NDIS progress note timing and retention: what the law actually says
We found no provision that sets a deadline for writing a progress note or shift note. The Practice Standards require records to be made in an accurate and timely manner, without defining timely. The clocks that do exist run on other things: claims must be made within 90 days from 1 December 2026, prescribed claim records are kept 7 years from the claim date under section 45B, and incident and restrictive practice records are kept 7 years under the Rules.
Key takeaways
- No provision we found sets a time limit for writing a shift note or progress note. The Practice Standards indicator says records are made in an accurate and timely manner.
- Claim timing is the clock that bites: 2 years today, 90 days from delivery from 1 December 2026.
- Retention: 7 years from the claim date for prescribed records (section 45B, in force from 27 August 2026), and 7 years for incident and restrictive practice records under their Rules.
- There is no general rule, in the sources we checked, that all provider correspondence must be kept for 7 years.
What does the law say about progress note timing and retention?
Each row below states one point and the provision it comes from. Where we did not find a provision, the row says so.
| Point | What the sources say | Where |
|---|---|---|
| Is there a deadline for writing a progress note or shift note? | We found none. The NDIS record keeping page requires complete and accurate records, and gives no time limit for writing case notes. | NDIS record keeping requirements page (current as of 20 August 2026) |
| Do the Practice Standards say anything about timing? | Yes, in general terms. The information management indicator is that the system “records each participant’s information in an accurate and timely manner”. The outcome is that information is identifiable, accurately recorded, current and confidential. Timely is not defined. | NDIS Practice Standards, Core module, Information management |
| How often must progress against goals be assessed? | At a frequency relevant and proportionate to risks, functionality and the participant’s wishes, with the plan updated where progress differs from expected. | NDIS Practice Standards, Support planning |
| What are the time limits for reporting an incident? | Reportable incidents that result in harm must be reported within 24 hours. The form for an unauthorised use of a restrictive practice without immediate harm is due within 5 business days. These are notification deadlines, not note deadlines. | NDIS Commission, Reportable incidents |
| How long do I have to make a claim? | 2 years now. From 1 December 2026, claims must be submitted within 90 days of delivering a support. | NDIS Act section 45A(5)(a) as amended (Schedule 2 Part 5, item 89); NDIS website |
| How long are claim records kept? | Prescribed records that relate to a claim, or to the support the claim relates to: 7 years beginning on the day the claim is made, unless the Rules prescribe a shorter period. Civil penalty 120 penalty units. In force from 27 August 2026 for claims made on or after that date. | NDIS Act section 45B(1) to (3) |
| Which records does section 45B cover? | Records of a kind prescribed by the NDIS Rules. We did not find Rules prescribing them on 26 September 2026, so the Act does not itself say that every progress note is covered. | NDIS Act section 45B(1) |
| How long are incident records kept? | 7 years from the day the record is made, and for a reportable incident record, 7 years from the day notification is given. | Incident Management and Reportable Incidents Rules 2018, sections 12(4) and 25(2) |
| How long are restrictive practice records kept? | 7 years from the day the record is made. | Restrictive Practices and Behaviour Support Rules 2018, section 15(3) |
| Must all provider correspondence be kept for 7 years? | We found no such rule in the record keeping page, the Practice Standards, section 45B or the 2026 reform instruments. The NDIA Terms of Business record clause we quoted (version effective 1 July 2016, updated January 2020) concerns accounts, financial records and service agreements and states no retention period. Section 45B is the later and higher authority. | See sources |
Why does timing still matter if there is no deadline?
Three things create a working deadline even without a rule for the note. The Practice Standards indicator expects timely records. The claim window shrinks to 90 days from delivery from 1 December 2026, and a claim needs a finished record behind it. And where a note records a reportable incident, the reporting deadlines still apply to that incident, including 24 hours where harm results. Progress notes should be written soon enough that these three things can be met, and your policy should say what soon enough means for your service.
What should you do with this?
- Set a written internal standard for how soon after a shift a note is completed, and evidence that you meet it. The law does not set one, so yours will be judged against the “timely” indicator.
- Make sure every claim can be traced to the notes and records that support it, and keep them for 7 years from the claim date.
- Keep incident and restrictive practice records for 7 years from the dates in the Rules.
- Check the Rules made under section 45B when they are published, and check the other Commonwealth, State and Territory laws that may apply.
The retention detail, including the section 45B text, is in how long NDIS providers must keep records. For what each reform date means for a note, see NDIS dates and shift notes. This guide is general information, not legal advice.
Frequently asked questions
Is there a legal deadline to write an NDIS progress note?
We found no provision that sets one. The Practice Standards require each participant’s information to be recorded in an accurate and timely manner and do not define timely.
How long must NDIS progress notes be kept?
Section 45B of the NDIS Act requires prescribed records relating to a claim, or the support a claim relates to, to be kept for 7 years from the day the claim is made. Which record kinds are prescribed is left to the NDIS Rules, which we could not find on 26 September 2026.
How long do I have to claim for an NDIS support?
Two years currently. From 1 December 2026, claims must be submitted within 90 days of delivering a support.
Must all NDIS provider correspondence be kept for 7 years?
We found no such rule in the sources we checked. Seven years is stated for claim records under section 45B and for incident and restrictive practice records under their Rules.
Sources
- What are the record keeping requirements (NDIS) (NDIA, retrieved 25 September 2026)
- Core module: Provider governance and operational management (Information management) (NDIS Quality and Safeguards Commission, retrieved 25 September 2026)
- NDIS Practice Standards and Quality Indicators (Support planning) (NDIS Quality and Safeguards Commission, retrieved 25 September 2026)
- Reportable incidents (NDIS Quality and Safeguards Commission, retrieved 25 September 2026)
- National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Act 2026, Schedule 2 Part 4 (section 45B) and item 86 (section 182(4)) (Federal Register of Legislation, retrieved 26 September 2026)
- Securing the NDIS for future generations (NDIS laws page) (NDIA, retrieved 26 September 2026)
- NDIS (Incident Management and Reportable Incidents) Rules 2018, sections 12 and 25 (Federal Register of Legislation, retrieved 25 September 2026)
- NDIS (Restrictive Practices and Behaviour Support) Rules 2018, section 15 Record keeping (Federal Register of Legislation, retrieved 25 September 2026)
- NDIA Terms of Business for Registered Providers, Maintenance, Records & Audit: Maintaining records (NDIA, retrieved 26 September 2026; version effective 1 July 2016, updated January 2020)
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