12 February 2026

TEQSA is aware of accounts of aggressive and direct promotional activities of commercial academic cheating services that target students studying for an Australian higher education award. The accounts suggest operators of these services are approaching students on campuses to promote their services and collect students’ contact details. This follows concerns TEQSA raised in a previous sector alert, of students being approached in online environments, including directly through email, social media and class groups set up in messaging apps.

These accounts suggest these activities are organised and coordinated and may involve:

• coercing students who have previously used commercial academic cheating services, under threats of blackmail, to sign-up other students
• offering students incentives and convenient ways to register or sign-up for commercial academic cheating services.

Engaging illegal academic cheating services may leave students vulnerable to identity theft and blackmail, and increase cyber security risks for students and higher education providers.

Background

Amendments to the TEQSA Act in September 2020 made it illegal to provide or advertise a commercial academic cheating service in Australia. Since then, TEQSA has worked to block illegal cheating websites and remove social media accounts and posts that advertise these services, disrupting their business model.

In April 2024, TEQSA issued a sector alert to providers advising of changes in the marketing and promotional behaviour of commercial academic cheating services. The alert highlighted the direct promotional activities used by these operators to target students through email or via class groups set up in messaging apps or on social media platforms.

Research shows commercial academic cheating services are frequently coordinated by organised groups and can involve criminal behaviour, putting students who use them at risk of blackmail or identity theft. Blackmail activities can include demands for further payment, class materials or contact details of other students.

If you become aware of information or evidence relating to a commercial academic cheating service targeting your institution, or being used by students at your institution, you can lodge a report via our website.

Immediate provider actions

TEQSA stresses the need for Australian higher education providers to be vigilant in addressing risks to academic integrity by engaging in a range of activities to educate students, detect cheating, upskill staff and report cheating services.

TEQSA expects all providers to reassess the risks and effectiveness of their responses to these risks, including ensuring:

• information on the risks of using these services is shared with students as part of their induction
• the risks associated with using academic cheating services are clearly and regularly communicated to students as part of ongoing discussions about academic integrity
• students are aware of how to access genuine study support, should they need it. Additional resources to support students with academic misconduct are available on our website
• students and staff are aware of, and have clear pathways to, raise an alert with campus security (for example, via a security app or a phone number), should cheating service activities or recruiters on campus require an immediate response
• students know how to access security and support services if, for example, they are experiencing blackmail
• students and staff are made aware of the potential for class groups on messaging apps and social media platforms to be infiltrated by academic cheating services
• students and staff are regularly reminded of their obligation to comply with IT security protocols
• IT systems are monitored for suspicious activity, and spam filters and other tools are updated to quarantine emails to students that advertise illegal cheating services
• consideration is given to reissuing the login credentials and requiring password updates
• posters, business cards and other material posted or left on campus promoting commercial academic cheating services are promptly removed.

Resources

Previous relevant updates from TEQSA

• Sector alert: Changes in commercial academic cheating service activities in 2024
• Sector update: Cyber security and associated risks posed by illegal academic cheating services

Supports for students

TEQSA has the following supports for students available on our website:

• Student academic misconduct resources
• Understanding academic integrity (including in languages other than English)
• Academic integrity toolkit

Additional TEQSA resources

• TEQSA’s Protecting academic integrity page provides a full and up-to-date list of academic integrity materials for providers.
• Staff with relevant responsibilities may wish to complete the free online TEQSA Masterclass: contract cheating detection and deterrence

Information about Australia’s anti-commercial academic cheating laws

• Tertiary Education Quality and Standards Agency Amendment (Prohibiting Academic Cheating Services) Bill 2019
• Fact sheet about the Prohibiting Commercial Academic Cheating Services Bill 2019 (PDF, 65 KB)
• Blocked commercial academic cheating websites
• Report a suspected commercial academic cheating service

Purpose

The purpose of this policy is to describe TEQSA’s approach to considering extensions to the period of provider registration or course accreditation under sections 37A and 57A of the Tertiary Education Quality and Standards Agency Act 2011 (the TEQSA Act).

