By CELA on 20 Oct, 2022

The question of whether to include nappy change facilities in a service is something that comes up frequently for early learning interior architecture designer Tracey Sharp. 

“What’s happening at the moment is there’s a conflict,” says Tracey, who spent over 20 years working in the ECEC sector before making a career shift into interior achitectural design. “The National Construction Code says that nappy change facilities aren’t required for services that don’t provide care for children under the age of three. 

“Obviously, this isn’t an issue for most long daycare centres. However, it becomes an issue in preschools that are brand new or redeveloping. In the case of a redevelopment, they don’t already have those facilities, so they may choose not to include them in the new design.”

Are we holding children to impossible standards? 

The law is one thing but does the law align with what we know about child development? Are we creating environments that are inclusive of children's individual stages of development?

Developmental Milestones and the Early Years Learning Framework and the National Quality Standards resource notes that between the ages of 3-5, we may observe that children can go to the toilet by themselves.1 Research suggests that only 40-60% of children are daytime toilet trained before they reach the age of three.2 That means that possibly only half of children are toilet trained by the time they reach the magic milestone of three. 

Tracey says this conflict between reality and the National Building Code is problematic. 

“There are some children that just aren’t ready to toilet train before the age of three,” she explains. “Potentially, they’ve had a traumatic experience with toileting and feel ashamed or embarrassed. But nappy change facilities and toilets are actually learning spaces for children. So we need to treat them as such.” 

The bottom line on toilet training 

The Victorian Government Better Health website recommends keeping children in nappies until they show signs that they are ready to start toilet training. These signs include interest in using the toilet, maturity to recognise the urge to use the toilet and a dislike of wearing nappies.3 Parenting expert Janet Lansbury advocates for a child-led approach as the key to successful toilet training.4 

There are many reasons why a child may not be toilet trained by the age of three, some of which are quite serious. Children may have an underactive or overactive bladder5, or they may be going through an emotional life change, such as welcoming a new sibling.6 Children with additional needs can also take longer to master toileting.7 

What are the ethical considerations? 

Jennifer Moglia, Executive Officer Professional Learning at CELA, suggests that even though this may not be a legal issue, it does have ethical implications. 

“How is a child allowed to 'be' if they’re not ready to toilet train?” she asks. “How are we guided by the framework of being, belonging and becoming if we’re not supporting children to be who they are at the stage they’re at?” 

The issue of dignity and supporting children is one thing, but Jennifer also says that inclusion is a concern. 

“What are we saying to our community if children that aren’t toilet trained are excluded from our service? What does it say about the philosophy of the service and its practices? It’s important to include all children, regardless of whether or not they’re able to independently use the toilet.” 

Tracey echoes Jennifer’s sentiments and believes that not including nappy-changing facilities impacts on the rights and dignity of the child. 

“There are some children that are just not ready to toilet train before the age of three,” she says. “If they can’t attend preschool or move to the next room at their long daycare centre, what does that say to them?” 

What does this mean for the future? 

Jennifer suggests considering policies and procedures and priority of access guidelines in making the decision about nappy-changing facilities. However, there is also an important human element that can be a critical difference in the success of a new way of doing things. 

“This requires critical reflection and discussion,” she explains. “There may be some procedural training required, but what’s most important is that educators are supported to understand the ‘why’ behind the decision to embrace the potential for greater inclusion of all children.” 


1. Australian Government Department of Education, Employment and Workplace Relations. Early Years Learning Framework Practice-Based Resources - Developmental Milestones

2. Anna Christie. Toilet Training Infants and Children in Australia: 2010. Restraint Project UNSW. 

3. Victorian Government. Toilet Training. Better Health. 

4. Janet Lansbury. 3 Reasons Kids Don’t Need Toilet Training (And What To Do Instead). August, 2014. 

5. Continence Foundation of Australia. Daytime Wetting. November, 2020. 

6. Continence Foundation of Australia. Toilet Training. August, 2022.  

7. Continence Foundation of Australia. Toilet Training Children with Special Needs. May, 2019. 


Toileting and Nappy Changing Principles and Practices 

Child Care Planning Guideline 

Child Care Centre Building Code, Regulations & Requirements 

CELA professional development relating to this topic

Find out more

About CELA

Community Early Learning Australia is a not for profit organisation with a focus on amplifying the value of early learning for every child across Australia - representing our members and uniting our sector as a force for quality education and care.



