
The assessment data your accreditation body will ask for
An accredited training provider does not get one standard list of assessment records. In the four rule sets compared here, as of October 2026, each body asks for different things: identity and results come up most often, minimum retention runs from 2 to 7 years, and none of the provisions reviewed names item-level responses or retake logs.
This guide sets the primary-source wording side by side for IACET, the WIOA eligible training provider list, EPA’s accreditation rule for lead-safe training, and Australia’s VET regulator. It then turns the gaps into a records checklist. Our posts on IACET assessment evidence for CEUs and ETPL learner outcomes reporting go deep on one body each. This one is the cross-body view.
This is general information, not legal advice. Rules change, and your own approval documents may add conditions. Have your accrediting body or a qualified adviser confirm each row before you rely on it.
Key takeaways
- Identity and test results are the most commonly named data. Only EPA’s rule lists per-student results and identity details in any depth.
- Minimum retention for assessment-related records ranges from 2 years (Australia) to 7 years (IACET), and the ETPL rule sets none.
- No provision reviewed names item-level responses or retake history, so keep them anyway if you need to prove a result.
- When more than one body applies, keep each record until the longest applicable clock ends and ask the body in writing when a rule is unclear.
Which bodies does this comparison cover, and why these four?
This guide covers four bodies whose assessment-related record rules could be read from their own published text in October 2026: IACET’s ANSI/IACET 1-2018 requirements matrix, the WIOA eligible training provider list rules, EPA’s training program accreditation rule for lead-safe work, and the Australian VET regulator’s 2025 compliance standards.
The word “accredited” does not mean the same thing across them. EPA’s rule refers to “accredited training programs.” WIOA states keep a list of “eligible” providers. Australia’s regulator registers training organizations. Your own approval letter tells you which rules apply to you.
Two things are left out on purpose. ISO/IEC 17024 personnel certification schemes are not covered because their clause wording could not be read from a free primary source. State education agencies and OSHA programs are also out of scope. If one of those is yours, treat the checklist below as a starting point only.
Which assessment records does an accredited training provider have to keep?
Identity and results are named most often, but the depth differs. EPA lists per-student results and identity details, IACET asks for processes rather than fields, the ETPL rule asks for aggregate outcomes, and Australia’s regulator asks for the assessments themselves. Table 1 gives the wording and section numbers.
| Data element | IACET (ANSI/IACET 1-2018) | WIOA ETPL (20 CFR 680.460) | EPA lead-safe training (40 CFR 745.225) | Australia VET (2025 compliance standards, s 10) |
|---|---|---|---|---|
| Learner identity | Process to verify that the learner who registers and takes part is the one who receives the CEU (8.1) | Not addressed in this section | Certificate carries name, unique ID number and address ((c)(8)). E-learning gives each student a unique identifier ((c)(6)(viii)(A)). Post-course report adds date of birth ((c)(14)) | Register of qualifications and statements of attainment issued (10(a)). Identity checks not described in s 10 |
| Test or assessment results | Assessment methods and a process to confirm learners achieved the outcomes (7.1, 7.2). No score format named in the requirements read | Aggregate only: credential information and program completion rate ((g)) | “Results of the students’ hands-on skills assessments and course tests” ((i)(1)(vi)). Score per student in the post-course report | Records of all assessments a student submitted (10(c)) |
| Pass mark or criteria | Learners told whether they met “the established criteria” (8.2) | Share obtaining a recognized credential ((g)) | Passing score on the course test. E-learning closing test of at least 20 questions, 80% correct ((c)(7), (c)(6)(viii)(D)) | Not set in s 10 |
| Item-level responses | Not named | Not named | Not named for the course test. E-learning progress and knowledge checks are tracked | Not named. “Assessments submitted” is the nearest wording |
| Dates and times | Record for each learner and learning event (8.4). No time fields named | Exit date sets the reporting quarters ((g)) | Completion or test-passage dates on the certificate. E-learning log-ins and launches tracked ((c)(8), (i)(1)(ix)) | Retention clock starts when the student completes the training product (10(c)) |
| Retake or attempt history | Not named | Not named | Not named | Not named |
Table 1 reflects the wording as of October 2026. IACET and the Australian instrument were read from the standard’s requirements matrix and the instrument’s text. The two US federal rules were read from the eCFR, which describes itself as authoritative but unofficial.