Legislative authority

Section 37A of the TEQSA Act provides that TEQSA may extend the period of a registered higher education provider’s registration. The extended period may exceed seven years.

Section 57A of the TEQSA Act provides that TEQSA may extend the period of the accreditation of a course of study. The extended period may exceed seven years.

Principles

1. TEQSA may consider extending the period of a provider’s registration or the period of accreditation of a course of study for a range of reasons. These include:
   
   1. to reflect an established track record of low-risk, high quality delivery of higher education, either across a provider’s operations or with respect to one or more courses
   2. to harmonise periods of registration and accreditation, or harmonise periods of registration under the TEQSA Act and another act (such as the Education Services for Overseas Students Act 2000)
   3. to provide for efficient management of TEQSA’s workload.
2. Relevant matters when considering a possible extension under section 37A or section 57A include, but are not limited to, the following:
   
   1. the provider’s history, including the history of its scholarship, teaching, research, students’ experiences, financial status and capacity, and compliance with the Higher Education Standards Framework, TEQSA Act and other laws regulating higher education
   2. matters relevant to the risk of the provider not complying with the Higher Education Standards Framework or the TEQSA Act in the future, including its internal quality assurance mechanisms and its financial status and capacity
   3. any material risks to students or quality identified in the risk assessments for the provider
   4. the quality of data submitted by the provider as part of TEQSA or other Australian Government information collection processes
   5. TEQSA’s anticipated workload during the period when the provider’s registration or course accreditation is due to expire
   6. the period of any other registration or accreditation of the provider (including registration under the Education Services for Overseas Students Act 2000 or the National Vocational Education and Training Regulator Act 2011), and the extent to which harmonisation of the expiry dates of registration or accreditation would benefit the provider
   7. any relevant comments or evidence from the provider
   8. any relevant comments or evidence from other agencies, including (but not limited to) the Department of Education, the Australian Skills Quality Authority
   9. the need for any decision, and the process leading to any decision, to be appropriate, fair, objective, and defensible.
3. The TEQSA Act does not limit the period for which a provider’s registration or course accreditation may be extended. With this in mind, TEQSA will usually extend registration or accreditation for a period no longer than seven years, to provide an appropriate opportunity for a scheduled review of the provider or a particular course. Further, in circumstances where a short extension is being considered (up to 12 months), it may be more appropriate to first consider allowing a provider to submit its application for renewal at a date later than the usual 180 days prior to expiry – this would allow an extension to be considered closer to the expiry date if it becomes necessary.

Contact

A provider can contact TEQSA’s Enquiries Management Team if there are any enquiries about extensions to the period of provider registration or course accreditation.

• send an email to providerenquiries@teqsa.gov.au
• or phone 1300 739 585.
   

Documents

Guide to fitness and propriety under the TEQSA Act  (MS Word, 162 KB)

Guide to fitness and propriety under the TEQSA Act  (PDF, 202 KB)

Overview

In 2017, the Tertiary Education Quality and Standards Agency Act 2011 (the Act) was amended to include a ‘fit and proper person’ requirement at provider registration and renewal of registration, and as an ongoing condition of registration as a higher education provider.

This requirement is located in the following provisions of the TEQSA Act:

• Paragraph 21(1)(b) provides that TEQSA may grant an application for registration if it is satisfied that the applicant, and each person who makes or participates in making decisions that affect the whole, or a substantial part, of the applicant’s affairs, is a fit and proper person.
• Paragraph 36(1)(b) contains an identical provision with respect to renewal of registration.
• Subsection 25A provides that a registered higher education provider, and each person who makes or participates in making decisions that affect the whole, or a substantial part, of the provider’s affairs, must be a fit and proper person. This is a condition of registration.

In December 2018, the Tertiary Education Quality and Standards Agency Fit and Proper Person Determination 2018 (the Instrument) came into effect. The purpose of the Instrument is to specify matters that TEQSA may have regard to when determining whether a person is fit and proper under paragraph 21(1)(b), subsection 25A and paragraph 36(1)(b) of the Act.