Ricky Tan
Posted on 27 Mar, 2024
It is ok for a child in Preschool, whether they have mastered the art of using the toilet,
Kathy Phipps
Posted on 10 Feb, 2023
We are a community preschool who follow the traditional enrollment requirement of 'toilet trained' but recognise that there are varying degrees and measures of what that means for any one child and their family. To support a more ethical and inclusive enrollment plan we are currently looking at purchasing a hydraulic nappy change table (and have applied for a local community grant), which we will accommodate in our disable shower space. The space and the table will provide privacy, comfort and safety for the child and work safe measures for our educators. To make what may appear to be a small and positive change does require a financial cost for both the structure and the extra team members and this must be considered, but the final decision should not be made at the cost of a good ethical decision that supports the rights of the child and their right to grow in self agency and be able to access an inclusive preschool program. If we are unsuccessful with the grant we will purchase the lift with our own funds as we believe that this is truly the right way for us to move forward with our children and their families within our community.
Posted on 2 Nov, 2022
There are enough children who are toilet trained by the age of 3 for centres and services to not be bothered about or with those who are not. In fact, parents are pressured with emotional blackmail-like talk, that their child may not be ready to "move up" to the "next class" if the child is not toilet trained. Staff start conditioning toilet training in the early toddlers age range and continue to interrupt the children's play and activities with their insistence on using the toilet as per staffing wants, needs, and schedules. Good luck with changing this archaic and selfish mindset; a mindset that serves no other purpose than to make the staff's life easier - there is always a battle for not wanting to do nappy changes, with casuals more often than not drawing the so-called short straw. And good luck with changing the emotional and verbal labelling associated with forcing the child to use the toilet by humiliating them with putdowns when they have an "accident" - "why did you do that" "why didn't you go to the toilet" "you're a big boy / girl now" and other cliché ridiculing. May I suggest that the use of the word "accident" be abolished as it is inappropriate and conjures the wrong image and thought process in a child's mind. Maybe the wording could state the facts - you have done a wee you have done a poo wee and poo belong in the toilet I will help you practice I will keep your toys safe while you go Call me when you need me and so on ... Good luck with this culture change
Tania Gibson
Posted on 1 Nov, 2022
This is an interesting topic but with the crisis on staffing in Early Years at the current level and I don't think many ECT'S will Favour changing nappies as most sadly don't believe they should clean their rooms. Again, this will fall on our existing trained staff who are already burnt out.
Sharon Walker
Posted on 26 Oct, 2022
This article is brilliant and raises some very important ethical points for us in early childhood education. I have always been an advocate for children to progress at their own pace and to be included with their peers. Toileting is just like any other skill and developmental milestone. No child should be excluded or made to feel shame if they have not yet mastered this skill and no early childhood educator (of any qualification) should be above helping a child learn this skill. Thank you for putting this issue in the spotlight.
Jennie Hudson
Posted on 25 Oct, 2022
I think that there is more to this. If you are running a preschool to the 1-10 or 1-11 ratio, you are not typically staffed to cater for children that are not toilet trained. It is not just about dignity but a child protection and a supervision issue if staff were to change the child in a cubicle or other more dignified area. We have an ECT in our 2-3 room who provides preschool level programming to 3 year olds not toilet trained or toilet training, however we run that room at 1 to 5 or better and charge fees appropriate to that level of supervision. Children in that situation are allowed to participate in incursions targeted at Preschool age.
Heidi Lyons
Posted on 25 Oct, 2022
Children are not always toilet trained by the age of 3yrs. Should they be held back from going to Preschool or moving up to the Preschool room because they're not toilet trained? Where is the INCLUSIVE ENVIRONMENT, doesn't the EYLF & NQF talk about the Inclusion of all children? In our service moving up to the Preschool room is not determined by if you're toilet trained or not. Although I have heard of services that actually do this. How is that ok to hold a child back that is in all other areas ready for Preschool, but just hasn't mastered the art of using the toilet? What about children with additional needs? are they to be excluded from these environments if there are no nappy-changing facilities?
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