can write a behaviour support plan

An NDIS behaviour support practitioner

An NDIS behaviour support practitioner is a person the Commissioner considers suitable to do behaviour support assessments and write plans that may contain restrictive practices (Rules, section 5). A degree alone doesn't make you one. Until the Commission finds you suitable, you can't do behaviour support assessments or write plans, "even under supervision" (NDIS Commission, Apply to be a behaviour support practitioner).

How suitability works (NDIS Commission, Apply to be a behaviour support practitioner):

  • Two pathways: self-assessment, with a supervisor-endorsed portfolio of evidence, or the new entry-level pathway for people with under 6 months of positive behaviour support experience.
  • Measured against the Positive Behaviour Support Capability Framework, which has four levels: core, proficient, advanced and specialist. The Commission doesn't endorse a level. It decides "suitable", "not suitable" or "unable to make a decision" (NDIS Commission, Capability Framework).
  • New entry-level practitioners need supervision from a proficient (or higher) practitioner, and may be found not suitable to run a practice on their own.
  • A valid NDIS worker screening clearance goes on the application, and most decisions take 4 to 6 weeks.

The practitioner must also be engaged by a registered provider, or be registered themselves.

A registered specialist behaviour support provider

The business delivering the service must be registered with the Commission for registration group 0110, Specialist positive behaviour support, and must use an NDIS behaviour support practitioner for every plan it writes. That applies to plans with no restrictive practice in them too (NDIS Commission, Rules for specialist behaviour support providers; Rules, sections 17 and 18). Specialist behaviour support is audited against Module 2 of the Practice Standards, and implementing plans with restrictive practices against Module 2A (NDIS Commission, Rules for implementing providers). Our audit preparation guide covers both.

Interim vs comprehensive plans

Both count as a behaviour support plan, but they do different jobs (NDIS Commission, How to develop behaviour support plans; Implementing Provider Checklist):

Interim planComprehensive plan
PurposeSafeguard the person and lower immediate risk while the assessment is doneImprove quality of life and address why the behaviour happens
Based onWhat's known nowA behaviour support assessment, including a functional behavioural assessment
CoversPrevention, reducing harm when the behaviour occurs, if and how restrictive practices may be usedAll of that, plus environmental changes, skill development and steps to reduce and eliminate restrictive practices
Deadline (with a restrictive practice)1 month after the specialist provider is engaged6 months after the specialist provider is engaged
ReviewReplaced by the comprehensive planAt least every 12 months, and sooner if circumstances change

Two clocks, two start points

The specialist provider's clock starts when it is engaged to write the plan. Once a restrictive practice has been used and the provider is engaged because of it, the interim plan is due within 1 month and the comprehensive plan within 6 months (Rules, section 19). The Commission counts "engaged" from the date of the service agreement, or a start date written into it. A change of practitioner inside the same provider doesn't restart the clock (Position statement: Interim and comprehensive behaviour support plan workflow, February 2026).

The implementing provider's clock starts at the first use of the restrictive practice. If the use is likely to continue and isn't covered by a plan, the implementing provider must take all reasonable steps to get an interim plan within 1 month of that first use and a comprehensive plan within 6 months (Rules, sections 11 to 13). Keep records of those steps, because a long waitlist is only a defence if you can show you tried (Implementing Provider Checklist).

Legally these deadlines apply only to plans with a regulated restrictive practice, but the Commission expects them to guide other plans too (NDIS Commission, Rules for specialist behaviour support providers).

When a participant changes provider

A new specialist provider takes on the section 19 deadlines from its own engagement date. If a current, lodged and authorised interim plan still fits, it can go straight to the comprehensive plan. If a current comprehensive plan exists, it can move to implementation support, and the 12 month review runs from that plan's start date (Position statement, February 2026).

What a plan must contain

For a plan with a regulated restrictive practice, the specialist provider must take all reasonable steps to reduce and eliminate the need for it, change the person's environment where that helps, and consult the person, their family or guardian, and the implementing provider. The person and their supporters must be told, in an accessible format, that a restrictive practice is going in (Rules, section 20). A comprehensive plan requires a behaviour support assessment, including a functional behavioural assessment: working out "the function or purpose behind a person's behaviour" (Rules, sections 5 and 20(5)).