On 5 April 2025, the Instrument was amended by the Tertiary Education Quality and Standards Agency Fit and Proper Person Determination 2018 – Amendment No 1 of 2025. The amendments allow TEQSA to have regard to the following additional matters when determining whether a person is fit and proper:

• whether a person has been convicted of a foreign offence against a foreign law/s (subsection 6(1A))
• whether a person has previously been found not to be a fit and proper person for the purposes of any other law of the Commonwealth, a State or Territory (subsection 10(1)(i))
• whether the public is unlikely to have confidence in a person’s suitability to be a person who makes or participates in making decisions that affect the whole, or a substantial part, of a registered higher education provider’s affairs (subsection 10(3A)).

Section 7A of the Educational Services for Overseas Students Act 2000 (ESOS Act) also specifies matters that TEQSA (as an ESOS agency) must have regard to in deciding whether a provider is fit and proper to be registered for the purposes of the ESOS Act.

This guidance sets out the principles and considerations that TEQSA will have regard to when assessing fitness and propriety for the purposes of the TEQSA Act.

What does it mean to be a ‘Fit and Proper Person’?

‘Fit and proper person’ is not defined for the purposes of the Act. Read in the context of the Act, TEQSA considers that whether a person is fit and proper should be determined by reference to the person’s character and ability, as well as the likelihood that the person will comply with (or reasonably assist compliance with) the obligations imposed by the Act and the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards). Whether a body corporate is fit and proper should be determined by reference to the persons through whom the body corporate acts, as well as the body corporate’s own history. These considerations are reflected in the Instrument.

The objects of the Act include, among other considerations, the protection and enhancement of Australia’s reputation for quality higher education and training services and to protect students undertaking, or proposing to undertake, higher education in Australia by requiring the provision of quality higher education. These considerations underpin TEQSA’s regulatory activities and inform the way in which fitness and propriety is assessed by TEQSA.

What matters does TEQSA consider?

The Instrument sets out matters that TEQSA may have regard to in determining whether a person is a fit and proper person for the purposes of the TEQSA Act.

If one or more of the matters set out in the Instrument arises in relation to a person, TEQSA’s assessment will take into account additional factors such as:

• whether the matter in question is relevant to exercising duties within the higher education sector
• the seriousness of the matter
• the length of time that has lapsed since the event occurred
• any history of past conduct
• any consequences for the applicant or any other person
• the implications of the matter—that is, what it shows about the person
• the person’s attitude towards the matter—such as whether the person has learnt, changed and improved their behaviour and is unlikely to further offend in the future.

The evidence that is relevant to whether a person is fit and proper, and the weight that should be afforded to that evidence, will be considered in the circumstances of each case.

Compliance with the law

In determining whether a person is fit and proper, TEQSA may have regard to matters in relation to the person’s compliance with the law, including whether the person:

• has been convicted of an offence against an Australian or foreign law
• has been ordered to pay a pecuniary penalty (monetary penalty) under an Australian law
• is currently involved in proceedings before a court or tribunal.

If the person has been convicted of an offence or ordered to pay a pecuniary penalty, TEQSA may have regard to the seriousness of the offence or contravention concerned.

However, TEQSA will not have regard to:

• a conviction that is spent under Part VIIC of the Crimes Act 1914 (Cth) or a similar State or Territory law (meaning the person is generally no longer required to disclose the conviction and it will not appear on most criminal record checks)
• a conviction that has been quashed, set aside, extinguished, annulled or pardoned.

Financial record

A person’s financial record is an important element in determining their fitness and propriety.

When assessing a person’s financial record, TEQSA may have regard to matters including whether the person:

• has been insolvent or bankrupt
• has taken steps to take the benefit of any law for the relief of bankrupt or insolvent debtors, such as a debt agreement under part IX or a personal insolvency agreement under part X of the Bankruptcy Act 1966 (Cth)
• has compounded debts with one or more creditors
• has assigned remuneration for the benefit of one or more creditors
• has been under external administration, in relation to a company
• owes outstanding debts to the Commonwealth.

