In Australia, the Early Years Learning Framework (EYLF) invites educators in Early Childhood Education and Care (ECEC) services to view children as learners who are confident and involved (Australian Government Department of Education, Employment and Workplace Relations, 2009) while the National Quality Standard (NQS) contends that the “educational program and practice of educators are child-centred, stimulating and maximise opportunities for enhancing and extending each child’s learning and development” (Australian Children’s Education and Care Quality Authority [ACECQA], 2017, p. 95). Additionally, article 12 of the United Nations Convention of the Rights of the Child (UNCRC) advises that it is a child’s right to contribute and their opinions need to be considered in decisions that affect them (United Nations Children’s Fund [UNICEF], 1996). Nonetheless, limitations appear to exist in supporting educators’ decisions and provisions in the environment and use of the outdoor learning spaces that contrast with the documents that underpin educator practice. This literature review examines the tensions between the ideal and the reality of children’s and educators’ decision making in outdoor learning spaces. It shows that strong policy alone is not sufficient unless underpinned by an environment in which educators are able to make decisions without fear of litigation and children’s perspectives are heard, respected, and enacted.