Plan managers will need a deed with the NDIA and may provide no other NDIS supports. Here is the market the Agency described to the Senate

This is general information about what the law and the NDIA’s published answers say. It is not advice about any particular plan manager, and nothing here identifies one.

What changes when Part 6 commences

Schedule 2 of Act No. 66 of 2026 is headed Fraud measures, and Part 6 of it, Registered plan management providers, is the only part of the Act whose start date is left to the executive. Item 9 of the commencement table in section 2 says it starts on A single day to be fixed by Proclamation, with a backstop: if it has not started within 24 months of Royal Assent, it starts on the first day of the next month. Assent was 20 August 2026, so the latest start is 1 September 2028. We set out every other date in the Act’s commencement timetable.

Once it commences, Part 6 does four things to the NDIS Act:

• A deed is the gate. New subsection 73EA(1): A person must not be registered to manage the funding of supports under participants’ plans unless a deed of arrangement that meets the requirements in subsection (2) is in force between the person and the Agency. The deed must cover integrity and governance standards with reporting to the Agency, staff and key personnel requirements, claims handling including verification of identity and verification of the provision of supports, technology and systems standards, and requirements on related parties and conflicts of interest.
• Plan management only. New paragraph 73F(2)(j) makes it a condition of registration that a registered plan manager must not provide any supports or services other than plan management under the NDIS. New subsection 73E(2B) says the Commissioner must not register a person to provide other supports while it is registered, or applying, to manage plan funding, and the reverse.
• A penalty for managing funds without a deed. New section 73EB makes it a contravention for a registered plan manager to manage the funding of supports under a participant’s plan when no compliant deed is in force, with a civil penalty of 250 penalty units.
• A public list. New subsection 73EA(3): The Agency must keep a public register of registered plan management providers.

The transitional item, item 101, gives existing plan managers time and gives the regulator a lever. For 6 months from commencement the penalty in section 73EB does not apply to a plan manager already nominated in a participant’s plan, and the plan-management-only condition does not apply to an existing registered plan manager. After commencement, if an existing plan manager has no deed in force, The Commissioner may, in writing, revoke the registration. The verb is may.

What the Department says about timing, and what it calls the change

The Department of Health, Disability and Ageing’s Securing the NDIS page, last updated 27 August 2026, lists among its measures to commission a panel of plan management providers to improve service quality and integrity standards and reduce fraud. Under next steps it says: The new plan management approach will be implemented from 1 October 2027, beginning with a 6 month transition period.

That is the Department’s stated plan, not law. The Act does not mention a panel and does not name 1 October 2027; only a Proclamation can set the day. The Department’s 6 month transition does match the two 6 month windows in item 101. As at 7 October 2026 the Federal Register lists no Proclamation for the Act, and its version list for the NDIS Act shows future boundaries for Act 66’s dated parts, to 1 January 2028, but none for the Part 6 items, 90 to 101.

The market Part 6 lands on, in the NDIA’s own figures

At the Senate Community Affairs Legislation Committee’s Perth hearing on 6 August 2026, Senator Alex Antic asked how many providers offer plan management, how many claims they lodge, and how many had made inappropriate claims. The NDIA took the questions on notice. Its written answers, published on the committee’s inquiry page, are the most detailed public picture of this market we have found.

The NDIA’s summary: The plan management market is characterised by a small number of large plan managers, and a long tail of many plan managers supporting very few participants. In the October to December 2025 quarter, it says, payments to plan managers totalled $8 billion, of which $163 million was for plan management services and the rest paid providers on participants’ behalf. So the fee is about 2 per cent of the money that flows through plan managers.

On the count of plan managers, answer IQ26-000066 says 4,080 different providers held an active registration to provide plan management at some point from 2022-23 to 2026-27; there were 2,786 registered plan managers at 30 June 2026; and 1,584 were active in 2025-26, of which 599 claimed only plan management fees and no other supports in the year. It then sorts the 1,584 by the plan management fees the NDIA paid them in 2025-26:

Adding the bands: 17 plan managers were paid more than $5 million in fees, and 922, 58 per cent of the 1,584, were paid less than $50,000. 603 were paid less than $10,000, and 259 less than $1,000. The ten bands sum to the NDIA’s total.

