
NDIS Record Keeping Requirements: How Long Providers Must Keep Records (7-Year Rule)
Registered NDIS providers must now keep records for seven years. Destroying them is a criminal offence, and payments can be clawed back if you can’t produce one.
From 1 December 2026, NDIS providers have just 90 days to submit a claim — here is what that means for your organisation and what you need to do before the deadline hits.
NDIS providers currently have two years to submit a claim for supports delivered. From 1 December 2026, that window cuts down to 90 days. Miss it, and the payment is gone, there’s no appeal process for late claims under the new rules.
The NDIS claim window is the period a registered provider has to submit a payment claim to the NDIA after delivering a support. Under the current rules, providers have up to two years from the date of delivery to lodge a claim through the myplace provider portal.
From 1 December 2026, this changes. The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Act 2026, Act No. 66 of 2026, assented 20 August 2026, reduces that window to 90 days. Any support delivered before that date and not yet claimed must be submitted before the window closes, or the revenue is permanently lost.
| Current rules | From 1 December 2026 | |
| Claim window | 2 years | 90 days |
| Late claim option | Yes, within 2 years | No |
| Record retention required | 5 years | 7 years |
| Penalty for missing the window | Revenue loss | Revenue loss (no exceptions) |
| Criminal exposure for missing records | No | Yes, destroying records is now a criminal offence |
The 2026 amendment was passed to reduce fraud and improve financial accountability across the NDIS. Scheme payments reached 5 billion in FY2025-26, and the government identified late, inaccurate and fraudulent claims as a significant contributor to scheme cost blowouts.
The 90-day window is designed to make it harder to submit claims for supports that were never delivered, and easier for the NDIA to audit and recover incorrect payments.
For providers doing the right thing, the change mostly means one thing: your billing and record-keeping have to be much tighter than they used to be.
Under the old rules, a provider could deliver a support in January and claim it in October. From December 2026, that same claim would need to be submitted by April.
Here is what that means for day-to-day operations:
The claim window change doesn’t sit alone. The same Act increases the mandatory record retention period for registered providers from five years to seven years, and makes destroying records a criminal offence.
This is a significant shift. Previously, failing to keep records meant an audit finding and possible sanctions. Under the new Act, deliberately destroying records exposes providers to criminal prosecution.
The practical implication: any record-keeping system that relies on manual filing, shared drives or individual workers keeping their own notes is now a serious liability.
1. Audit your outstanding claims now
Run a report of every support delivered in the past 90 days that has not been claimed. Any support more than 90 days old should be prioritised for immediate submission before the new rules take effect.
2. Review your documentation workflow
Identify the gap between when a support is delivered and when the shift note is completed. If that gap is regularly more than a few days, your process needs to change before December.
3. Make sure every worker can document on the day
Workers who cannot or do not complete their notes at the time of delivery are creating a claim risk. Mobile-first documentation tools that let workers record on-site reduce this risk significantly.
4. Check your record retention
If your current system does not retain records for seven years and flag when a record is at risk of being deleted, you are exposed under the new Act.
5. Set up alerts for approaching deadlines
Manual tracking of 90-day windows across dozens of participants and hundreds of supports is not realistic. Providers need a system that surfaces upcoming claim deadlines automatically.
Does the 90-day rule apply to supports already delivered before 1 December 2026?
The 90-day window applies from the date the Act takes effect on 1 December 2026. Providers should check the transitional provisions carefully and seek legal or compliance advice if they have large volumes of outstanding claims from the current period.
What happens if I miss the 90-day window?
The claim can’t be submitted. There is no appeals process or grace period under the new rules. The revenue is lost.
Does this apply to unregistered providers?
The mandatory claim window applies to registered NDIS providers. However, the broader reforms in the 2026 Act expand the definition of provider significantly. Providers who were previously unregistered may now be captured under the new rules and should check their registration status.
Does the 90-day window apply to plan-managed participants?
The claim window rules primarily affect registered providers claiming directly through the NDIA portal. If your participants are plan-managed, confirm timing requirements with the relevant plan manager, as their payment terms may differ.
What records do I need to keep for each claim?
Providers must retain records that demonstrate the support was delivered as claimed. This includes shift notes, attendance records, participant signatures or verification, and any relevant incident or medication records. The record must be retained for seven years from the date of service.
Does using AI to write shift notes comply with NDIS requirements?
Many workers are already using consumer AI tools to write shift notes. The NDIS doesn’t prohibit this, but the record must accurately reflect what happened. Records created using offshore consumer AI services raise a separate concern: participant health information may be processed outside Australia without consent. Providers should ensure any AI tools used for documentation are governed, onshore and traceable.
The 90-day claim window is the most immediately quantifiable change in the 2026 NDIS reforms. It turns a documentation problem into a revenue problem, and it starts on 1 December 2026.
Providers who have tight, consistent documentation workflows and claim regularly will barely notice it. Providers who batch-process claims, rely on workers to complete notes days or weeks later, or use manual systems to track outstanding billing face real financial exposure.
The time to fix the workflow is now, not in November.
Wholii is built for registered NDIS providers who need to stay on top of documentation, credentials and compliance without a dedicated compliance team.
Workers can complete shift notes by voice on any device, with every answer traced back to what was said. Claim-relevant documentation is structured, timestamped and audit-ready. Compliance dashboards surface outstanding items before they become a problem.
Book a free demo at wholii.com.au/book-demo
Sources: National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Act 2026, Act No. 66 of 2026; NDIA Quarterly Report Q4 2025-26; NDIS Commission Annual Report 2024-25.
Disclaimer: This article is for general information only and does not constitute legal or compliance advice. Providers should seek advice specific to their circumstances.

Registered NDIS providers must now keep records for seven years. Destroying them is a criminal offence, and payments can be clawed back if you can’t produce one.

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