TEQSA’s guidance notes are concise documents designed to provide high-level, principles-based guidance on interpretation and application of specific standards of the Higher Education Standards Framework (Threshold Standards) 2021. They also draw attention to other interrelated standards and highlight potential risks to compliance. They do not introduce prescriptive obligations.
 

The definitive instruments that set out providers’ obligations in delivering higher education remain the Threshold Standards (as written by the Higher Education Standards Panel) and the TEQSA Act.
 

In early 2024, TEQSA consulted stakeholders with a draft version of the guidance note about learning resources and education support, and considered all feedback.
 

This guidance note was finalised on 11 June 2025.
 

The purpose and intent of the guidance note about learning resources and education support is to support providers to assure themselves that their learning resources are appropriately accessible to all students and related to learning outcomes, and that learning support services meet the needs of student cohorts.
 

• Full list of guidance notes

1. What do learning resources and educational support encompass?

In the context of the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards), learning resources and educational support refer to the academic resources made available for a course of study and the support a provider offers students to develop students’ capacity for independent learning and inquiry.

The primary obligations related to learning resources and educational support are found in section 3.3 of the Threshold Standards.

Facilities and resources of a more general nature that do not form part of a particular course of study are covered in other parts of the Threshold Standards:

• Facilities and Infrastructure (section 2.1)
• Wellbeing and Safety (section 2.3)
• Staffing (section 3.2).

Learning resources and educational support relating to research and research training fall within section 4.2 of the Threshold Standards and are not considered as part of this guidance note (See Guidance note: Research and research training).

Learning resources

The Threshold Standards require a provider to ensure students:

• have access to up-to-date learning resources, which are directly relevant to their course of study
• receive timely training and support to access and use student learning management systems (more information about obligations regarding student learning management systems is available in the Facilities and Infrastructure Guidance note)
• are not subjected to unexpected barriers, such as the cost of technological requirements to access required resources.

When assessing learning resources, TEQSA will consider:

• the educational materials
• their availability
• their accessibility
• their quality.

The Threshold Standards do not dictate or specify a required form for learning resources. Examples of learning resources include physical books, journals, videos, websites, podcasts, or online databases. Regardless of the form a learning resource takes, a provider must ensure the resources are:

• available in forms that are accessible to all students, including those with disability, regardless of the mode of study (e.g. online only)
• appropriate for the level of qualification under the Australian Qualifications Framework (AQF)
• relevant and up to date.

The Threshold Standards do not explicitly state a provider needs to have a physical library and physical learning materials. However, there is an expectation on providers to ensure students can readily access materials and resources referred to in their course of study.¹ TEQSA will not accept a model where a provider makes no learning resources available and refers its students to a public library, or similar.

When assessing the quality of learning resources, TEQSA may engage the assistance of an external subject matter expert. Information regarding learning resources will need to be sufficiently detailed for the expert to form a view on their quality and appropriateness for the course of study.

If a provider elects for its learning resources to be managed by an external third party, it must be able to demonstrate:²

• the arrangement with the other party is part of a formal agreement
• delivering the resources in this way is practical for students and does not create unreasonable barriers to access.

Educational support

In general, TEQSA will expect providers to give students the educational support necessary to allow them to develop their capacity for independent learning and inquiry.

TEQSA will expect providers to:

• have educational support services available to its students consistent with their course of study
• have qualified staff that can help students locate the information they need
• give training to students on how to locate and use resources relevant to their course of study
• provide timely feedback regarding student assessment
• have support services for students who are at risk (or potentially at risk) of not making progress with their studies
• regularly communicate with students about how to access resources and support services.

Under Standard 3.3.4 of the Threshold Standards, providers are also required to provide students with more general support services to:

• develop study skills
• develop English language proficiency
• assist in their transition to living in Australia.

2. What TEQSA will look for

TEQSA considers relevant standards from the Threshold Standards in the context of learning resources and educational support, among which most notably are:

Obligations applying to providers of education to overseas students

Where it applies to a provider, TEQSA considers the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) and the Education Services for Overseas Students Act 2000 (ESOS Act).

Sections of the National Code relevant to learning resources and educational support are:

2.1.5 – before accepting a prospective student for enrolment, a provider must make information about campus locations, facilities and learning resources available in plain English

6.1 – a provider must support overseas students adjusting to study and life in Australia by providing information and culturally appropriate orientation on:

• 6.1.2 – English language and study assistance programs
• 6.1.5 – its facilities and resources
• 6.1.8 – support services available to assist students with general or personal circumstances adversely affecting their education in Australia

6.3 – a provider must give reasonable support to overseas students to enable them to achieve expected learning outcomes regardless of place or mode of study, at no additional cost to the student

6.4 – a provider must facilitate access to learning support services consistent with the requirements of the course, mode of study and learning needs of the student

8.22 – a provider must take all reasonable steps to support overseas students who may be disadvantaged while engaging in distance or online learning.

