by: Claire Holmes

Since 1 January 2026, Table A and Table B providers have been required to comply with the National Higher Education Code to Prevent and Respond to Gender-Based Violence (2025). Across the sector, significant work is already underway.

The Higher Education Gender-Based Violence (GBV) Regulator has released a range of practical materials to support implementation. These include best-practice guidance, training resources, and ready-to-use templates that can be adapted for communications, awareness campaigns and student-facing information.

These resources are particularly useful for institutions looking to strengthen existing initiatives or implement quality-assured materials without starting from scratch.

The next question is capability — whether the staff responsible for receiving reports, conducting investigations and making decisions have the judgement and confidence to apply the Code in practice and deliver outcomes that are fair, consistent and able to withstand scrutiny. This is why expectations around human-centred and trauma-informed practice are fundamental.

What does human-centred and trauma informed mean in practice?

A human-centred approach means designing policies, processes and systems around the real experiences, needs and wellbeing of the people affected, while maintaining procedural fairness, clear governance and defensible decision-making.

In practice, this includes:

• clear and accessible reporting pathways
• step-by-step guidance on what to expect
• transparent timeframes and communication, and
• processes that recognise people may be vulnerable, anxious or distressed.

A trauma-informed approach recognises that individuals involved in a process may have experienced trauma and ensures that institutional responses minimise further harm while maintaining fairness, objectivity and due process. It requires respectful treatment and procedural fairness for all parties, including respondents.

At its core, trauma-informed practice:

• recognises the impact trauma can have on memory, behaviour and communication
• avoids practices that may re-traumatise individuals
• prioritises psychological safety, dignity and respect
• supports clear, consistent and predictable processes, and
• operates alongside natural justice and defensible decision-making.

In practice, this may involve limiting the need for individuals to repeat their experience, using structured investigation approaches, avoiding adversarial questioning, and allowing appropriate breaks during interviews.

Implementation is about practice, not just policies

Sector discussions, including recent professional development forums, have reinforced a consistent message: compliance with the Code will not be demonstrated through policy documents alone.

The GBV Regulator will increasingly expect to see evidence of how institutions are operating in practice, including:

• clear governance oversight and reporting to governing bodies
• defined decision-making pathways and accountability
• capability development for staff involved in complaints handling
• data collection and monitoring to support continuous improvement
• consistent investigation and outcome processes
• appropriate arrangements with third-party accommodation and service providers
• human-centred, trauma-informed processes that support both complainants and respondents.

This work sits at the intersection of human safety, procedural fairness and institutional accountability. The test over time will not be whether a framework exists, but whether processes and decisions are consistent, fair and defensible.

One Code, different institutional contexts

The Code applies across a diverse higher education landscape. Universities, dual-sector providers and specialist institutions operate at very different scales and with different risk profiles.

Effective implementation therefore requires a proportionate approach that reflects:

• institutional size and organisational capacity
• student cohort volume and characteristics
• delivery model (on-campus, online or blended)
• any residential and accommodation arrangements, and
• the complexity of the operating environment.

The expectation is not that all providers adopt the same structures or levels of resourcing, but that the response is fit for purpose, practical, accessible, well documented and appropriate to the institution’s context.

For large universities, this may involve coordination across multiple faculties, campuses and service areas. For smaller or specialist providers, the focus may be on the clarity of roles, accessible processes and strong governance visibility. In both cases, the goal is the same: systems that address stakeholder needs, work in practice and demonstrate consistency over time.

Across the sector, one of the most significant risks is not policy coverage, but capability.

The critical question is whether the people responsible for receiving reports, conducting investigations and making decisions have the skills and confidence to apply those frameworks in practice. Responding to gender-based violence matters requires specialised judgement. Staff involved in investigations and decision-making must be able to:

• apply trauma-informed principles appropriately
• manage sensitive and confidential information
• conduct fair and procedurally sound investigations
• assess evidence consistently
• document findings and reasons clearly
• make documented decisions that are defensible if reviewed or challenged.

Many institutions have invested in awareness training, but fewer have developed role-specific capability aligned to their own procedures, governance pathways and documentation requirements. This is often where gaps emerge between policy and practice.

Building capability where decisions are made

As the sector moves forward, the challenge is not understanding the Code. It is embedding systems that support consistent practice over time.

DVE is currently working with universities to design tailored training and assessment programs for investigators and decision-makers. These programs are typically:

• modular and role-specific
• aligned to the institution’s own procedures and governance framework
• focused on practical decision-making and documentation
• designed to build consistent, defensible practice over time.

This work is relevant across the sector, from large universities seeking consistency across complex structures to smaller providers requiring proportionate capability solutions. Effective implementation is not about adopting another institution’s model. It is about building a system that works for your context and ensuring that, when decisions are made, the institution can demonstrate that they were fair, human-centred, trauma-informed and supported by evidence.

If your organisation is already working towards alignment with the National Higher Education Code and would like to strengthen staff capability, decision-making processes or evidencing practices, the DVE team would welcome the opportunity to discuss how a tailored approach could support your organisation’s needs. Please contact us via info@dvesolutions.com.au or 1800 870 677.