Auditors request records for children who have attended in the previous seven years. Missing years signal non-compliance. This is not a paperwork exercise. It is a forensic reconstruction of your service’s operational integrity. Every missing date stamp, unsigned form, or incomplete log is a documented failure of governance. The regulator’s spot-check system is designed to catch these failures. Your board’s job is to ensure they don’t exist.

The Audit Trigger

The auditor’s method is simple and devastating. They ask for the file. For safety checks, they look for three dated components: identity confirmation, police vet, and risk assessment. A missing date for any step is a fail. For excursions, they demand the signed risk assessment and the parental approval form detailing ratios and transport. Its absence is an admission that the excursion was not properly authorised. For incidents, they ask for the documented proof that a mandatory notification was sent to the Ministry and, if required, Oranga Tamariki or Police. No copy, no proof. The audit is a binary test: the document either exists in the required form, or it does not.

The Regulatory Hook

Non-compliance is anchored in the Education and Training Act 2020. Section 626 grants officials the right of entry to demand these documents. The 2026 ECE Licensing Criteria (GMA101, GMA109, GMA306, HS227, Schedule 2) specify exactly what must be recorded and retained. The Health and Safety at Work Act 2015 underpins the duty to manage risks, with documented assessments being the primary evidence of due diligence. When a child goes missing on an excursion, the absence of a prior risk assessment isn’t just a paperwork error—it’s potential evidence of a PCBU failing its primary duty of care, with all the legal ramifications that entails.