• Preparing a CRICOS renewal application (Stage 1)

    Stage 1: the provider prepares a CRICOS renewal application

    Legislative requirements

    Your application should demonstrate that your governing body is assured of your institution’s current, and continuing, compliance with the requirements of the:

    Evidence requirements

    TEQSA has revised its approach to the evidence required for applications to renew CRICOS registration. We have done this to reduce the volume and scope of evidence required to demonstrate compliance with the National Code.

    Applications to renew CRICOS registration should include the following evidence:

    1. A self-assurance report
    		 Outlining how the governing body manages key sector risks, how it assures itself of the quality of its higher education operations and that it is compliant with the National Code.
    1. An index of supporting evidence
    		 Referenced throughout the report.
    1. An independent external audit report or additional supporting evidence

    The report of a recently conducted independent external audit of the effectiveness of the provider’s internal mechanisms for self-assurance and compliance with the National Code (including planned and completed actions arising from these reviews).
     

    Or, if the provider does not have self-accrediting authority, and chooses not to provide a recently commissioned independent external audit, additional supporting evidence.
    1. For providers with a Foundation Program – an additional self-assurance report
    		 Focused on the requirements for renewing a Foundation Program.
    1. For providers with an ELICOS course – an additional self-assurance report
    		 Focused on the requirements for renewing an ELICOS course.
    1. For providers with an under 17 exemption – additional supporting evidence
    		 Satisfying the requirements to renew exemptions to enrol students under the age of 17 in Foundation Programs.

    CRICOS registration renewal: Self-assurance report

    A self-assurance report provides an opportunity to demonstrate the effectiveness of your self-assurance mechanisms.

    The self-assurance report for applying to renew CRICOS registration should be a maximum of 10 pages. It should outline how your governing body assures itself of the quality of your education operations, and your current and continued compliance with the requirements of the ESOS Act, the National Code 2018, and where relevant, the ELICOS Standards, and the Foundation Program Standards.

    When applying to renew CRICOS registration, your self-assurance report should include:

    1. Evidence of how risks have been identified, managed and mitigated, and how your institution will manage these risks going forward (including areas for continuous improvement and any associated actions and measures which are in place to monitor success).
    2. Demonstration of how you manage key sector risks in the following areas:
    Student recruitment and admission

    TEQSA recommends considering our:
    Student participation, support and experience

    TEQSA recommends considering:
    Student attainment

    TEQSA recommends considering:
    1. Where applicable, the findings, actions (planned and completed) and outcomes of at least one external audit. This audit should have been undertaken, by a suitably qualified discipline expert, no more than 18 months before applying to renew CRICOS registration. A copy of the audit should be included, as an attachment, to the self-assurance report.
    2. The findings, actions and outcomes of the most recent review report on recruitment performance, including the performance of agents (e.g. student numbers enrolled and succeeded, meetings with agents and terminations of agents). The following attachments should be included with the self-assurance report:
      • policies and procedures regarding recruitment and management of agents
      • an example of a written agreement between your institution and an education agent.
    3. A copy of an example agreement used where third-party providers are engaged to provide welfare and/or accommodation arrangements to students under the age of 18.
    4. Evidence of a culturally and age-appropriate orientation program, including the presentation used for overseas students.
    5. Details of any third-party arrangements for the delivery of a course or courses to overseas students.

    Note: All claims made in the self-assurance report must be substantiated by evidence, with reference to specific supporting documents in-text. 
     

    Where possible, supporting evidence should be directly accessible via in-text hyperlinks, included as attachments to the report, or listed in the index and available for later submission on request.

    Index of supporting evidence

    Your application should include an index of all supporting evidence referenced in the self-assurance report. At a minimum, the index should include:

    Items to be listed with hyperlinks to their location on your website
    • Policies and procedures regarding:
      • marketing and recruitment
      • credit and recognition of prior learning (RPL)
      • admission
      • assessment of English language proficiency
      • fee refunds
      • students under the age of 18
      • critical incidents
      • student support
      • orientation
      • staff development
      • health and safety
      • overseas student transfers
      • monitoring, recording and assessing course progress, including intervention strategies for students at risk
      • monitoring and recording attendance (where applicable)
      • assessing, approving and recording deferment, suspension and cancellation
      • complaints and appeals.
    • Current marketing and promotional material for current and prospective students, including sample course brochures and promotional material published on social media
    • Overseas student handbooks
    • A current list of education agents engaged to formally represent the provider
    • Samples of information given to students under the age of 18 outlining emergency contacts and how to seek assistance and report on incidents of actual or alleged sexual, physical or other abuse.
    Items may be listed without hyperlinks and TEQSA may request copies of these items at any time
    • Details of marketing materials provided to agents
    • A register of students granted credit within the last 24 months
    • An example of a Letter of Offer and a written agreement between your institution and a student for a course of study
    • Details of any training and development programs provided to agents
    • Evidence demonstrating that the suitability of accommodation for students under the age of 18 has been verified, prior to the accommodation being approved and at least every 6 months thereafter
    • Policies and procedures for selecting, screening and monitoring any third parties your institution has engaged to organise and assess welfare and accommodation arrangements (where applicable)
    • Evidence of compliance with Commonwealth, state and territory legislation, or other regulations regarding child welfare and protection requirements
    • A copy of the Working with Children Check register
    • A copy of the critical incident register, or other written record, for at least the last 2 years
    • Details of ESOS training and ongoing professional development undertaken by staff
    • A description of student services for overseas students, including:
      • legal services
      • emergency and health services
      • academic and English language student support
      • welfare support services
      • other student support services.
    • Examples of correspondence sent by your institution to overseas students when you:
      • intend to refuse a transfer request
      • intend to report the student for unsatisfactory course progress or attendance
      • are notifying the intention to suspend or cancel the student’s enrolment
      • are notifying that a deferral, suspension or cancellation has taken place
      • are notifying the outcome of an internal appeal process for both favourable and adverse decisions.
    • A report of all decisions to defer, suspend or cancel the enrolment of overseas students in the preceding 12 months, with a description of reasons and outcomes
    • A report of all student complaints and appeals received in the preceding 12 months, with evidence of processes implemented and a description of outcomes and actions taken
    • Evidence of quality assurance and monitoring arrangements between your institution and any third party engaged for the delivery of a course
    • An outline of changes to current third-party arrangements for course delivery and a copy of the amended contract if, since being approved by TEQSA, any of the following areas have been impacted:
      • roles and responsibilities of each party
      • delivery site location
      • duration of contract length.
    • A report of all refund requests and outcomes from the previous 12 months, with evidence that refunds provided were reported in PRISMS within the required timeframe (where applicable)
    • Where relevant, evidence your institution is meeting its obligation to maintain the ‘Protected Amount’ (all pre-paid tuition fees must be held in a designated bank account which is separate to day-to-day operating expense accounts)
    • A copy of relevant policies and procedural documents that ensure your institution has robust mechanisms for maintaining the Protected Amount.

