Table of contents
- National Higher Education Code to prevent and respond to gender-based violence explained
- What the National Code means for your organisation
- The do’s and don’ts of the National Code
- Why this feels harder than it should
- The problem isn’t the National Code as a whole
- What most organisations are doing right (and where it breaks)
- The shift the National Code is actually asking for
- The Clauses that have created confusion
- Clause 1.4e: understanding risk across the organisation
- Clause 1.4f: why capability becomes the issue
- Clause 1.4k: where everything gets tested
- How higher education Organisations can meet the National Code
- Why this work doesn’t hold together
- What this looks like when it starts to work
- Where to start
National Higher Education Code to prevent and respond to gender-based violence explained
Across higher education, there is growing pressure on how institutions prevent and respond to gender-based violence.
Over the past few years, student surveys, advocacy work and media reporting have highlighted consistent gaps. Students don’t always feel safe. Responses to disclosures can vary. And accountability is not always clear.
The introduction of the National Higher Education Code to Prevent and Respond to Gender-Based Violence (2025) is a direct response to this. It sets clearer expectations for what prevention and response should look like across the sector.
For leadership teams, this shifts the conversation. It’s not just about having policies in place, it’s about being able to demonstrate that they work, and that responsibility sits at an organisational level.
Read more: National Higher Education Code to prevent and respond to gender-based violence explained
What the National Code means for your organisation
One of the biggest shifts is that Gender-Based Violence (GBV) is no longer being treated as a standalone HR issue. It’s now sitting alongside WHS, governance and ESG, with board-level accountability and increasing expectations around transparency and reporting. This means Institutes of Higher Education need to move from reactive responses to a more proactive, system-wide approach, where prevention, capability and data all play a role.
Read more: Beyond Compliance: What the New National Code means for your organisation
The do’s and don’ts of the National Code
As Institutes of Higher Education start working through the Code, certain patterns are becoming clear.
What tends to work is starting with how things actually operate in practice. Mapping real scenarios, understanding how disclosures are handled end-to-end, and identifying where decisions are made and by who. This gives a much clearer view of where gaps and inconsistencies sit.
Where teams get stuck is trying to solve this through documentation alone. Building policies, frameworks and plans without a clear view of how those processes play out in real situations. It often leads to duplication, unclear ownership, and systems that don’t hold together when tested.
Other common challenges are keeping this work within one team, relying heavily on individual knowledge, or treating it as a one-off exercise rather than something that needs to be reviewed and improved over time.
The Institutes of Higher Education making progress are not doing everything perfectly, but they are able to see how their systems operate, where the gaps are, and what needs attention first.
Read more: The Do’s and Don’ts of the National Code
Why this feels harder than it should
On paper, the National Code is clear. It sets out expectations for prevention, response, governance, and accountability, and for most Institutes of Higher Education, the intent is well understood. Higher education providers have been actively working to align with these expectations, investing time into updating policies, delivering training, and strengthening support services across their organisations.
However, the experience of implementing the Code is more complex than understanding it. The challenge is not whether something exists, but whether it holds together in practice.
As Institutes of Higher Education move beyond documentation and into operational reality, questions begin to surface around consistency, effectiveness, and alignment. It becomes less about ticking requirements and more about understanding how the organisation actually functions.
This is where the work starts to feel harder than expected.
This is also where resourcing becomes a challenge. Delivering this work requires coordination across multiple teams, clear ownership, and often dedicated capability that doesn’t always exist internally. For many Institutes of Higher Education, that means relying on external support to bring structure to the work, which can be costly and difficult to sustain over time.
This is where the work starts to feel harder than expected.
The problem isn’t the National Code as a whole
A common assumption is that Institutes of Higher Education are challenged because the Code is difficult to interpret. In reality, most teams have a strong understanding of what is required. The expectations are clear, and there is generally alignment on what “good” should look like at a high level.
The difficulty lies in applying those expectations across the organisation. The Code does not sit within a single function. It spans student wellbeing, HR, compliance, governance, and operational environments such as accommodation.
Each of these areas contributes to prevention and response, but they do so in different ways, using different systems and processes.
As a result, Institutes of Higher Education are not lacking knowledge. They are lacking a clear, connected view of how their work operates as a whole.
Read more: National Higher Education Code Explained
What most organisations are doing right (and where it breaks)
There is a significant amount of good work already underway. We have universities who are reporting after implementing the Code in January 2026 and we have non-universities working towards a deadline of January 2027.
Institutes of Higher Education are strengthening policies, improving reporting pathways, and delivering training designed to build awareness and capability. These are critical components, and they reflect a strong commitment to meeting the expectations of the Code.
The challenge is not the presence of these elements, but how they connect. This work is often distributed across multiple teams, each responsible for a different part of the system. While each function may be operating effectively, the connections between them are not always clear. Processes can vary, information can be siloed, and ownership can become blurred.
This creates a situation where organisations appear compliant on the surface, but struggle to demonstrate how their systems operate in practice.
Read more: Most workplaces think they’re compliant. They’re not
The shift the National Code is actually asking for
The National Code introduces a shift in expectation. It moves beyond requiring Institutes of Higher Education to have the right elements in place, and towards requiring them to understand how those elements operate together.
Institutes of Higher Education are now expected to demonstrate how their systems function, where risk exists, and how prevention and response are being delivered in practice. This requires a level of visibility that is not always present in traditional compliance approaches.