Management history

In determining whether a person is fit and proper, TEQSA may have regard to matters relating to the person’s management history in the provision of education and as a company director including:

• whether:
  • the person’s registration to provide higher education or vocational education and training
  • the person’s registration as a Registered Training Organisation (RTO)
  • the accreditation of a higher education course of study in relation to the person
  • the person’s registration under the ESOS Act
  • subsidy funding arrangements for the provision of education by the person, such as Commonwealth Supported Places
    
    have been cancelled, revoked, shortened, not renewed or suspended
• whether the person has:
  • had a condition imposed on one of the types of a registration, approval or arrangement mentioned above
  • breached such a condition
  • been disqualified from managing corporations under Part 2D.6 of the Corporations Act 2001 (Cth). 

Provision of information

TEQSA may also have regard to whether the person has provided false or misleading information to persons or bodies including:

• TEQSA
• the National VET Regulator, i.e. the Australian Skills Quality Authority (ASQA)
• a body of a State or Territory that registers education providers
• a tuition assurance administrator
• a relevant Minister, Department or Secretary - currently the Minister for Education, Department of Education and Secretary of the Department of Education
• an authority of a State or Territory that deals with subsidy funding arrangements for education

in circumstances where it is reasonable to assume that the person knew the information was false or misleading.

Previous conduct and involvements

Finally, in relation to a person’s previous conduct and involvements, TEQSA may have regard to matters including:

• whether the person has been found not to be a fit and proper person under other Acts, instruments and arrangements listed at subsection 10(1) of the Instrument
• whether the person has engaged in conduct that reasonably suggests a deliberate pattern of unethical behaviour, or of acting inconsistently with laws of the Commonwealth, a State or Territory, in relation to the provision of education or training
• whether a business providing education would have been a fit and proper person for the purposes of the Act at the time the person was involved with that business
• whether the public is unlikely to have confidence in the person’s suitability to be a person who makes or participates in making decisions that affect the whole, or a substantial part, of a registered higher education provider’s affairs
• any other matter relevant to the honesty, knowledge or ability of the person.

TEQSA may consider instances of previous conduct that did not result in a conviction but call into question a person’s judgement and integrity, for example, if a person has been found to have committed an act of professional or academic misconduct.

TEQSA’s processes

A finding by TEQSA that a person is not a fit and proper person is a serious determination. It could result in an application for registration being rejected or a provider’s registration being cancelled. In addition, it could also have serious consequences for an individual’s reputation and, in some cases, their employment.

Accordingly, when determining whether a person is fit and proper it is important that TEQSA give due regard to relevant considerations including a person’s:

1. compliance with the law and provision of information
2. previous conduct and management history
3. financial record.

The above matters can be considered in respect of the person (if an individual), a corporation and any of its officers (if a provider or prospective provider), including its directors, chief executive and managers, or other persons who are involved in making decisions that affect the whole, or a substantial part, of the provider’s affairs.

TEQSA affords procedural fairness to those affected by fitness and propriety requirements by affording them an opportunity to address relevant evidence and issues before making an adverse decision.

Next steps

If you have queries about TEQSA’s application of the fit and proper person requirements, please contact the TEQSA Enquiries Management team at providerenquiries@teqsa.gov.au for assistance.

Document control information

Documents

Guidance note: Changes in a course of study that may lead to accreditation as a new course  (MS Word, 149 KB)

Guidance note: Changes in a course of study that may lead to accreditation as a new course  (PDF, 227 KB)

Providers should note that Guidance Notes are intended to provide guidance only. The definitive instruments for regulatory purposes remain the TEQSA Act, the Higher Education Standards Framework, the National Code and the ESOS Act as amended from time to time.