    Independent external audit

    Standard 11.4 of the National Code requires providers who are self-accrediting to undertake an independent external audit within 18 months of their registration’s expiry.

    TEQSA strongly encourages all providers (including those who do not have self-accrediting authority) to undertake an independent external audit of their compliance with the ESOS Framework in the second half of their registration period.

    An independent audit is an opportunity for your institution to have a person, or persons, with significant expertise evaluate the effectiveness of your internal mechanisms for self-assurance, to ensure they align with contemporary practice and support continuous improvement.  TEQSA’s ability to efficiently assess your application to renew your CRICOS registration is greatly assisted by a high-quality independent audit report.

    If your institution does not have self-accrediting authority, and you do not submit a recently conducted independent external audit report with your application, you will need to provide additional supporting evidence (see the guidance on preparing additional supporting evidence below).

    A guide for providers undertaking an independent external audit is available. The audit report should be accompanied by your institution’s response, including any completed or in-progress actions which look to address issues the report identified and when they have been, or will be, undertaken.

    Additional supporting evidence

    If your institution does not have self-accrediting authority, and you do not submit a recently conducted independent external audit report, you are required to submit the following items with your application:

    • examples of credit and recognition of prior learning (RPL) decisions, with copies of relevant records and correspondence
    • examples of admissions with copies of relevant records and correspondence, capturing a variety of student cohorts, for example:
      • recruited onshore
      • recruited offshore
      • recruited via a pathway
      • recruited via an agent
      • recruited without an agent
      • admitted with academic qualifications
      • admitted with professional qualifications
      • admitted with prior study at an Australian provider
      • admitted with English language proficiency
      • admitted with an English language waiver.
    • examples of assessment of English language proficiency, with copies of relevant records and correspondence
    • examples of care arrangements for students under the age of 18 and their monitoring, with copies of relevant records and correspondence
    • examples of intervention strategies for managing students at risk and the outcomes of these, with copies of relevant records and correspondence
    • examples of deferments, suspensions and cancellations, with copies of relevant records and correspondence
    • examples of complaints and appeals by students and the outcomes of these, with copies of relevant records and correspondence
    • evidence demonstrating that the suitability of accommodation for students under the age of 18 has been verified before the accommodation was approved and at least every 6 months after its approval
    • policies and procedures for selecting, screening and monitoring any third-parties engaged by the provider to organise and assess welfare and accommodation arrangements (if applicable)
    • a copy of the Working with Children Check register
    • a copy of the critical incident register, or other written record, for at least the last 2 years
    • a description of student services for overseas students, including:
      • legal services
      • emergency and health services
      • academic and English language student support
      • welfare support services
      • other student support services.
    • evidence of quality assurance and monitoring arrangements between the provider and any third-party engaged for the delivery of a course
    • an outline of changes to current third-party arrangements for course delivery and a copy of the amended contract if, since being approved by TEQSA, any of the following areas have been impacted:
      • roles and responsibilities of each party
      • delivery site location
      • duration of contract length.
    • a report of all refund requests and outcomes from the previous 12 months, with evidence that refunds provided were reported in PRISMS within the required timeframe (where applicable)
    • where relevant, evidence that the provider is meeting its obligation to maintain the ‘Protected Amount’ (all pre-paid tuition fees must be held in a designated bank account which is separate to day-to-day operating expense accounts)
    • a copy of relevant policies and procedural documents that ensure that the provider has robust mechanisms for maintaining the Protected Amount.

    Foundation Program renewal

    TEQSA requires CRICOS-registered providers who deliver Foundation Programs to apply for re-accreditation of their Foundation Program(s) at the same time they apply to renew their CRICOS registration. For these providers, the application to renew Foundation Program(s) is integrated into the application to renew CRICOS registration.

    These providers will submit an additional self-assurance report as part of their CRICOS renewal focused on the Foundation Program requirements.

    In instances where a Foundation Program has been added within 2 years of applying to renew CRICOS registration, the provider may limit their Foundation Program renewal application to: a self-assurance report; and, an index of supporting evidence (focused on the Foundation Program requirements), omitting any other attachments.

    ELICOS renewal

    TEQSA requires CRICOS-registered providers who deliver ELICOS courses to apply for re-accreditation of their ELICOS course(s) at the same time they apply to renew their CRICOS registration. For these providers, the application to renew ELICOS course(s) is integrated into the application to renew CRICOS registration.

    These providers will submit an additional self-assurance report as part of their CRICOS renewal, focused on the ELICOS course requirements.

    In instances where an ELICOS course has been added within 2 years of applying to renew CRICOS registration, the provider may limit their ELICOS renewal application to: a self-assurance report; and, an index of supporting evidence (focused on the ELICOS requirements), omitting any other attachments.

    Under 17 exemption renewal

    TEQSA requires providers who have existing exemptions to enrol students under the age of 17 in Foundation Programs, to apply to renew their exemption when they apply to renew their CRICOS registration.

    To renew exemptions to enrol students under the age of 17 in Foundation Programs, you will need to submit the following evidence as an appendix to your CRICOS renewal application:

    • policies and procedures which are in place to manage the provision of welfare arrangements for students under the age of 17, including critical incident policies and procedures
    • details of appropriate arrangements which are in place for student accommodation and wellbeing, including evidence demonstrating that the suitability of accommodation for students under the age of 17 was verified before the accommodation was approved and at least every 6 months after its approval
    • an example of any agreements with third-party providers who have been engaged to provide welfare and/or accommodation arrangements to students under the age of 17
    • policies and procedures for selecting, screening and monitoring any third party your institution has engaged to organise and assess welfare and accommodation arrangements (if applicable)
    • details of appropriate arrangements which are in place for the orientation of students that are under the age of 17, including samples of information given to them relating to emergency contacts and how to seek assistance and report on incidents of actual or alleged sexual, physical or other abuse
    • evidence of appropriate arrangements which are in place for academic progress review of students that are under the age of 17
    • evidence of compliance with Commonwealth, state and territory legislation, or other regulations, regarding child welfare and protection requirements
    • a copy of the Working with Children Check register
    • evidence staff receive training in child protection principles, as part of the staff induction process.
    Last updated:

    Related links

  • Guidance note: Academic monitoring, review and improvement

    Body

    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 amended on advice from the Higher Education Standards Panel to the Minister for Education from time to time) and the TEQSA Act.
     

    In August 2023, TEQSA consulted stakeholders with a draft version of the Academic Monitoring, Review and Improvement guidance note, and considered all feedback.
     

    This guidance note was finalised on 19 March 2024.
     

    The purpose and intent of the guidance note about academic monitoring, review and improvement is to support providers by encompassing key elements of institutional quality assurance.
     

    1. What does monitoring, review and improvement encompass?

    In the context of the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards) monitoring, review and improvement are key elements of institutional quality assurance.