Where do all four stay silent?
None of the provisions reviewed names item-level responses or retake history. Silence is not permission. IACET still requires a process to ensure learners achieved the outcomes through assessment, and item data is how most providers would show that process working. The same logic applies to attempt history when a learner passes on a third try.
Pro tip: Store the Form Version With Every Result. Record which form, item set and pass mark applied to each result. A score of 82% is hard to defend if the form or cut score changed since and you cannot show which version that learner saw.
Which rules reach down to the click and question level?
Among the four, only EPA’s rule for electronic learning goes this far. It requires a unique student identifier, tracking of log-ins, launches, progress and completion, periodic knowledge checks, and a closing test with no answer feedback until submission. The rule permits e-learning for the classroom portion of renovator, dust sampling technician and lead-based paint activities courses.
As of October 2026, 40 CFR 745.225(c)(6)(viii) sets these electronic learning requirements:
- A unique identifier assigned to each student to launch and re-launch the course.
- Tracking of “each student’s course log-ins, launches, progress, and completion.”
- At least 16 knowledge checks over the entire course, each passed before the next module.
- A closing test of at least 20 questions, with 80% answered correctly.
- No feedback on test answers until the student has completed and submitted the test.
Records of these events are also named in the recordkeeping paragraph, (i)(1)(ix). A provider that already logs them has much of an item-level data model in place, even though the rule never asks for item responses by name. If you serve other bodies, proctoring and identity checks for training providers covers how exam-day identity can be recorded.
How long must an accredited training provider keep assessment records?
Minimums range from 2 to 7 years depending on the body, and one rule sets none. IACET requires 7 years, EPA requires 3 years and 6 months or 5 years by course type, and Australia requires 2 years for assessments after completion. The ETPL rule leaves retention to state and grant terms. Table 2 compares retention and delivery.
| Question | IACET | WIOA ETPL | EPA lead-safe training | Australia VET |
|---|---|---|---|---|
| Minimum retention | “for a minimum of seven (7) years” (8.5) | No retention period set in 680.460 | 3 years and 6 months for lead-based paint activities courses. 5 years for renovator and dust sampling technician courses offered on or after April 22, 2010 ((i)(2)) | 2 years after the student completes the training product (10(c)). 30 years for AQF certification documentation (10(b)) |
| Who keeps the records | Provider maintains them and makes them available to learners (8.5) | Provider submits information to the state ((h)(1)) | Provider keeps them and makes them available to EPA on request ((i)(1)) | Provider keeps them. Students, including former students, can access copies of certification documentation (10(d)) |
| When data goes to the body | No routine submission named in the requirements read | “in a timeframe and manner determined by the State, but at least every 2 years” ((h)(1)) | Post-course notification received within 10 business days of completion ((c)(14)) | On request: report of qualifications and statements of attainment issued (10(e)) |
| Format and storage | Operational recordkeeping system with backup (8.4). Privacy and security policy (8.6) | Set by the state | Not specified beyond the records listed | Digital copies allowed where keeping originals is impractical. Safeguard against unauthorized access, fire, flood and pests (ASQA 2025 FAQ) |
Consider a hypothetical learner who completes a renovator course on November 20, 2026, in a program that also awards IACET CEUs. EPA’s 5-year minimum would run to November 20, 2031 and IACET’s 7 years to November 20, 2033, if both are counted from completion. Neither provision as read here names the start of its clock, so counting from completion is an assumption. Keep the record to the later date.
What should an accredited training provider’s records checklist include?
A cross-body checklist keeps one record per learner attempt, with the fields below and a retention date. The first group is named by at least one of the four bodies. The second group is named by none, yet makes the first group provable in an audit.
Fields at least one body names:
- Legal name, unique learner ID and address, plus date of birth and a photo where a body requires them (EPA).
- Course or learning event, with completion and test-passage dates (IACET 8.4, EPA).
- Test and hands-on results per student (EPA, Australia).
- Whether the learner met the criteria and when they were told (IACET 8.2).