One caution on the counts. At the hearing itself an official put the figure at 2,800 registered plan management providers, Approximately 1,400 of those providers are active and operating. The written answer’s 1,584 counts plan managers active at any point in the 2025-26 year, so the two measure different things; we use the written figures.

What the NDIA says it found in that tail

Answer IQ26-000067 sets out the integrity findings. Each is the NDIA’s own figure, and none names a plan manager.

• An NDIA assessment of fraud risk showed that over 90% of the smallest 1,000 plan managers had fraud risk flags. A risk flag is an indicator the Agency uses to target checks; it is not a finding that any plan manager committed fraud.
• The Australian Taxation Office analysed the 899 riskiest small plan managers and found 343, or 38 per cent, would not meet Statement of Tax Record requirements.
• High risk claims from plan managers rejected through pre-payment integrity reviews: none in 2022-23 (No provider/plan manager pre-payment integrity program), 413 claims totalling $555,000 in 2023-24, 4,924 totalling $11.5 million in 2024-25, and 7,339 totalling $28.1 million in 2025-26. Of the 2025-26 rejections, 59% due to no services actually delivered, 32 per cent for not being in line with the plan and 9 per cent for duplicate or incorrect claims. The NDIA attributes the rise to its own effort: The NDIA is detecting and rejecting more claims as it improves detection systems and increases pre-payment treatment capacity.
• A post-payment review that began in March 2025 had covered 47 plan managers, and the NDIA says 28 of them had significant non-compliance, including claims inconsistent with section 10 of the Act (its examples are iPads, groceries, alcohol and household items) and payments to unregistered providers of therapy supports.
• Manual Payment Review, under which payments are paused until the NDIA has reviewed the evidence for a claim, was in place for 19 providers, plan managers and participants in 2022-23, 678 in 2023-24, 1,217 in 2024-25 and 1,391 in 2025-26. Answer IQ26-000068 adds that over 1,000 plan managers were subject to it as at 31 March 2026.
• The NDIA has referred over 360 plan managers for criminal investigations or interventions by other Fraud Fusion Taskforce partners.

The figures come with a caveat on the early years. At the hearing, the official who took the question on notice said data from 2022 on would not be representative because of the maturity of systems over that time. A rising count of rejected claims reflects more checking as well as whatever is being caught.

Our view

This is opinion, built on the documents above. Part 6 and the NDIA’s answers point the same way. The Act replaces registration alone with a contract the Agency is a party to, and the Department calls the result a panel. Read together, that suggests the number of plan managers after the transition will be set by which providers hold a deed, not only by who can register. The Act does not say how many deeds the Agency will offer or on what basis, so that is our inference, not something the law states.

For a participant the practical questions are two. First, does your plan manager also provide you, or anyone, other NDIS supports? If so, once the 6 month window passes it can keep only one of those roles. Second, when the public register appears, is your plan manager on it? Until a Proclamation is made, neither question has a date, and the Department’s 1 October 2027 is a plan rather than a commencement.

For plan managers, the deed’s content will matter more than anything in the Act, because subsection 73EA(2) lists only headings. Related party is defined in new subsection 73EA(2A) by the Corporations Act’s tests for relatives and associated entities, and NDIS rules may prescribe further circumstances.

What we could and could not check

We have not seen a draft deed, and we found no published one. The NDIA’s website blocks automated reading, a constraint we have recorded since August 2026 and do not try to get around, so we make no statement about what the NDIA has or has not published there on plan management. The answers on the committee page carry the date the committee set for their return, 10 August 2026, but no publication date.

Background on registration as it stands today is in which NDIS providers must register, and the money flowing through plan managers is in our piece on the Pricing Schedule.