Purpose of this note

TEQSA expects that courses of study will evolve over time as providers make improvements as part of their quality assurance processes and/or respond to changing circumstances in the educational and workplace environments. Some changes may be relatively minor, some may be more significant (i.e. changes to course title, a notable reduction in course duration, or the introduction of new majors or specialisations), while others may change the course so fundamentally that it amounts to a ‘new’ course. A ‘new’ course will need to be accredited as such, whether internally if the provider has authority to self-accredit the new course, or externally by TEQSA. In the case of accreditation by TEQSA, accreditation as a new course of study may arise as a result of:

• a provider’s own initiative to replace a previously accredited course of study with a new course of study, or
• TEQSA determining that the proposed changes to a course of study will change the course sufficiently to warrant accreditation of the course as a new course of study.

The aim of this note is to indicate some of the major factors that TEQSA may have regard to in reaching a decision on whether accreditation of a course can be renewed under its existing identity or whether it needs to be accredited as a new course of study.

Because of the variety of factors that may affect a determination by TEQSA, providers are advised to discuss proposed significant changes to a course of study with TEQSA. These discussions will help to resolve whether the proposed changes fundamentally change the nature of the course of study and/or likely expectations of it from students and the community, to the extent that TEQSA will require accreditation as a new course.

Factors that may affect TEQSA’s determination

Many factors may influence TEQSA’s decision making in particular circumstances. Some key factors that may lead to a requirement for accreditation as a new course are outlined below. Many of these are somewhat interdependent, e.g. changes to learning outcomes and course design, but for the purposes of this guidance note they are considered separately. The discussion largely follows the matters raised by the requirements of the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework).

Representation of the course of study

From time to time, providers may wish to change the orientation of a course to match new or emerging opportunities, such as innovative employment opportunities or marked changes in technologies. This may cause a provider to structure the course differently and change the title. For example, a Bachelor of Science (BSc) may be recast as a BSc (Environmental Sciences) or BSc (Emerging Technologies). Where the new title of the course is likely to suggest to prospective students that the course may lead to markedly different employment prospects or opportunities for further study, TEQSA may form the view that the course should be accredited as a new course. This could also apply to broadening or narrowing a field of education, e.g. changing a Masters of Business Administration (MBA) to a more specialised course of study, e.g. to MBA (Health Management), or vice versa. TEQSA would also consider whether the new title, if not accredited as a new course, may cause confusion with existing courses or be misleading to the community and potentially affect the reputation of Australian higher education.

Level/type of qualification

Where a change to a course is proposed to lead to a different qualification at the same AQF level, e.g. bachelor (honours) degree to a graduate diploma at Level 8, or to one at a different level, from a bachelor to a masters degree, the course will need to be accredited as a new course. This will also include postgraduate courses, e.g. masters, doctorate, that are proposed to change from coursework (or predominantly coursework) to a research degree (i.e. including at least two-thirds research work). A change to a research degree would also involve meeting the Research and Research Training Standards (Domain 4 of the Threshold Standards) if that has not already occurred.

Where a provider that offers a diploma accredited as a vocational education and training (VET) course proposes to convert this to a higher education course, or to offer a higher education diploma with the same title and content, the higher education diploma will need to be accredited as a new course. Higher education providers should have regard in such cases to the over-riding requirement to deliver teaching and learning that engage with advanced knowledge and inquiry (Threshold Standards Category Criterion B1.1).

Learning outcomes

TEQSA expects the learning outcomes of courses to evolve with time, and such evolution is unlikely to have an impact on re-accreditation of a course. However, from time to time, marked changes may occur in expected learning outcomes, e.g. to provide training for a different (broadened or specialised) scope of professional practice, such as a new major or course solely addressing forensic accounting instead of management accounting. In such cases TEQSA will consider accreditation as a new course in the interests of clarification and avoidance of confusion about what can be expected of graduates. Providers may well also see this as advantageous in proposing a new field of study.

Course duration/volume of learning

A marked change in the duration of a course of study or the volume of learning may lead to a need for accreditation as a new course. This may occur particularly if:

• there has been a marked reduction in the volume of learning without other corresponding changes to other factors, and/or
• a marked and unsubstantiated departure from the broad guidance of the AQF is proposed.