Obligations applying to providers receiving financial support from the Commonwealth

Providers subject to the Higher Education Support Act 2003 (HESA) may have additional obligations regarding learning resources and educational support.

The HESA sets out, amongst other things, the parameters of what a provider can charge students for the services it provides. Providers subject to the HESA must not charge students for learning resources and educational support, where doing so would be contrary to the HESA.

As an example, section 36-45 of the HESA places limits on the amount a provider can request a student to contribute.

From 1 January 2024, providers are required to comply with the Higher Education Support Amendment (Response to the Australian Universities Accord Interim Report) Act 2023. The Department of Education is responsible for compliance with these requirements.

• Under the requirements, providers will be expected to document, publish and implement a support for students policy. The policy requirements apply to providers approved under HESA.

3. Identified issues

TEQSA has identified several issues which may indicate risks to students and non-compliance with obligations related to learning resources and educational support. These include, but are not limited to:

Communicating key information

• students not being made aware of the cost of resources required for a course before accepting an offer
• students not being made aware of how to access information and resources relevant to their course of study
• students not being made aware of inherent requirements or special requirements relevant to their course of study prior to accepting an offer and enrolling, resulting in a student not achieving learning outcomes
• students missing orientation and not receiving the information from orientation later, for example PhD students who often commence their courses at irregular times.

Quality of learning resources and support

• using poor quality resources in a course of study (e.g. irrelevant, obsolete, non-authoritative material) including outdated versions of textbooks in its library
• students not receiving timely and/or sufficient feedback on assessments. This may lead to students being unaware they are at academic risk until too late in the study period to take corrective action
• inadequate monitoring of at-risk student cohorts, leading to a failure to identify opportunities to provide educational support
• failure to identify opportunities for the continuing improvement of learning resources and educational support services.

Accessing resources

• students facing barriers to accessing resources such as:
  • being required to use uncommon or unreasonably costly software
  • having limited access to science or computer labs that are only open during regular working hours
  • limited access to teaching staff
  • access to online resources requires impractically high internet speeds
  • online students being unable to access resources that are only available onsite
  • students with a disability being unable to access learning materials because they are not in an accessible form.

Related resources

• Guidance note: Facilities and infrastructure
• Guidance note: Wellbeing and safety
• Guidance note: Diversity and equity
• Guidance note: Research and research training
• Higher Education Support Act 2003
• New requirements to support students (Department of Education, Australian Government)
• Higher Education Provider Guidelines (Department of Education, Australian Government)

Notes

1. This is separate to supplemental material such as suggested reading, which a student may decide to acquire on their own initiative.
2. See also, Guidance note: Delivery with other parties.

Document information

Purpose

The purpose of this policy is to establish a set of principles to inform TEQSA’s treatment of providers identified as high risk in relation to students or financial position—at the point of identification, and also in the course of accreditation, re-accreditation and re-registration assessments. It elaborates upon and further specifies the principle, published in TEQSA’s Risk Assessment Framework, that TEQSA may take various forms of action in relation to providers being identified as high risk. The principles that comprise this policy are intended to ensure that identified provider risk-levels drive differential treatment of providers, in line with established good practice in risk-based regulation, and consistent with the basic principles for regulation included in TEQSA’s establishing legislation.

Scope

This policy relates to providers identified as high risk through TEQSA’s annual risk assessment process. It does not relate to providers identified as low or moderate risk. Although the policy may to some extent describe TEQSA’s treatment of providers not identified as high risk, this is intended only to enhance clarity through contrast.

Principles

In-cycle monitoring

1. Where a provider is identified as high risk, the following activities are immediately triggered:
   
   1. a request for information to enable greater differentiation of risk type and extent, with the information requested to be determined on the basis of identified risk factors and other information available to TEQSA
   2. analysis of existing data, supplemented by additional information requested of high risk providers, to more precisely identify any potential areas of concern with the provider
   3. formulation of an action plan that will include consideration of the full range of available and appropriate regulatory options, including in relation to CRICOS applications, consistent with the principles for regulation described in the TEQSA Act
   4. TEQSA will provide advice to the relevant Australian Government department and portfolio Minister to support decision making under the Higher Education Support Act 2003.