Rather than focusing solely on documentation, organisations need to develop a system-level understanding of their operations. This includes how decisions are made, how information flows, and how different parts of the organisation interact.
Read more: Beyond Compliance – What the National Code Means for Your Organisation
The Clauses that have created confusion
While the Code is clear at a high level, there are specific parts where this complexity becomes more visible.
Clauses 1.4e, 1.4f and 1.4k are where many organisations are spending time. Not because they are unclear in intent, but because they require a different level of understanding of how the organisation actually operates.
These clauses ask organisations to understand risk across the organisation, build capability in how people respond, and review how systems are working in practice.
Clause 1.4e: understanding risk across the organisation
Clause 1.4e introduces the requirement for a whole-of-organisation assessment that identifies systemic risks, as well as the enablers and barriers to preventing gender-based violence. This represents a shift away from isolated risk management and towards a broader understanding of how risk exists across the organisation.
Risk is not confined to a single area. It exists across environments, behaviours, systems, and organisational structures. Understanding this requires organisations to bring together information that is often fragmented across different teams and functions.
In practice, this means moving beyond individual data points or processes, and developing a coherent view of how risk is distributed and managed across the organisation. For many Institutes of Higher Education, this is where the work becomes more complex, as it requires both coordination and interpretation.
We have put together a free guide to help you understand Clause 1.4e.
Read more: How Higher Education Organisations Can Meet the National Code
Clause 1.4f: why capability becomes the issue
While 1.4e focuses on understanding risk, clause 1.4f shifts attention to capability. It asks whether people across the organisation can respond consistently, confidently, and in line with what is expected in practice.
Even with strong systems in place, outcomes depend on how those systems are applied. Responses can vary depending on experience, judgement, and context, particularly in complex or high-pressure situations.
Where organisations get stuck is not in delivering training, but in understanding whether it has translated into capability. It is often unclear how confident staff feel, how decisions are being made, or whether responses are consistent across teams.
This creates a level of uncertainty. Not whether something has been done, but whether it would hold up in practice.
Clause 1.4k: where everything gets tested
Clause 1.4k requires organisations to review how disclosures and formal reports are actually handled. This is often the point at which the system becomes visible in a meaningful way. Rather than focusing on intended processes, it requires an examination of real-world practice.
This includes how cases are managed, how decisions are made, and how responses may vary across different parts of the organisation. For many organisations, this process highlights inconsistencies that were not previously apparent.
It also reveals the gap between design and delivery. Systems that appear coherent in documentation may function differently in practice, and this gap becomes critical when assessing effectiveness.
Where organisations get stuck is in how this is evidenced and reported. Reviewing individual cases is one part, but translating that into something structured, consistent and defensible across the organisation is much harder.
Many teams are working across large reporting requirements, often with 40+ of line items to capture, assess and demonstrate. This quickly becomes complex to manage, particularly when information sits across different systems, teams and formats.
This creates a different kind of uncertainty. Not just what is happening in practice, but whether it is being captured, reported and communicated in a way that reflects the reality of the organisation.
How higher education Organisations can meet the National Code
For many organisations, the question is not whether the work has started, but how to bring it together in a way that is clear, consistent and defensible.
This means moving beyond individual pieces of work, policies, training and processes, and taking a more structured view of how they connect across the organisation. It requires understanding where risk sits, how capability shows up in practice, and how responses are being managed and reviewed over time.
In practice, this often starts with mapping what already exists, identifying where gaps and inconsistencies sit, and prioritising what needs attention first. From there, the focus shifts to building a clearer, more coordinated approach that can be maintained and demonstrated over time.
We’ve broken this down into a more practical step-by-step approach here.
Why this work doesn’t hold together
Across all of these areas, a consistent challenge emerges. The work exists, but it does not always connect. Organisations are managing multiple components of prevention and response, often across different teams and systems, without a single, unified view.
The tools used to manage this work are often not designed for system-level visibility. As complexity increases, it becomes more difficult to maintain clarity. Information becomes harder to track, and inconsistencies become more difficult to identify.
This creates a gap between effort and understanding. Significant work is being undertaken, but organisations still struggle to confidently explain how their systems operate.
What this looks like when it starts to work
Organisations that are making progress are not necessarily those that have addressed every issue. Instead, they are organisations that have developed a clearer understanding of how their systems function.
They are able to map processes across the organisation, identify where inconsistencies occur, and understand how different components interact. This allows them to prioritise action more effectively and focus on areas of highest impact.
Importantly, they are also able to demonstrate this understanding. They can show how their approach is evolving, and how improvements are being made over time.
Where to start
For most organisations, the starting point is not to create new systems or frameworks. The work begins with understanding what already exists. This involves mapping current processes, identifying where responsibilities sit, and examining how different parts of the organisation interact.
It also requires a focus on actual practice, rather than intended processes. By understanding how situations are handled in reality, organisations can begin to identify gaps and areas for improvement.
This approach allows organisations to move from a fragmented view to a more coherent understanding of their systems.
Where Capyble fits
As organisations work through these requirements, many reach the limits of manual approaches. Spreadsheets and disconnected documents can only provide a partial view, and maintaining consistency becomes increasingly difficult as complexity grows.
Capyble is designed to address this challenge by helping organisations bring together what already exists into a structured, organisation-wide view. This supports the identification of systemic risks, enablers, and gaps, and enables organisations to prioritise action based on a clear understanding of their current state.
The focus is not on adding more, but on creating clarity.