A marked change in volume of learning would be expected to be accompanied by various other changes, such as changes to the:

• level or qualification type
• scope of the expected learning outcomes
• prerequisites or other aspects of academic preparedness
• course design, or
• delivery methods.

If these types of accompanying changes have not occurred, TEQSA would be concerned about the credibility of the proposed changes to the volume of learning. Where accompanying changes are being proposed to support a change in volume of learning, TEQSA will form a view on whether, in aggregate, they change the fundamental nature of the course to the extent that it amounts to a ‘new’ course.  

Entry requirements

Changes to entry requirements may cause TEQSA to see the changes as a new course. This would occur where the changed entry requirements are likely to change the consequent type and level of learning experiences that flow from the change, e.g. a change from undergraduate entry to graduate entry, or new and substantial requirements for prerequisite professional or workplace experience that is expected to be advanced in the course of study. Changes in entry requirements that may require additional support, e.g. admitting an educationally disadvantaged cohort, but do not otherwise change the fundamental nature of the course or its outcomes, are less likely to require accreditation as a new course. 

Course design/delivery

Providers are expected to change the design and delivery of courses over time as part of their internal monitoring and quality assurance. TEQSA will consider such changes as part of re-accreditation of a course of study. Provided that the changes do not markedly change the expected outcomes of the course for students or the community, TEQSA is unlikely to require accreditation as a new course of study. For example, progression to more emphasis on online learning is likely to be seen as part of a natural evolution in a provider’s educational management, provided the changes are accompanied by corresponding relevant changes to the provider’s monitoring and quality assurance. Adopting a solely online mode of delivery would be a material change, but not necessarily change the course to such an extent that it would require accreditation as a new course.

However, where the design and delivery of a course is changed fundamentally and such changes to its design and delivery are claimed to engender markedly different graduate capabilities and/or a capacity to meet new community expectations, TEQSA may form the view that accreditation as a new course of study is warranted. For example, if a provider introduced an unprecedented predominance of ‘best practice’ work-integrated learning, TEQSA may form the view that the interests of all parties may be better served by accreditation as a new course.  

Research and research training

As mentioned above, offering a research degree(s) requires a provider to meet the standards of the Threshold Standards for both research and research training. Changes to a course of study that are intended to convert it to a research degree will require accreditation as a new course of study.

Institutional quality assurance

If a provider proposes changes to a course of study that would require capabilities that have not been demonstrated previously, TEQSA will need to consider accreditation as a new course. For example, a provider may wish to incorporate new fields of education into a course for which it has not previously demonstrated a capacity for sufficient academic leadership, staff expertise, learning resources or dedicated expertise in institutional quality assurance (e.g. in the academic board or equivalent) in that field to meet the requirements of the Threshold Standards prima facie. As discussed above, this would apply to new research degrees but it would apply in any area where the provider is proposing significant involvement in new fields of education or markedly different modes of delivery, e.g. adding significant STEM content to a humanities program.

Delivery partners

The Threshold Standards set out specific requirements in relation to delivery with other parties. A proposal for a new delivery partner would require consideration by TEQSA at least as a material change, and, depending on the nature of the delivery arrangement and its likely impact on the design of course of study, may lead to accreditation as a new course. So too may a change of delivery partner, however TEQSA would take into account the provider’s previous record of managing and quality assuring delivery partners.

International students

Providers may propose changes to a previously accredited course to meet the needs of one or more cohorts of international students (whether onshore or offshore). TEQSA will have regard to the matters discussed elsewhere in this guidance note in considering whether the course amounts to a ‘new’ course and warrants accreditation as such. TEQSA will also have regard to any potential impact on the reputation of Australian higher education. 

Resources and references

Material changes and other notifications

TEQSA welcomes the diversity of educational delivery across the sector and acknowledges that its Guidance Notes may not encompass all of the circumstances seen in the sector. TEQSA also recognises that the requirements of the Threshold Standards can be met in different ways according to the circumstances of the provider. Provided the requirements of the Threshold Standards are met, TEQSA will not prescribe how they are met. If in doubt, please consult your TEQSA assessment manager.