    The Threshold Standards provide that all higher education providers (providers) carry out ongoing monitoring and review to improve their operations, and that providers comprehensively review all their registered courses of study (courses) at least every 7 years. For each course of study, a comprehensive review should encompass:

    • design and content
    • expected learning outcomes – their methods of assessment and student achievement
    • emerging developments in the relevant field of education
    • mode of delivery
    • changing needs of students
    • identified risks to quality
    • trend analyses over a range of factors (e.g. completion rates) for different student cohorts and subgroups. 

    Alongside student feedback, such continuous monitoring and reviews should also inform ongoing improvement activities. As the Explanatory Statement of the Threshold Standards notes, the purpose of monitoring and review is “to maintain and enhance [the] quality and effectiveness” of the provider’s educational offerings.1

    To ensure a provider’s improvement cycle both maintains and enhances its offerings, the Threshold Standards place 2 quality assurance conditions upon comprehensive reviews.

    The first condition is that comprehensive reviews involve benchmarking activities such as external referencing. Although the Threshold Standards do not define ‘external referencing’, TEQSA understands this term to describe activities wherein a provider assesses an aspect of their operations against an external comparator. Examples of external referencing include, but are not limited to:

    • peer review
    • moderation of courses
    • course accreditation by professional bodies
    • engagement with and feedback from industry groups
    • comparisons with identified good practices in the sector
    • comparisons grounded in publicly available information or market intelligence
    • comparisons developed through collaboration with other providers, peak bodies, employers, or industry.

    The second condition placed upon comprehensive reviews is that they are overseen by peak academic governance processes. Such oversight aims to ensure a provider’s monitoring, review and improvement activities are not ad hoc but instead reflect a systematic approach to quality assurance.

    At the same time, oversight by academic processes should also serve to ensure the systematic approach a provider adopts to monitoring, review and improvement is appropriate to the specific character of the provider. For example, the Threshold Standards describe more developed processes of review, monitoring, and improvement for providers granted self-accrediting status, and for those who seek to enter ‘higher’ provider categories. But across any such variations, TEQSA holds all providers to a common expectation of being able to demonstrate an understanding of how their own monitoring, review and improvement operations provide an appropriate form of ongoing and systematic quality assurance.

    2. What TEQSA will look for

    TEQSA considers relevant standards from the Threshold Standards in the context of academic monitoring, review and improvement, among which most notably are:

    Threshold Standards (2021) Part A Key considerations

    1.3.3 Orientation and Progression 
     

    2.2.3 Diversity and Equity 
     

    4.2.1(c) Research Training 
     

    5.4 Delivery with Other Parties 
     

    7.1.4 Representation
     

    The provider monitors:

    • student progress within or between units and in research training
    • trends in rates of retention, progression and completion of student cohorts through courses of study
    • participation, progress and completion of identified subgroups through courses of study
    • its arrangements for delivery of education with other parties and the other parties’ performance
    • the performance of agents and other parties representing the provider

    1.4 Learning Outcomes and Assessment 
     

    3.1.5 Course Design 
     

    5.3.1–5.3.4 Monitoring, Review and Improvement 
     

    7.3.3 Information Management
    • at least every 7 years, all accredited courses of study are subject to a comprehensive review covering:
      • course design and content
      • expected learning outcomes
      • methods of assessment
      • student achievement of learning outcomes
      • emerging developments in the field of education
      • modes of delivery
      • changing needs of students
      • identified risks to quality.
    • comprehensive reviews are overseen by academic governance processes
    • comprehensive reviews and improvement activities draw upon external referencing of student cohort success
    • learning outcomes for each course of study are informed by national and international comparators
    • courses of study are professionally accredited by a relevant professional body where accreditation is required for graduates to practice
    • student data is securely and confidentially maintained.

    1.3.5 Orientation and Progression 
     

    2.2.3 Diversity and Equity 
     

    5.3.7 Monitoring, Review and Improvement
    • improvement activities draw upon regular interim monitoring and review, comprehensive reviews, external referencing  and student feedback
    • improvement activities aim to mitigate future quality risks, and use data about student progress to improve admissions criteria, course design, teaching, supervision, learning and academic support. 
    5.3.5 and 5.3.6 Monitoring, Review and Improvement
    • students have regular opportunities to provide feedback, and have membership on governing bodies
    • teachers and supervisors have opportunities to review feedback about their teaching and research supervision.

    6.1.3(d) and 6.2.1(f) Corporate Governance 
     

    6.3.1(b), 6.3.1(d), and 6.3.2 Academic Governance 
     

    6.2.1(f–k) Corporate Monitoring and Accountability 
     
    • competent academic governance processes have been implemented and operate according to an institutional academic governance policy framework
    • academic governance processes provide:
      • effective academic oversight of teaching, learning, research and research training quality
      • institutional benchmark setting and monitoring for academic quality
      • advice to management and the corporate board on academic matters.
    • effective academic oversight of quality is secured through:
      • continuous monitoring, review and improvement of academic policies and, academic and research activity
      • monitoring of potential risks
      • the evaluation of monitoring, review, and improvement processes.
    • there are periodic independent reviews (at least every 7 years) of the effectiveness of the governing body and academic governance processes.  
    Threshold Standards (2021) Part B Key considerations

    B1.2.2, B1.2.5, and B1.2.7–B1.2.9 ‘University College’ Category 
     

    B1.3.2, B1.3.8, B1.3.10, B1.3.12 ‘Australian University’ category 
    • providers registered in either the ‘University College’ or ‘Australian University’ category demonstrate a mature level of development and a track record of compliance regarding:
      • mature and advanced processes for the monitoring, review, quality assurance and improvement of courses of study, and the maintenance of academic integrity
      • identifying, implementing, and sharing good practices in teaching and learning
      • having a sufficient depth of academic leadership and academic expertise to guide teaching, learning and academic governance
      • engagement with employers, industry, or the professions to inform the development, review and improvement of educational offerings.
    B2 Criteria for Seeking Self-Accrediting Authority
    • providers seeking partial self-accrediting authority (SAA) have completed at least one review and improvement cycle, demonstrated successful implementation of evidence-based improvements grounded in monitoring and review, and established effective review and improvement activities across all courses of study
    • providers seeking full SAA also demonstrate, across at least 3 (2-digit) fields of education, mature and advanced processes for:
      • design, delivery, accreditation, quality assurance, monitoring, review and improvement of courses of study
      • the maintenance of academic integrity.

    Obligations applying to providers of education to overseas students in Australia

    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).

    The sections of the National Code relevant to monitoring, review and improvement are 4.1, 4.2.3, 8.1, 8.3, 8.6 – 8.8.

    Sections 4.1 and 4.2.3 require providers engaging an education agent to enter into a written agreement that outline processes for monitoring the agent’s activities, particularly regarding whether the agent is giving students accurate information on the provider’s offerings. The agreement should also include corrective action to be taken if it is determined that the agent is not complying with the terms of the agreement.

