Imagine this: You volunteer at your child’s school, direct a business providing services to children, or sit on a board connected to youth programs. You’ve likely assumed your role was compliant. But Queensland’s Blue Card system has changed, and not knowing the new rules could now land you or your organisation in hot water.
You find yourself facing serious questions while your reputation, business interests or family standing are on the line. It’s a real risk if you assume existing compliance is sufficient.
That’s the pain point: thinking you’re covered, but the rules have changed and you might not even realise yet. The good news is: you can overcome this risk with clear guidance, timely action and strategic legal advice. In this blog we will walk you through what the Blue Card system is, what’s changed in Queensland and what you and your business or family need to do now.
What is the Blue Card system?
The Blue Card system in Queensland is the state’s working with children check. In plain English: if you undertake certain child related work, volunteer roles or run a business that provides services to children, you must hold a valid Blue Card (or your organisation must ensure compliance). It’s administered by Blue Card Services under the Working with Children (Risk Management and Screening) Act 2000.
For the professional services community, this might sound tangential, but if you sit on boards of clubs, run training programmes for children, fund or direct businesses servicing children (entertainment, photography, sport, churches), or your children volunteer with you, the rules can apply. It’s a compliance and reputational risk if overlooked.
What’s changed in the Blue Card system in Queensland?
Here are the key changes that have come into effect in Queensland, which are particularly relevant for professionals, business owners, parents and directors in Brisbane:
- New risk assessment criteria
Blue Card Services must now apply a specific criterion when undertaking a risk assessment on an applicant or card holder. Namely, Blue Card must be satisfied that an applicant presents a real and appreciable risk to the safety of children before refusing an application. Consistent with interstate working with children legislative frameworks, Blue Card Services will also apply a ‘reasonable person’ test – that is, would a reasonable person allow their child to have supervised or unsupervised contact with the applicant. - Expanded scope of who needs a Blue Card
From 20 September 2025, the scope of child‑related work that requires a Blue Card has been broadened. That means roles and business activities previously exempt may now fall within the system.
Examples: entertainment or party services, gym or play facilities, photography services, talent or beauty competitions. - New self‑disclosure obligations
Applicants and cardholders must now self‑disclose certain “disclosable matters” such as child protection orders, domestic/family violence orders, or other relevant history. There are of course transitional provisions that do not require a person with domestic violence history prior to 20 September 2025 to disclose this information unless they are renewing their application. - New discretionary suspension power
The new laws give Blue Card Services the ability to suspend a Blue Card where there is a change in assessable information that was not known to the department at the time of issuing the clearance. - Professional services implications
Notably for professionals: from 20 September 2025, lawyers and legal professionals providing services to children will need a Blue Card under the health counselling/support services category.
These changes mean that if you or your business previously assumed exemption, you might now need to act. That’s where the risk arises.
Why it matters for parents, professionals & directors in Brisbane
You may be thinking: “This is for schools and childcare centres, not me.” But the reality is that for families and professionals in Brisbane, the exposure is broader:
- If you fund or direct a company that provides children’s services (sports clubs, photography, entertainment, tuition), you may now be a ‘business owner’ subject to obligations.
- If your child’s school or extracurricular program involves you as a volunteer (committee member, event organiser) you need to check the parent volunteer exemption and whether it still applies. For example, the exemption for parent volunteers in respect of overnight excursion or stays no longer applies.
- As a professional or director, a compliance failure may not only be an administrative matter, it could trigger investigations, reputational harm, or regulatory scrutiny.
How missing compliance can trigger criminal law consequences
Non‑compliance with the Blue Card system doesn’t often lead to immediate criminal charges for a private individual or parent – but for business owners, directors and professionals the stakes are higher. The new reforms have also introduced changes to the regulatory environment (including newly created offences) which may affect you. For example, an employer must now keep a register of information about the persons they employ including their applications for working with children clearances and who may be restricted from holding a Blue Card. It is now an offence for an employer to fail to keep this register.
Why choose to work with us at Robertson O’Gorman Solicitors?
At Robertson O’Gorman we specialise in high stakes criminal defence and regulatory risk for professionals, directors and parents in Brisbane. Whether you’re dealing with serious criminal charges, complex governance issues or potential Blue Card system exposure, our team brings together decades of courtroom experience, former prosecutors and accredited criminal law specialists.
We assist clients with Blue Card matters day in and day out. Given our expertise in criminal law and regulatory investigations, we’re uniquely placed to advise on the interplay between child safety regulation (like the Blue Card system) and criminal/regulatory risk.
If you’d rather not handle this alone, or you’ve already got a potential issue ticking, give our team a call for a strategic discussion.
Next Steps
If you’re reading this and thinking: “Yes, this could apply to me or my business,” here’s what to do next:
- Call our Brisbane team at (07) 3034 0000 to speak with one of our criminal solicitors or book a free case appraisal here.
- Make a quick internal audit (or ask us to help) of any child related activities, volunteer roles or business operations you’re connected with and check whether Blue Card obligations now apply.
- If you identify a potential gap, act promptly (apply for Blue Card, update registers, implement strategies) rather than waiting until an issue arises.
FAQ’s
Who now needs a Blue Card in Queensland under the new system?
Under the changes effective from 20 September 2025, the list of work, volunteer and business activities requiring a Blue Card has expanded. New categories include entertainment, photography, beauty services for children, amusement parks, legal professionals providing services to children.
As a parent volunteer at my child’s school, do I need a Blue Card after the reform?
Possibly. The “volunteer parent exemption” has been standardised from 20 September 2025 – but it does not apply in all cases (overnight camps, direct close contact with other children, certain roles). If you’re volunteering in a role where you supervise or guide children (other than your own), you must check.
If my business provides services to children (e.g., party photography), what obligations do I have now?
You should assess whether your business now falls within a regulated category requiring staff or volunteers to hold Blue Cards. Also, your business needs to keep an employee/volunteer register and maintain a Child and Youth Risk Management Strategy (CYRMS) if applicable. Transitional arrangements may apply.
If I already had a Blue Card under the old system, do I need to do anything now?
Yes – check whether your card is up to date, whether your role now requires disclosure of new matters (self‑disclosure), whether your business or role changed categorisation, and whether your organisation’s risk management plan meets new standards. The new decision‑making and compliance powers mean older assumptions may no longer suffice.
Can a Blue Card decision be reviewed if it’s refused or revoked?
Yes, certain decisions by Blue Card Services may be reviewed by the Queensland Civil and Administrative Tribunal (QCAT). If you receive a negative decision you should consider legal advice to determine if review rights apply.
Written By The Robertson O’Gorman Team
Robertson O’Gorman Solicitors is Brisbane’s pre‑eminent criminal defence firm, with a legacy of over 40 years of legal excellence. Their team includes accredited criminal law specialists and former prosecutors who consistently appear across Magistrates, District, Supreme and appellate courts. As a First Tier firm recognised in Doyle’s Guide 2025, they deliver strategic, early‑ ‑stage legal advice – often before charges are laid – to preserve rights and achieve optimal outcomes for clients. Known for fearless yet compassionate advocacy, the firm combines deep courtroom experience with a commitment to social justice, integrity and tailored client care.
Disclaimer: This article is general information only and cannot be regarded as legal advice as it does not take into account your personal circumstances. For tailored advice, please call us on (07) 3034 0000.