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Employers are accountable for ensuring training providers verify identity and participation; failure to do so can lead to criminal liability for false credentials. Unverified training may not reflect actual participation, risking compliance and safety in high-risk industries. It's crucial to confirm training integrity with regulators to maintain a safe workplace.
After asking an OHS regulator whether training providers are expected to verify identity and participation, the answer pointed to a deeper truth: responsibility starts — and ends — with the employer.
I asked an Occupational Health & Safety (OHS) enforcement body:
The response didn’t lay out a checklist for training providers. Instead, it emphasized something broader — and more serious:
“It is the responsibility of the employer to ensure the service provider is operating as business with integrity and honestly”
Put plainly: if training certification is unverified or false, it’s the employer who’s accountable.
The OHS authority clarified that in the few cases where it directly regulates certification (such as life-critical programs like First Aid or asbestos-related work), training providers are expected to:
“Check the identity of workers taking the course as well as what is being taught.”
But for all other training, regulators often don’t directly oversee third-party training programs. That doesn’t remove the burden — it shifts it to employers.
And when it comes to false credentials or claims of completion, the regulator didn’t mince words:
“A person falsifying documentation may be participating in a criminal offence and should be reported to the police.”
Many training programs in high-risk industries still:
Despite this, those certificates are used to demonstrate compliance, satisfy audits, and authorize dangerous work.
If these documents don’t reflect verified participation, they may be considered false records — and employers who rely on them may be exposed to criminal and regulatory liability.
I’ve purposely not identified the OHS regulator I spoke with — because this isn’t just about one agency or one jurisdiction. Instead, I suggest you ask your own regulator the same question I posed at the beginning of this article.
And assuming you get a straight answer, I’d bet that answer will be very similar.
Because at the end of the day, you can’t build a safe workplace on unverifiable training — and no regulator is likely to tell you otherwise.
Cognisense is a team of specialized experts dedicated to helping organizations navigate regulatory, legal, and industry standards. We focus on identifying the right technology, applications, and processes to ensure compliance while maintaining effective risk mitigation.
Robert Day, our Managing Director, brings decades of experience in high-risk industries. With deep regulatory knowledge and investigative expertise, he is passionate about protecting lives and ensuring organizations adopt rigorous, technology-driven compliance strategies.
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