The plan needs evidence-based, person-centred, proactive strategies that address the functions of the behaviour. Each restrictive practice must be (Rules, section 21):

  • clearly identified in the plan
  • authorised under the state or territory process, where one exists
  • used only as a last resort, after proactive strategies have been tried
  • the least restrictive response possible
  • aimed at reducing the risk of harm
  • in proportion to that risk
  • used for the shortest possible time.

The person must also get chances to join community activities and learn new skills that could reduce the need for restrictive practices.

The five regulated restrictive practices

PracticeWhat the Rules mean by it (section 6)
SeclusionConfining a person alone in a room or space they can't freely leave
Chemical restraintMedication used mainly to influence behaviour, not to treat a diagnosed condition
Mechanical restraintA device used to prevent, restrict or subdue movement mainly to influence behaviour
Physical restraintPhysical force to prevent, restrict or subdue movement mainly to influence behaviour
Environmental restraintRestricting free access to parts of the environment, including items or activities

Source: Rules, section 6. Locked pantries, removed items and off-limits rooms can all be environmental restraints, and the Commission ran a compliance campaign on them in 2024-25 (NDIS Commission, Regulatory Priorities Report 2024-25).

Authorisation is a state or territory job

The Commission doesn't authorise restrictive practices. Each state and territory runs its own process, which might mean guardian consent, a tribunal or an authorised officer (Rules, section 9). The implementing provider gets it from the authorising body where the person lives and lodges the evidence with the Commission, which links a summary of every state's framework from its Rules for implementing providers page. If a state prohibits a practice, you can't use it at all (Rules, section 8).

Some practices should never appear in a plan. The Commission's position statement names physical restraints such as basket holds, prone and supine restraint, pin downs and takedowns, and punitive approaches such as aversive practices, response cost, overcorrection and denial of key needs. They must stop immediately (Position statement: Practices that present high risk of harm).

A template outline you can use

The Commission publishes free Interim and Comprehensive BSP templates (version 3, April 2025) with checklists (NDIS Commission, How to develop behaviour support plans). Its 2025 review found plans on its comprehensive template scored higher than other formats (BSP Quality Snapshot 2025). Use the real templates. Here are their section headings, to check your own format against (Interim BSP template; Comprehensive BSP template):

SectionInterimComprehensive
Person, plan dates, practitioner and provider detailsYesYes
PurposeYesYes
Consultation (with the person, with others)YesYes
Other sources of informationYes
About the personYesYes
Risks of harmYesYes
Why the behaviour occursYes
GoalsYes
Preventative strategiesYes
Proactive strategiesYes
Skill developmentYes
Response strategiesYesYes
Regulated restrictive practices: summary, authorisation, protocolsYesYes
Practices to be ceased immediatelyYesYes
Implementation support and monitoring (plus review, comprehensive)YesYes
Practitioner declaration (and supervisor)YesYes

The interim plan records when the comprehensive plan is due; the comprehensive plan records its review date. Each restrictive practice gets a protocol headed: description, implementers, rationale, circumstances (routine or as needed), strategies to be used first, procedure, impacts and safeguards, training, monitoring and review, and the plan to reduce and eliminate it. Chemical restraint has its own protocol that also records the prescriber, the medication and its next review date.

Drafting with AI? The Commission doesn't ban it, but expects no participant's personal information to be disclosed to AI systems (Position statement: Use of artificial intelligence in development of behaviour support plans).

Lodging the plan with the Commission

Any plan containing a regulated restrictive practice, including a reviewed plan, must be lodged with the Commission "as soon as practicable after it is developed", whether or not authorisation has been obtained yet (Rules, section 24). The Commission says it generally considers two weeks from the date the practitioner finalises the plan to be practicable (Policy guidance: Monitoring and reviewing, May 2026).

The practitioner lodges through the Commission's registered providers portal, with details of the participant, the restrictive practices and the implementing providers, and the functional behavioural assessment attached where relevant (NDIS Commission, How to develop behaviour support plans). Lodging creates the "schedule" of restrictive practices that the implementing provider reports against. The implementing provider then activates the plan and attaches its authorisation evidence (NDIS Commission, Rules for implementing providers).

A new Commission portal is expected in October 2026, with a dashboard of due monthly reports and one authorisation upload per plan (NDIS Commission, What's changing in the new portal).

