Response to the Independent Review of the Retirement Living Code of Conduct
Introduction
The first independent review of the Code, which commenced on 1 January 2020, is both constructive and timely. It confirms that the Code continues to play an important role in retirement living and that it should now be updated to reflect a more mature, more complex and highly regulated operating environment.
Against that backdrop, the review provides an opportunity to update the Code so that it remains fit for purpose in the current regulatory environment. The Code was established to promote and protect the interests of current and future residents, lift standards, build trust and confidence, support complaints resolution and provide a self-regulatory framework that complements legislation.
Those objectives remain sound.
The review also highlights the need to improve awareness and accessibility of complaint-handling and escalation pathways, including the Code Administrator pathway. More broadly, it indicates that the next version of the Code should be shorter, clearer and more visible to residents; principles-based; focused on resident outcomes; and stripped of unnecessary duplication of legislative requirements.
The review also finds broad support for the concept of an industry Code among residents, government representatives and Code signatories, while also highlighting concerns about its visibility, consistency and enforcement.
In summary, we acknowledge the review’s findings on scope, structure, visibility and enforcement, and will use them to inform the next version of the Code. This will include clarifying the role, operation and visibility of the Code Administrator and Panel functions. The Code will remain a voluntary instrument operating alongside state and territory legislation.
For transparency, the Retirement Living Code Administration (RLCA) – the body responsible for administering, promoting and enforcing compliance with the Code – has set out its response to the individual recommendations in the table that follows.
The RLCA will now commence work on the revised Code, informed by the review, and will publish it once finalised through its governance processes.\
Acknowledgements
The RLCA thanks Phil Khoury and the team at cameron ralph khoury (CRK) for conducting a thorough and independent review of the Retirement Living Code of Conduct.
The review drew on extensive consultation with residents, resident committees, operators, government representatives and Code signatories. Those perspectives have provided valuable guidance on how the Code can be modernised while continuing to support trust, transparency and high standards across the sector.
The RLCA also acknowledges the residents, operators and stakeholders who contributed to the review process and shared practical insights into how the Code operates on the ground.
Trust, Confidence and Resident Outcomes
The Code exists to support trust and confidence in retirement living communities.
Residents and their families rightly expect transparency, professionalism, accountability and respectful engagement throughout the resident journey. The review confirms that the Code remains an important mechanism for supporting those expectations, while also identifying opportunities to make it clearer, more visible and more practical.
The next version of the Code should be:
- Clearer and easier for residents to understand
- More visible across retirement communities
- Focused on resident outcomes
- Principles-based rather than duplicative of legislation
- Supported by stronger guidance, education and communication.
The RLCA agrees the Code should continue to operate alongside state and territory legislation – not as a substitute for regulation, but as an industry commitment to high standards and continuous improvement.
Responding to the Review
The RLCA acknowledges the review’s conclusion that the Code requires modernisation to reflect the contemporary retirement living environment.
The review raises important questions about the future role and structure of the Code, the functions of the Code Administrator and Panel, how awareness and uptake can be strengthened, and how the Code can better support residents and operators.
The RLCA supports the overall direction toward a shorter, clearer, more resident-centric and outcomes-focused Code framework. To progress this work, the RLCA has engaged CRK to assist with refinement of the Code and development of its next iteration.
The revised Code should speak more directly to residents, use plain English drafting, avoid unnecessary duplication of legislative requirements, and clearly articulate the standards and behaviours expected of Code signatories.
Full RLCA Position on Review Findings and Recommendations
Conclusion
The RLCA thanks Phil Khoury and CRK, along with the residents, operators and stakeholders who contributed to this review.
The review provides valuable guidance on how the Code can evolve to better support residents, strengthen trust, improve visibility and promote high standards across the retirement living sector.
The RLCA welcomes the review’s direction toward a clearer, more resident-focused and outcomes-oriented Code framework.
Where concerns have been identified, the RLCA has sought to balance stronger resident outcomes with practical implementation, proportionality and the realities of a highly regulated national environment.
The next version of the Code will support higher standards, greater transparency and stronger public confidence across the sector.