Wendouree man Kane Cameron-Kiely, 24, had been on the sex offender registry for less than a week in September 2020 when he messaged a 12-year-old girl on social media app Instagram: "You are pretty cute just saying."

The accused has a mild intellectual disability and an IQ of 67. He was 21-years-old at the time.

The County Court of Victoria heard on Tuesday the message was the first of "numerous" communications Cameron-Kiely would send to six underage girls across the following months through to March 11, 2021.

Crown prosecutor Michelle Zammit said there was an escalation from the accused's earlier offending where he was found to have sent sexually explicit messages to a 13-year-old girl in 2017 after her father reported it to Ballarat Police.

He was handed a two year community corrections order with 150 hours of community service work for the related charge of using a carriage service to procure a person under 16 years of age.

"While there was contact with [an] initial 13-year-old victim we now have communication with six victims including two sisters aged 11 and 12," Ms Zammit.

"The messages take on a further explicit nature."

According to court documents seen by The Courier, Cameron-Kiely tried arranging to meet one of the girls, aged 11, at Wendouree McDonalds on multiple occasions, and sent her an explicit image of himself and "vulgar" text messages, including asking if she was alone and to keep their interactions a secret.

Ms Zammit acknowledged a jail term for the escalated offending would "weigh more heavily" on the accused given his disability and medical issues, including Chron's disease, but said prison was within sentencing range.

"[These] notwithstanding, this is a case the prosecution submits anything less than a term of imprisonment with a non-parole period would be impermissible," she said.

"He's demonstrated his awareness that he knows it's behaviour he can not only not engage in, but he's told by [a doctor,] 'you can't do this'."

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Counsel for the accused Jonathan Barreiro's defence hinged on the "complicated" mix of mental diagnoses for Cameron-Kiely, including his disability, personality and social anxiety disorders, and paedophilic attraction.

"The personality impairment has undermined his ability to manage his deviant arousal," Mr Barreiro said.

"The anxiety [disorder], social withdrawal, contributes to disconnection which puts him in a place where he's more likely to reoffend because of his intellectual disability and personality disorder."

Mr Barreiro said while the accused's "make up" resulted in him being more likely to reoffend, it also meant he responded well to treatment.

Cameron-Kiely has not reoffended since engaging in treatment under the corrections order issued in 2020. However, he did not disclose his escalated offending at the start of the order with any treatment providers.

Judge Michael Tinney questioned the defence counsel at length on Tuesday and challenged submissions that Cameron-Kiely had reduced moral culpability for the escalation.

"He's counselling secrecy and plainly enough he's not disclosing to those treating him under the order ... [he] knew he was dealing with young girls, he knew he was on an order and he knew what he was doing was wrong," the Judge said.

"But for the very serious offending he's committed, his compliance record would be exemplary, but that's the 'but'."

Mr Barreiro replied: "But then he goes to sink his teeth into [treatment]."

The accused pleaded guilty on Tuesday to charges of failing to comply with sex offender reporting obligations and grooming a child under 16.

Judge Tinney ordered the accused be assessed for another corrections order and a justice plan.

"We're a long way from this being the end position," the Judge said.

"My calling for these reports does not convey any end destination."

Cameron-Kiely's bail was extended until April 18, 2023, when the matter will return to court.

"I have to work out whether I send you to prison or if there's an alternative option," Judge Tinney told the accused.

"So for heaven's sake, the internet has brought enough troubles for you so stay off it."

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