What implementing providers must do

You must be registered to use regulated restrictive practices. An unregistered provider using them is in breach of the Rules (NDIS Commission, Rules for implementing providers). Then:

ObligationWhat it meansSource
Use the plan as writtenRestrictive practices only in line with the plan; tell the specialist provider when circumstances changes 10
AuthorisationGet it from the state or territory and lodge evidence with the Commissions 9
Monthly reportsReport on every practice in the schedule, including months it wasn't used, within 5 business days of month ends 14; Commission
Short term approvalsReport every 2 weeks while a short term state or territory approval is in forces 14
RecordsEach use: what led to it, times, place, people, witnesses, less restrictive options tried, impact and actions. Keep 7 yearss 15
Unauthorised or emergency useNotify as a reportable incident within 5 business days. Any use causing serious injury, authorised or not, within 24 hoursCommission; checklist

A restrictive practice is unauthorised if it isn't in a behaviour support plan, isn't authorised under the state or territory process, or isn't used in line with the plan (NDIS Commission, Rules for implementing providers). Emergency use counts too (Implementing Provider Checklist). See our reportable incidents guide for the forms, and our progress notes guide for recording each use.

Monthly reports can go in against active, expired or partially active plans, but not closed ones, and a closed plan can't be reopened. If a practice in use isn't on the schedule, you can't report it until the practitioner fixes the schedule or relodges (NDIS Commission, Rules for implementing providers). SIL providers should also read our SIL registration guide.

Reviews: at least every 12 months

A comprehensive plan containing a regulated restrictive practice must be reviewed by an NDIS behaviour support practitioner as soon as practicable after a change in circumstances that needs the plan amended, and in any event at least every 12 months while it's in force (Rules, section 22). The reviewed plan is relodged (Rules, section 24).

The Commission's May 2026 guidance fills in the gaps (Policy guidance: Monitoring and reviewing, May 2026):

  • When the 12 months starts. A plan is in force from the date the practitioner finalises it. If the plan date, the practitioner's signature and a supervisor's signature differ, use the latest.
  • What counts as a change in circumstances. A significant change in risk, behaviour, needs, health, environment or supports, such as a pattern of unauthorised restrictive practices, a change in living arrangements or a change of provider.
  • Minor edits are not a review. Fixing typos or updating a medication dose goes in an addendum or a version number (for example 1.2), doesn't change the in-force date, and the annual review is still due. If an edit affects the authorisation status of a restrictive practice, it's a full review and the plan is relodged.
  • Document it, including why you did or didn't change the plan. If reducing a restrictive practice has stalled, record the barriers, actions, owners and timeframes.

Common gaps the Commission finds

Each year the Commission scores a random sample of lodged comprehensive plans with the BSP-QEII quality tool. Its 2026 snapshot of 129 plans found (Behaviour Support Plan Quality Snapshot 2026):

  • an average quality score of 14.1, above the minimum of 13 needed "to effect some change" but not best practice, and flat over three years (14.39 in 2024, 14.93 in 2025)
  • 42% of plans rated weak, 32% underdeveloped, 20% good and 6% superior
  • 83% showed consultation with the participant, up from 32% in 2022
  • 79% included a fade-out strategy for restrictive practices, up from 56% in 2023.

The 2025 snapshot found only 42% of plans showed the participant had been told about the intention to include a restrictive practice, a legislated requirement the Commission said it would enforce (BSP Quality Snapshot 2025). In 2024-25 it also worked with 129 providers over 419 participants subject to unauthorised restrictive practices, and chased monthly reporting (Regulatory Priorities Report 2024-25).

Add the Commission's own checklists, and these are the gaps to close first:

  1. No record of telling the person, in an accessible format, that a restrictive practice is going into their plan.
  2. No fade-out plan, or one that's written but never acted on.
  3. Strategies that don't tie back to the function of the behaviour found in the assessment.
  4. Overdue reviews, or a tidy-up passed off as a review.
  5. Plans not lodged or relodged, or a schedule that doesn't match what staff actually do.
  6. Authorisations missing, expired, or not lodged with the Commission.
  7. Missed monthly reports, especially nil months.
  8. Practices in use that aren't in the plan, like a locked fridge nobody thought of as a restraint.
  9. Staff not trained on the person's own plan.

Orangised's allied health module has Interim and Comprehensive Behaviour Support Plan templates with a review trail (draft, submitted, changes requested, approved, released), signed approvals and watermarked drafts. Restrictive practice records carry review and expiry dates that feed a compliance calendar and reminder emails. Lodging plans and monthly reports still happens in the Commission's own portal.

Sources

General information for NDIS providers, not legal or financial advice. Rules change: check the source before you act, and if something here is out of date, tell us.

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