    Sections 8.1 and 8.3 require providers to monitor student’s attendance and progress to ensure they are on track to complete their studies in the duration specified by their Certificate of Enrolment. Sections 8.6, 8.7 and 8.8 provide for more detailed requirements for monitoring the attendance and progress of students enrolled in ELICOS, Foundation Programs and higher education programs, and for having intervention strategies to support students when necessary.

    3. Identified issues

    Within the context of the Threshold Standards, TEQSA has identified a range of issues which may indicate potential problems in a provider’s approach to monitoring, review, and improvement:

    Monitoring and data gathering

    • Lack of investment in adequate time, staff, or resources to effectively complete monitoring, data gathering or data analysis, or a lack of focus on areas that pose the greatest risk to students and the integrity of the provider, which may lead to:
      • insufficient data being available to identify problems and engage in evidence-based improvement in areas such as academic integrity, progression, completion, and admissions
      • a failure to monitor or provide support to students with equity backgrounds
      • insufficient oversight of education agents and other third parties, increasing the risk to the students of being misled or receiving a poor quality of education
      • courses being subject to ad-hoc changes.
    • Not monitoring cohorts of students who are more likely to be at risk academically, i.e. students with a low socio-economic status background.
    • Not monitoring English language skills as a risk factor that may impact on students’ successful completion of courses.

    Quality assurance systems

    • Quality assurance systems are absent, too complex, or poorly enacted, which may result in:
      • a provider being unable to validate the quality of its educational offerings
      • courses of study not being sufficiently reviewed or updated.

    Student feedback

    • Lack of timeliness or neglecting student feedback in monitoring and improvement processes, resulting in:
      • failing to adequately address barriers and risks to sub-groups of student cohorts progressing through courses of study
      • the hinderance of course improvement based on the end users’ (students’) experience
      • constraining improvements of other aspects of the student experience including campus and facilities, course enrolment and student information systems, and issues of student wellbeing and safety
      • elevated reputational and market risks.
    • Declining responses to student feedback, which may impact on providers’ approaches to monitoring and review.
    • Lack of mechanisms to screen student feedback to identify abusive or discriminatory comments or feedback that indicates that there may be a risk of harm, resulting in:
      • teachers and supervisors failing to review student feedback due to concerns about psychosocial hazards or harms
      • providers failing to identify students at risk of harm
      • providers failing to protect staff from abusive or discriminatory feedback.

    Integrity of operations

    • Insufficient attention to the integrity of a provider’s operations, including the academic integrity of its offerings, that raises concerns about the credibility and legitimacy of any qualifications issued.

    External referencing

    • A lack of external referencing within an institution limiting the awareness of advances in a particular field of education, leaving a provider ‘reinventing the wheel’ or providing outdated education.
    • A lack of stakeholder perspective via external referencing jeopardising claims about the quality and standing of courses, providers, and the Australian higher education sector more broadly.
    • No involvement of industry stakeholders and advisory boards or other stakeholders external to the institution in benchmarking to ensure graduates are best placed to succeed in their industries.

    Lacking the general capability to monitor, review and improve in a way expected given the character of the provider

    • Absence of any systematic policies and approaches to an ongoing improvement cycle.
    • A lack of mature and advanced processes appropriate to the provider category in which the provider is registered.
    • Failure to systematically collect and analyse data for trend analyses on student progress and success across different cohorts and student subgroups.

    Related resources

    Notes

    1. Explanatory Statement Higher Education Standards Framework (Threshold Standards) 2021, p.11.

    Document information

    Version # Date Key changes
    1.0 19 March 2024 Document finalised
    Subtitle
    Version 1.0
    Stakeholder
    Publication type

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  • Gen AI and tomorrow’s professionals - upcoming webinar

    As generative artificial intelligence (gen AI) evolves, it will transform the way we work and learn. Australia’s professional accreditation bodies and higher education providers have a critical role in ensuring tomorrow’s graduates can use gen AI ethically and effectively, and have the knowledge and skills needed to meet the requirements of their chosen profession.

    On 12 June, TEQSA will host a joint webinar with the National Artificial Intelligence Centre (NAIC) and Jobs and Skills Australia (JSA). Professional accreditation bodies and higher education providers are invited to join us as we explore the impact of gen AI on education, regulation and industry, and our joint role in ensuring future graduates have the knowledge and skills they will need in tomorrow’s workplaces.

    The free webinar, Education to industry: how gen AI is shaping tomorrow, will be held on Thursday 12 June from 2pm to 3.30pm (AEST). 

    Register to attend: Webinar Registration - Zoom

    Date
    Last updated:
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    Artificial intelligence AI

  • Blocked illegal cheating websites

    Australia’s anti-cheating laws make it an offence to provide or advertise academic cheating services in higher education.

    TEQSA  is working to disrupt access to these sites to protect students and the integrity of higher education.

    List of blocked illegal cheating websites

    An alphabetical list of blocked illegal cheating websites is available below:

    • 1daixie.com
    • 12hoursessay.com
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    Last updated:

  • Websites blocked to protect students and academic integrity

    TEQSA continues to disrupt predatory academic cheating services, by blocking their websites in Australia.

    TEQSA has blocked another 60 commercial academic cheating websites, disrupting the operations of these illegal services which target students in Australia.

    This recent action brings the total number of websites blocked, under protocols with major internet service providers (ISPs), to 475. A list of the blocked illegal cheating websites is available at teqsa.gov.au.

    Academic cheating services allow students to pay someone to complete assessments for them. This undermines the student’s learning and the trust in the qualification they receive. Further, using these services leaves the student vulnerable to blackmail and identity theft.

    Blocking illegal academic cheating service websites is part of TEQSA’s multi-pronged approach to protecting the integrity of higher education awards.

    TEQSA has numerous resources available to support higher education students, academics and professional staff. These resources include:

    Date
    Last updated:
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    Keyboard

  • TEQSA Statement of Regulatory Expectations: Compliance with workplace obligations

    TEQSA has today published the Statement of Regulatory Expectations: Compliance with workplace obligations.

    Many providers have notified the Fair Work Ombudsman (FWO) and TEQSA that they have identified instances where they have underpaid staff and have not met their obligations under their enterprise agreements. These are serious instances of providers not meeting their obligations, and TEQSA notes extensive work has been undertaken by a number of providers to pay amounts owing to affected staff.

    However, work is also needed to address the underlying contributing factors and minimise the chance of recurrence in the future. TEQSA has worked closely with the FWO to identify system-level actions and improvements that are needed for providers to reasonably manage these risks. TEQSA's expectations about these system-level responses are set out in the Statement of Regulatory Expectations: Compliance with workplace obligations.

    A Statement of Regulatory Expectations (SRE) is not a legislative instrument. It is a new regulatory tool that TEQSA has adopted to inform providers' response to significant systemic, ongoing or emerging risks to compliance with the Higher Education Standards Framework (Threshold Standards) 2021.