Cyclical renewal of accreditation and renewal of registration assessments, and new accreditation assessments

2. In general, TEQSA differentiates the scope (of Threshold Standards tested), and the depth (of evidence required) of accreditation- and registration-related assessments on the basis of assessed risk.
3. For a provider that is not identified as high risk, an assessment will focus on a subset of standards and associated evidentiary requirements considered applicable to each case, and will expand this subset to cover areas of concern as appropriate to each case on the basis of available evidence.
4. Where a provider is identified as presenting a high risk to financial position, in registration- and accreditation-related assessments subsequent to the risk assessment, the starting point for the scope of assessment will include all financial- and resourcing-related standards, any standards related to planning and mitigation in case a provider ceases to operate, and any other standards that may be identified as relevant to the particular case given the financial risks identified, with this scope potentially reduced as appropriate in the context of the particular assessment.
5. Where a provider is identified as presenting a high risk to students, in registration- and accreditation-related assessments subsequent to the risk assessment, the baseline scope and evidence assumption will be reversed so that the starting point includes all standards appropriate to the application type, with standards subsequently excluded where not relevant to the provider or case in question, or where an assessment has recently determined the provider’s compliance, or otherwise where appropriate in the context of the particular assessment.

Contact

Any enquiries about TEQSA’s approach to high-risk providers can be directed to: providerenquiries@teqsa.gov.au.

Purpose

The purpose of this policy is to describe the Tertiary Education Quality and Standards Agency’s (TEQSA’s) approach in responding to a change of control or ownership of a higher education provider (HEP), and describe the reasons for its interest following such an event. 

A change of control or ownership occurs when a new entity obtains substantial ownership of a registered HEP (whether or not that is a majority stake in a provider). A change in control or ownership of a HEP has the potential to significantly impact a provider’s ability to meet the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework), noting the effect that a change in control or ownership can have on a provider’s governance arrangements and management. 

TEQSA’s interest following a change in control or ownership of a HEP will focus primarily on potential risks to the quality of students’ educational experience, and a provider’s financial viability and sustainability. Examples of events that impact students following a change in control or ownership that would concern TEQSA, while not exhaustive, include:

• a rapid increase in student enrolments in the absence of a planned and managed approach, particularly where there is reliance on growth in single source markets
• course closures in the absence of adequate teach out arrangements
• reductions in staffing (academic and support services) to lower expenses
• reductions in investment in facilities and infrastructure and the financial capacity of the HEP
• reductions in the quality of the learning environment through for example, reductions in senior academic leaders, increases in student to staff ratios, increased rates of academic staff casualisation, or an overreliance on third party teaching/delivery arrangements. 

Scope

This policy relates to providers that have been subject to a change of control or ownership in recent history. 

Principles

1. Before a change of ownership or control of a registered HEP event takes place , TEQSA expects to be provided with notification in accordance with section 29(1)(a) of the TEQSA Act (for further detail, refer to TEQSA’s Material Change Notification Policy). It is not necessary for an acquirer to take a majority ownership stake (i.e. greater than 50 per cent) in a provider in order to exercise effective control.
2. TEQSA’s approach in responding to a change in control or ownership of a HEP will be guided by its regulatory principles of reflecting risk, proportionality and necessity. TEQSA’s investigations and regulatory intervention will be focussed on key risks arising from the change of control or ownership to the quality of students’ educational experience, and the provider’s financial viability and sustainability.
3. Where there is a change of control or ownership of a HEP, TEQSA will seek early engagement with the affected provider (and its new owners). The objective of this engagement is to ensure that the provider can continue to meet the requirements of the HES Framework, to address any concerns TEQSA holds with aspects of the provider’s operations under its previous control and to confirm the future strategic directions of the HEP.
4. At a minimum, HEPs should expect that TEQSA will request documentation on the nature of the transaction, run a background check on any new shareholders and/or directors, and consider the history of prior tertiary education provision by the acquiring entity or its personnel. TEQSA may also request details of changes to key personnel, governance committees, financial statements, and fit and proper person declarations. Examples of sources TEQSA may refer to in its background checks include Australian Securities and Investments Commission’s (ASIC) current and historical company exacts, Equifax’s corporate scorecards and company/director credit reports, and the Australian Financial Security Authority’s National Personal Insolvency Index.
5. HEPs should also be aware that a change of control or ownership may trigger a compliance assessment if appropriate in the circumstances. A compliance assessment can be initiated at any time before or after the change of control or ownership has taken place.
6. If TEQSA’s concerns are not resolved by the provider’s response, TEQSA can take other regulatory steps to mitigate the risk that the provider will not meet the HESF. This includes placing conditions on courses and/or registration, or in serious cases shortening or cancelling a provider’s registration.
7. TEQSA recognises that it is part of a broader regulatory community and will work with other relevant Commonwealth and/or State and Territory agencies to acquire and share regulatory information, for intelligence purposes and to minimise regulatory burden on providers where they have already submitted information to other agencies. 

Further information

Further information about TEQSA’s approach following a change in provider control can be obtained by directing an email enquiry to: providerenquiries@teqsa.gov.au.