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The Victorian Qualifications Authority (VQA) developed a draft Credit Matrix Model for recognising the complexity of learning units delivered across the three educational sectors in Victoria, namely senior secondary education, vocational education and training [VET] and the higher education sectors. This paper reports on the empirical validation of the complexity component of the model, in particular, the appropriateness of the domains and indicators of learning thought to capture increasing complexity. To examine the validity and reliability of the draft Complexity Model, the indicators for each domain were empirically tested and validated through survey techniques. Participants were requested to (a) supply background information about the unit of learning; (b) judge which of the indicators within each measure best captured the complexity of their unit; and (c) rate each measure on its perceived effectiveness in defining the true complexity of the unit. Two hundred and fifty four (n=254) people responded to the survey. Of these people, 31% represented senior secondary education, 44% represented the VET sector and 25% represented higher education. Item Response Modelling was then used to evaluate the psychometric properties of the measures as well as to empirically develop and define levels of complexity within and across the measures. The data collected demonstrated the validity, accuracy and internal consistency of each Complexity Measure. The results also showed that the correlations among the five measures were significant, yet moderately positive, thus having direct implications for the factor structure that should underpin the Complexity Framework. Two variations of the framework were produced from this initial investigation: a six level structure and an eight level structure, each underpinned by the five domains: Application, Autonomy, Accountability, Problem Solving and Knowledge.