    A SRE clearly sets out TEQSA’s expectations of the types of actions, improvements and monitoring that providers should be putting in place to understand and manage a key issue or risk. It provides a level of detail to clearly and transparently communicate TEQSA's expectations. It should be used by providers to assess their systems, processes and monitoring and to take corrective or improvement actions where needed. A SRE may also set out TEQSA's expectations about the type of information that the senior executive and governing body should receive to inform their active oversight and accountability for the issue.

    By publishing an SRE, TEQSA is giving the sector greater transparency around how TEQSA interprets the standards and what we will look for through our compliance activities to assure providers continue to meet the Threshold Standards.

    The Statement of Regulatory Expectations: Compliance with workplace obligations was endorsed by the TEQSA Commission in March 2025. Publication was delayed due to TEQSA's obligations during the caretaker period while the federal election was underway.

    In addition to the FWO, TEQSA also consulted with the Department of Education, Universities Australia, the National Tertiary Education Union and the Australian Higher Education Industrial Association in developing this statement.

    The Statement of Regulatory Expectations: Compliance with workplace obligations applies to all registered higher education providers. However, those in the ‘Australian University’ provider category will be required to provide an annual attestation to TEQSA from their Vice-Chancellor, along with an index of supporting evidence, in relation to mechanisms to manage and assure compliance with workplace obligations. This is because evidence from the FWO and information provided to TEQSA shows providers in this category are more likely to be larger, more complex organisations with a greater risk of non-compliance.

    TEQSA will engage with Vice-Chancellors in the coming weeks regarding the additional reporting requirements and the date for submission. TEQSA is also updating its registration and re-registration processes to reflect these expectations and will communicate this to applicants accordingly.

    Further information

    Date
    Last updated:
    Featured image
    Statement of Regulatory Expectations

  • How to apply to add a Foundation Program to CRICOS

    Foundation Programs

    Foundation Programs for overseas students are nationally recognised courses that provide an academic entry pathway to first-year undergraduate study or its equivalent.

    Only education institutions registered under the Education Services for Overseas Students Act 2000 (ESOS Act) and listed on the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) can enrol overseas students to study in Australia on a student visa.

    TEQSA has regulatory responsibility for Foundation Programs delivered by registered higher education providers, and Foundation Programs delivered by education providers with an entry arrangement with at least one registered higher education provider. TEQSA is the ESOS agency responsible for registering and renewing registration on CRICOS by these providers.

    Foundation Programs must comply with requirements set out in the:

    Self-assurance report

    TEQSA requires that providers seeking to add a Foundation Program to their CRICOS registration or renew an existing Foundation Program submit a self-assurance report.

    A self-assurance report is an opportunity for providers to demonstrate the effectiveness of their self-assurance mechanisms.

    The self-assurance report should consist of no more than 5 pages outlining how the provider’s governing body assures itself of the quality of its education operations in relation to its Foundation Program, and that it meets and will continue to meet the requirements of the ESOS Act, the National Code 2018 and the Foundation Program Standards.

    Note: All claims made in the self-assurance report must be substantiated by evidence, with reference to specific supporting documents in-text. Wherever possible, supporting evidence should be directly accessible via in-text hyperlinks, included as attachments to the report where specified, or otherwise listed in an index for later submission on request.

    Adding a new Foundation Program

    As part of the self-assurance report, providers wishing to add a new Foundation Program to CRICOS should:

    1. Provide evidence of how risks have been identified, managed and mitigated, and how the provider will manage these risks going forward, including areas for continuous improvement, and associated actions and measures to monitor success.
    2. Demonstrate how the provider manages key sector risks in the following areas:

    Note: TEQSA expects that providers specialising in the delivery of Foundation Programs will adapt advice addressed to the higher education sector to the needs of their student cohort.

    Student recruitment and admission

    TEQSA recommends that providers consider:
    Student participation, support and experience

    TEQSA recommends that providers consider:
    Student attainment

    TEQSA recommends that providers consider:
    1. Outline the findings, actions arising, and resulting outcomes of at least one review by a suitably qualified discipline expert that verifies that the course is compliant with the Foundation Programs Standards. A copy of the review should be included as an attachment to the self-assurance report. See the section Commissioning a review of compliance with the Foundation Program Standards below for further information.
    2. Provide evidence of the course’s approval and oversight through the provider’s internal quality assurance mechanisms.
    3. Outline whether the program is delivered as a standard or extended Foundation Program.
    4. Outline whether the program is delivered as a streamed or generalist program.
    5. Verify that the scheduled English language hours are compliant with requirements under Standard 4 of the Foundation Programs Standards.
    6. Provide evidence of the formal measures the provider has implemented to ensure that assessment outcomes for the English language subjects are comparable to other criteria used for admission to the available higher education pathways, or for admission to other similar courses of study.

    Renewing an existing Foundation Program

    TEQSA requires CRICOS-registered providers who deliver Foundation Programs to apply for re-accreditation of their Foundation Program(s) at the same time they are applying to renew their CRICOS registration. For these providers, the application to renew their Foundation Program(s) is integrated into the application to renew their CRICOS registration.

    These providers will submit 2 self-assurance reports as part of their CRICOS renewal: one focused on the CRICOS re-registration requirements, and the other on the Foundation Program requirements.

    As part of the self-assurance report, providers wishing to renew a Foundation Program should:

    1. Provide evidence of how risks have been identified, managed and mitigated, and how the provider will manage these risks going forward, including areas for continuous improvement, and associated actions and measures to monitor success.
    2. Demonstrate how the provider manages key sector risks in the following areas:
    Student recruitment and admission

    TEQSA recommends that providers consider:
    Student participation, support and experience

    TEQSA recommends that providers consider:
    Student attainment

    TEQSA recommends that providers consider:

    Note: TEQSA expects that providers specialising in the delivery of Foundation Programs will adapt sector-wide advice to the specific needs of their students.

    1. Outline the findings, actions arising, and resulting outcomes of at least one review by a suitably qualified discipline expert that verifies that the course is compliant with the Foundation Programs Standards. A copy of the review should be included as an attachment to the self-assurance report. See the section Commissioning a review of compliance with the Foundation Program Standards below for further information.
    2. Provide evidence of the course’s approval and oversight through the provider’s internal quality assurance mechanisms.
    3. Outline whether the program is delivered as a standard or extended Foundation Program.
    4. Outline whether the program is delivered as a streamed or generalist program.
    5. Verify that the scheduled English language hours are compliant with requirements under Standard 5 of the Foundation Programs Standards.
    6. Provide evidence of the formal measures the provider has implemented to ensure that assessment outcomes for the English language subjects are comparable to other criteria used for admission to the available higher education pathways, or for admission to other similar courses of study.
    7. Outline any changes that have been made to the Foundation Program since it was last approved by TEQSA or another ESOS agency:
      1. where the provider has made significant changes that entail any of the following, if the changes are to be implemented at the time of reregistration the provider is to outline those changes, and the rationale for their implementation:
        1. changes, whether incremental or at one time, to more than 25% of the total number of course units or subjects from the time the Foundation Program was last approved by the ESOS agency for the provider
        2. substantial variations to course delivery, or
        3. substantial changes to course nomenclature, duration, entry requirements, outcomes or structure.
      2. where the provider has made any other changes, the provider will need to submit evidence of their approval by the provider’s academic board.