- Certificate or statement issued, with its number (IACET 8.3, EPA, Australia). What you issue is a separate decision, covered in certificate of completion vs certification.
- E-learning log-ins, launches, progress and completion (EPA).
- Credential earned and completion status for outcomes reporting (WIOA ETPL).
Fields no body names, but which make the rest provable:
- Form version, items shown and the pass mark applied.
- Attempt number and date for every retake.
- Item-level responses.
- The identity check used on exam day.
Fields about the record itself:
- Retention-until date, set by the longest applicable rule.
- Backup and access controls (IACET 8.4 and 8.6).
Pro tip: Stamp the Retention Date at Creation. Write the retention-until date into the record when the result is saved, not when someone cleans up years later. Then deletion is a query, and a rule change means updating one date field.
What do you do when the rules disagree or change?
Trust the current legal text over older guidance, keep the longest clock when two bodies apply, and ask your body in writing when wording is unclear. Rules do move. Australia’s retention period changed in 2025, IACET has announced a new standard, and WIOA reporting varies by state.
Australia shows how sources can disagree. ASQA’s older guidance for the 2015 Standards says to retain completed assessment items “for at least six months” from the date of the competence judgement. The 2025 compliance instrument, in force from July 1, 2025, says 2 years after the student completes the training product. ASQA’s own 2025 FAQ refers to the “previous ‘6 month rule’.” For a provider operating now, the instrument governs. As of October 2026 the older guidance page was still online and carried no publication date.
IACET said on February 28, 2025 that it plans to develop and submit a new standard “within two years” and that the 2018 standard remains in effect. Plan for a possible change to requirement numbers, not just wording. For the ETPL, the rule sets submission “at least every 2 years,” while the state decides timing and manner, so read your state’s policy before you design exports.
What should you do next?
Pick the one body that matters most to your business and open its wording. Mark each row of Table 1 as met, partly met or missing against your current system. Treat any “missing” row as a data-capture question first, and a software question second.
Then run a mock request. Pick one past learner and try to assemble identity, form version, result, certificate and retention date in under an hour. Whatever slows you down is your first fix. Confirm any unclear row with your accrediting body in writing.
If you are weighing tools, the SimpliAssess features page lists test management, examinee management and analytics and reporting. It does not describe what an export contains, so confirm that detail with the vendor and your accrediting body. For scheduling and certificates, SimpliTrain is a separate product from the same company, and its page for training companies lists attendance tracking, certifications and grading, and assessments and exams.
Frequently asked questions
What is an accredited training provider?
The term has no single definition. EPA’s rule calls them “accredited training programs” and requires them to follow their approved application terms. IACET sets requirements for providers, WIOA states list “eligible” providers, and Australia’s regulator registers training organizations. Check which term, and which rules, your own approval letter uses.
Do accreditation bodies require item-level test results?
Not in the provisions reviewed for this guide. IACET, the ETPL rule, EPA’s rule and Australia’s section 10 name results, scores or assessments submitted, but not item responses. Keep item data anyway if you need to show how a result was reached, and confirm expectations with your own body.
How long should training providers keep assessment records?
In the rules reviewed, minimums were 2 years for Australian assessments, 3 years and 6 months or 5 years for EPA courses, and 7 years for IACET. The ETPL rule sets none. If more than one body applies to you, keep records until the longest period ends, and check how each body counts its clock.
Can assessment records be kept electronically?
Generally yes, with conditions. IACET requires an operational recordkeeping system with backup. Australia’s 2025 FAQ allows digital copies where keeping originals is impractical, of sufficient quality to be a genuine and complete copy. EPA’s electronic learning rule requires tracked log-ins, launches and completion. Check your own body’s conditions.
Does an assessment platform make a provider compliant?
No. The rules here place the duty on the provider. EPA says accredited training programs “shall maintain” the listed records, and IACET asks providers to “have a process” for retention. A platform can store and export data, but your body judges your processes, definitions and evidence.
Who holds the learner records, the accreditor or the provider?
The provider, in all four rule sets reviewed. EPA’s rule has programs make records available to EPA on request. IACET’s requirement has the provider keep them available to learners. Australia’s guidance has providers retain assessment evidence and produce it when the regulator asks.