    If significant changes are made to courses at any other time, providers are reminded of their obligation to notify TEQSA via a material change notification outlining the changes, and the rationale for those changes. See TEQSA’s website for further advice on notifications required of CRICOS-registered providers.

    Commissioning a review of compliance with the Foundation Program Standards

    TEQSA strongly encourages providers to commission a review by a suitably qualified discipline expert to verify their Foundation Programs’ compliance with the ESOS Act, the National Code 2018 and the Foundation Program Standards. Commissioning a review can be an effective way for a provider to check that the design of their Foundation Program and their institutional policies, procedures and practice are fit for purpose.

    The engagement of an independent expert should be seen primarily as an opportunity to contribute to self-assurance and the continuous improvement of the organisation, rather than a method to meet TEQSA or other requirements. TEQSA expects providers can show how they have reflected on the recommendations made and identified and implemented improvements, both of which are critical elements of a healthy self-assurance and quality improvement process.

    Reviewers’ professional experience and qualifications should match the requirements of the review task, and reviewers should be briefed before the assignment and given clear specifications for the task. TEQSA has prepared a sample brief for reviewers, to indicate our expectations in relation to the scope of the review.

    Application for exemption to enrol students under the age of 17 in Foundation Programs

    Providers seeking to apply for an exemption to enrol students under the age of 17 (minimum acceptable age is 16) in a Foundation Program must apply to TEQSA detailing arrangements in place to support younger students.

    The application must meet the regulatory requirements, include all requested information, and be submitted through the provider portal. If approved, the exemption will be aligned with the provider’s CRICOS registration, and valid until the CRICOS registration end date. No fees apply for seeking an exemption.

    More details on accessing the application forms can be obtained by emailing cricos@teqsa.gov.au.

    Further information

    For more information or assistance with applying to add a Foundation Program to CRICOS, please contact the CRICOS team at cricos@teqsa.gov.au. 

    Last updated:

    Related links

  • Engaging an independent expert to undertake a review

    Body

    Sector update

    This document gives providers guidance on planning and conducting independent expert reviews.

    Why undertake a review?

    • An independent review can be an effective way for a provider to check the effectiveness of its institutional quality assurance processes.
    • Independent reviews can help assure providers that their institutional policies, procedures and practice remain current and aligned with contemporary developments.
    • Opportunities for continuous improvement can be identified. A provider can reflect on the recommendations made and identify and implement improvements, both of which are critical elements of a provider’s self-assurance and quality improvement process.
    • Independent review provides an opportunity to engage with expertise not available internally and draw on additional specialised expertise.
    • Incorporating independent expert advice into business-as-usual processes delivers the best value to providers as a means of supporting effective institutional quality assurance.
    • Engaging independent expert advice should be seen as an opportunity to contribute to self-assurance and the continuous improvement of the organisation, rather than a method to meet TEQSA or other requirements.

    Considerations when planning a review

    Providers may refer to TEQSA’s guidance on the factors for consideration relating to suitable independence and expertise.

    Timing

    • Should a provider wish to use evidence of independent expert review to demonstrate its focus on self-assurance and continuous improvement, planning well in advance of a regulatory process will allow time to demonstrate implementation of actions and improvements.

    Scope

    • A provider may choose to undertake a comprehensive periodic review, or a targeted review focused on specific standards.
    • Providers may include issues identified through previous reviews, including those identified by TEQSA or other regulatory processes, material changes that may have occurred (such as a move to online learning), input from key stakeholders including students and professional accrediting bodies.
    • The templates TEQSA uses to scope reviews when engaging experts are available from your case manager. These are provided as guidance only.

    Consideration of independent expert reports

    • Has the independent reviewer made any suggestions or observations, including identifying specific focus areas for the future? How will these be considered and addressed?  
    • Has the review process identified any gaps in terms of evidence that was not readily available? How can this be addressed in the future?
    • Does the report provide enough information, or would it be beneficial to meet with the reviewer to discuss the findings in more detail?
    • What has been learned from undertaking this review and what could be done differently in the future to improve the process and the outcome?
    • If an expert has suggested changes or improvements, could the expert be engaged to undertake a secondary review to assess how successfully those changes have been implemented?
    • If risk areas have been identified, how have the issues of non-compliance occurred? What steps can be taken to ensure the non-compliance is rectified and monitored to ensure risks are appropriately managed in the future?

    What does TEQSA look for?

    When a provider has submitted evidence of an independent review for consideration in a regulatory process, TEQSA will consider:

    • The finalised review complete with terms of reference, review reports and the provider’s response; including meaningful and detailed actions taken to address recommendations
    • Evidence that the relevant committees/bodies have considered the recommendations of the experts
    • Evidence that the Governing Body has considered any additional resourcing that might be required to address issues identified by the external experts.

    Successful independent reviews can also have additional benefits. For example an independent Course Review that is:

    • well-scoped
    • conducted by a suitable independent reviewer
    • clearly demonstrates that findings or recommendations have been considered, acted upon and improvements documented, and
    • shows Academic Board oversight,

    will carry significant weight when TEQSA is considering the quality of academic governance in a provider.

    This could reduce assessment timeframes in some circumstances as, depending on the suitability of the experts engaged, the findings of the review, and how the provider has actioned improvements, TEQSA may elect not to engage its own independent expert to undertake a review.

    Stakeholder
    Publication type

  • Guidance note: Staffing

    Body

    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 staffing and considered all feedback.
     

    This guidance note was finalised on 11 June 2025.
     

    The purpose and intent of the guidance note about staffing is to support providers in developing policies and processes to ensure there is requisite workforce planning and oversight of staffing arrangements and that both academic and professional staff have sufficient knowledge, skill, resources, qualifications or experience to provide adequate support to students and lead them towards expected learning outcomes.
     

    1. What does staffing encompass?

    Under the Higher Education Standards Framework (Threshold Standards) 2021 (Threshold Standards), registered higher education providers (providers) have obligations around staffing1 to ensure that:

    • student and staff support and services are sufficiently resourced by appropriately trained and qualified professional staff
    • academic staff have sufficient knowledge, teaching capacity and teaching expertise to meet the needs of students
    • research, research training, and scholarship is supported through appropriate policy frameworks and resources.

    Workforce planning supports a sound approach to planning, developing, maintaining and optimising staffing arrangements. Successful workforce planning ensures a staffing profile that will fulfil the provider’s higher education mission and ensure that the provider meets, and continues to meet, the requirements of the Threshold Standards and operates as an efficient organisation, both academically and corporately.

    The primary part of the Threshold Standards that sets out providers’ obligations around staffing is Section 3.2. Providers are expected to ensure their students:

    • are supported in their learning
    • have teachers who are qualified and equipped to lead them in their chosen course of study and towards expected learning outcomes
    • can access teaching staff when seeking individual assistance.

    Professional staff make important contributions to the delivery of learning and teaching. Providers should ensure they have sufficient professional staff to support the administration of learning and teaching operations and that these staff have the contemporary knowledge and skill needed to meet the requirements of their roles.

    Similarly, providers should confirm, through regular oversight, that academic staff, particularly those responsible for teaching and supervision, are appropriately equipped for their roles. This includes ensuring academic staff have, and continuously hold through ongoing professional development:

    • knowledge of contemporary developments in their discipline or field, informed by continuing scholarship and/or research
    • knowledge of current teaching and assessment approaches relevant to the discipline, and the skills and capacity to apply and disseminate disciplinary knowledge relevant for the mode of delivery and the needs of students
    • knowledge of institutional policies on academic integrity and how to identify potential academic and research integrity breaches and take appropriate action
    • a qualification in a relevant discipline at least one level higher than is awarded for the course of study, or equivalent relevant academic, professional or practice-based experience and expertise, except for staff supervising doctoral degrees having a doctoral degree or equivalent research experience.

    Providers are also expected to ensure that staff in the academic leadership team hold the necessary skills and experience to:

    • determine academic policies and standards for the provider
    • guide and supervise less experienced staff.

    Further, when undertaking research training, a provider should have enough suitably qualified and experienced academic and professional staff to provide supervision and support to research candidates in the fields of research being undertaken. The research output of students undertaking research training must also be assessed by suitably qualified experts who:

    • are independent of the work being assessed
    • have international standing in the relevant field of research to be assessed
    • have the competency to undertake assessments.

    2. What TEQSA will look for

    TEQSA considers relevant standards from the Threshold Standards in the context of staffing and workforce planning, among which most notably are:

    Part A: Standards for HE providers Key considerations
    2.1.1-3: Facilities and Infrastructure
    • There is appropriate staffing to ensure facilities and infrastructure are fit for purpose, sufficient for the students who use them and accessible when needed.
    2.3.4: Wellbeing and Safety
    • Providers promote and foster an environment that safeguards and supports the wellbeing and safety of both staff and the students they support.
    3.2.1-5: Staffing
    • Staff have appropriate training, level of qualifications and knowledge of contemporary developments in a relevant field or discipline to meet expected student learning outcomes.
    • Teaching staff who do not meet the standard for teaching or supervision are supervised by staff who do.
    • Professional staff have sufficient knowledge, skill and capacity to meet the administrative needs of student cohorts.
    • There are sufficient resources, including staff, to deliver new or reaccredited courses.
    • Staff are accessible to students seeking individual assistance with their studies.
    • Academic staff maintain knowledge of contemporary developments in relevant disciplines or fields, and skills in contemporary teaching, learning and assessment principles.
    3.3.4: Learning Resources and Educational Support
    • Staff who deliver learning support offer services tailored to the mode of study and specific needs of student cohorts.
    4.1.2: Research
    • Research staff are equipped with the qualifications, experience and skills required for their roles.
    4.2.2-3a-c: Research Training
    • As part of their research training, research students are supported by continuing supervisory arrangements.
    • Research students are provided with the appropriate resources, study environment, and support required for their project.
    • Supervisory staff have the requisite qualifications, experience and currency of knowledge in a relevant field of research to support research students.
    • Supervisors demonstrate on-going, original research contributions to a relevant field or discipline.
    5.3.3 and 5.3.6: Monitoring, Review and Improvement
    • The quality of teaching within a course of study, including staff support, is continuously improved and maintained through cyclic monitoring and review.
    • Teachers and supervisors have access to feedback on their performance and are supported in enhancing these activities.
    5.4.1-2: Delivery with other Parties
    • The governing body assures that quality delivery is maintained where a provider enters an arrangement with another party, including assurance that obligations regarding staffing are being met.
    6.1.4: Corporate Governance
    • An institutional culture is promoted and maintained that ensures staff are treated equitably and appropriate consideration is given to the different supports required by diverse groups of staff.
    • A safe environment is promoted and maintained by taking a proactive and educative approach to wellbeing.
    • Staff wellbeing is fostered by addressing the need to minimise vicarious trauma and/or burnout of staff who work in student-facing roles.
    6.2.1a-c,e: Corporate Monitoring and Accountability
    • Governing bodies ensure the provider has the capacity to deliver on its mission through its workforce with oversight of workforce needs and capabilities. Staffing is considered when setting and monitoring corporate directions and targets, considering resourcing needed to maintain and sustain the provider’s business model, and identifying and managing risks.
    • Governing bodies ensure the provider complies with legislative requirements such as workplace laws.
    • Governing bodies ensure sufficient systems and processes are in place to address material risks such as underpaying staff.
    6.3.1-2: Academic Governance
    • Institutional processes and structures are in place to maintain academic leadership and academic oversight to mitigate risks and assure the quality of teaching, learning, research and research training, including risks arising from staffing.
    • Staff in the academic leadership team hold the necessary skills and experience to perform their roles.

    TEQSA will seek information demonstrating that the level and type of staffing for courses of study meet the requirements of the Threshold Standards. This includes information about the overall planned or current complement of professional and academic staff, and the capabilities of individual academic staff members. TEQSA will expect to see key elements of a workforce planning process encompassing planning, target setting, monitoring and improvement and that these elements give rise to informed views at senior executive and governing body level.

    In the first instance, TEQSA will take account of the stage of development of the provider (e.g. new, developing or established) and whether the provider is in a relatively stable phase of staffing or is proposing new initiatives that require significant new workforce planning, such as:

    • introducing a new field of education or course of study
    • developing a new campus or mode of delivery
    • a proposed change of provider category
    • marked changes in service delivery or scale of operations.

    Applicants applying for initial registration will need to provide TEQSA with a workforce plan detailing how they will achieve and maintain the quality and level of academic and professional staffing required. TEQSA will need to be satisfied that the provider will meet the staffing requirements of the Threshold Standards for the initial establishment phase and then continue to meet the requirements through subsequent phases. Providers will need to show how they will scale their workforce progressively as student numbers are projected to increase. The applicant should also prepare contingency plans to account for risks associated with key academic staff departing the provider.

    To be satisfied that the relevant Threshold Standards related to staffing will be met and continue to be met, TEQSA will expect to see the following:

    • Governance mechanisms that provide oversight of a provider’s staffing arrangements
      • The corporate governing body ensures there is a policy framework in place that provides leadership and governance of academic activities. The policy framework will need to cover selection and development of staff (including underperforming staff) and address the staffing requirements of the Threshold Standards.
    • The actual, or projected, staffing complement for each course of study (including support functions and services)
      • TEQSA will expect a provider’s staffing of a current or planned course of study to be determined:
        • by the learning outcomes of the course
        • through analysis of the learning needs of students, including student access to academic staff outside of formal teaching hours
        • with consideration of contemporary knowledge required in the discipline or field, informed through continuing scholarship or research advancements.
    • An appropriate level of academic leadership reflected in a provider’s current staff profile or workforce plan
      • The level of academic leadership should be consistent with the provider’s:
        • scale, e.g. number of students, courses, teaching locations
        • fields of education and the Australian Qualifications Framework (AQF) levels of its courses of study.
    • Adequate risk analysis and action plans to address issues relating to staffing
      • The provider will need to demonstrate that the risks associated with projected developments (including those relating to the ability to meet staffing requirements) have been identified and that these can be managed and mitigated
      • If a provider’s staff profile or workforce plan shows a reliance on casual academic staff, the provider should demonstrate how it will ensure casual academic staff:
        • have and retain the contemporary skills and knowledge required to fulfil their roles
        • are allocated sufficient paid time to deliver effective teaching and support to students within the scope of their role.
      • Where an issue related to staffing arises, TEQSA will expect a provider to demonstrate how it will remedy the issue and prevent it re-occurring. For example, if the provider shows a lack of action to effectively mitigate or resolve identified issues related to staffing, it should provide a credible action plan to show how it will identify and respond to these issues in future. This action plan should later be supported by documentation showing activities undertaken in accordance with the action plan and any subsequent monitoring or consideration of the issues by the provider’s academic and corporate governing bodies.
    • An outline of the actual or projected governance and quality assurance systems for academic activities (including boards and committees) and provision for staff to operate and support them. The outline will need to demonstrate that the requirements of the relevant Threshold Standards are met or will be met.

    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 staffing are:

    • 5.3.2 – For students under 18 years of age, adults involved in or providing accommodation and welfare arrangements must have ‘working with children’ clearances.
    • 6.5 – A provider must designate a member (or members) of staff to be the official contact point for overseas students. These officers must have access to up-to-date details on the provider’s support services.
    • 6.7 – The provider’s staff who interact directly with overseas students must have knowledge of their obligations under the ESOS Framework.
    • 11.2.6 – The maximum number of overseas students reflects the appropriateness of the staff, resources and facilities for delivery of the course.

    Relevant Australian legislation

    It is important for providers to be aware of their obligations under other relevant legislation, including:

    • Obligations related to student support are set out under section 19-43 of the Higher Education Support Act 2003 (HESA) and apply to providers approved under the HESA.
    • Each state and territory have their own legislated requirements related to working with children clearances for any staff working with students under the age of 18. Providers should refer to their own relevant state and territory agencies.
    • Providers must fulfil their obligations under national workplace laws, such as the Fair Work Act 2009 and the Sex Discrimination Act 1984. These include, but are not limited to, ensuring staff receive pay and conditions in accordance with relevant industrial instruments and complying with the duty to eliminate unlawful sexual discrimination in the workplace. 

    3. Identified issues

    Within the context of the Threshold Standards, TEQSA has identified issues that may indicate risks to compliance regarding staffing. These include, but are not limited to:

    Staff skills and knowledge

    • Academic staff not having the appropriate qualifications to teach a course or providers not being transparent, consistent and appropriate in deciding whether a staff member’s experience is equivalent to such qualifications.
    • Research staff not having the requisite qualifications and currency of knowledge in the relevant field of research to provide effective supervision to research students.
    • There is insufficient investment in the training, resourcing or tools of professional staff to enable them to effectively deliver support and administrative services to students.
    • Academic staff teaching a course or subject they do not have the appropriate knowledge, skill and tools to teach.
    • Insufficient oversight of academic staff who teach specialised components of a course and who do not fully meet the standard for knowledge, skills and qualification.
    • Unclear or insufficient tools and guidelines for staff recruitment leading to risks of not recruiting staff with the required skills and knowledge.
    • Academic staff responsible for teaching that are not engaged in active scholarship resulting in their knowledge becoming out of date. This may impact the quality of teaching and currency of content and assessment methods (see Guidance note: Scholarship).
    • Insufficient delineation between professional development and scholarly engagement in institutional policies or processes, making it difficult to identify and manage risks arising from a lack of engagement in scholarly activities by academic staff.
    • Insufficient recognition of staff development needs.

    Staff resourcing and responsiveness to students

    • Unrealistic projections of staffing requirements with unsustainable financial and/or educational outcomes.
    • Staff numbers and capabilities not rising in line with rising student numbers as operations scale up, with attendant risks to educational delivery, student experiences and provider reputation.
    • A provider has not taken steps to ensure it has sufficient academic staff to maintain a reasonable staff-student ratio within sector benchmarks.
    • Academic staff responsible for teaching and supervising research are not available to support students in their studies at reasonable times. This includes casual staff who are not allocated time, or sufficient time, to provide this support.
    • Insufficient professional staff to provide non-academic support within reasonable timeframes.
    • Due to lack of capacity, academic staff are unable to mark student assessments or provide feedback in accordance with the provider’s policies.

    Academic oversight

    • Academic leaders have insufficient academic skills and experience to guide and oversee teaching and learning quality.
    • A senior academic is not assigned to oversee and coordinate a course of study, or where they are assigned, the senior academic delegates the responsibility to a junior staff member.
    • No evidence that workplace and scholarship plans are consistently implemented.

    Governance

    • A lack of oversight of workplace and scholarship plans by the corporate and academic governing bodies.
    • Poor organisational capacity to adapt to changing circumstances.
    • Insufficient capacity to anticipate and respond to contingencies and uncertainties.
    • Failure to consider the practical workforce implications of academic and/or corporate developments.
    • A lack of monitoring or monitoring mechanisms to identify issues related to workplace obligations. These include the quality of teaching, staff-student ratio, whether payments to staff are in accordance with national workplace laws and whether existing payroll systems are capable of ensuring correct payments to staff.
    • A lack of action to effectively mitigate risks or resolve identified issues related to workplace obligations, including wage underpayment.

    Related resources

    Notes

    1. For the purposes of the Threshold Standards, ‘staff’ includes personnel who are engaged in work for the provider even if they are not formally employed by the provider (e.g. honorary teachers, researchers or supervisors). Where such work is necessary or critical to the mission of the provider it needs to be encompassed by workforce planning. The term ‘staff’ includes both academic (teaching and research) and professional staff and encompasses the critical role of service delivery staff in the student experience.

    Document information

    Version # Date Key changes
    1.0 11 June 2025 Major revision. This guidance note and Learning resources and education support replaces Staffing, learning resources and educational support.

     

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