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TEQSA Corporate Plan 2021-25

24 August 2021


As the accountable authority of the Tertiary Education Quality and Standards Agency (TEQSA), we are pleased to present the TEQSA Corporate Plan 2021-25 as required under paragraph 35(1) of the Public Governance, Performance and Accountability Act 2013 (PGPA Act) and s160(1) of the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act). The Corporate Plan is prepared in accordance with the Public Governance, Performance and Accountability Rule 2014 and covers four reporting periods from 2021-22 to 2024-25.

Professor Peter Coaldrake AO
Chief Commissioner

Professor Joan Cooper

August 2021

From the Commissioners

We are pleased to present the Tertiary Education Quality and Standards Agency (TEQSA) Corporate Plan for the years 2021-22 to 2024-25. This plan sets out TEQSA’s priorities, in an environment of significant change and uncertainty for higher education, both in Australia and internationally. These priorities include: a revised approach to sector risks; addressing threats to academic integrity; evolving TEQSA’s compliance monitoring; building on measures taken during the pandemic; and improving TEQSA’s timeliness and responsiveness.

In response to the disruption caused by the COVID-19 pandemic, TEQSA’s approach to risk will remain focused on students and the financial viability of the higher education sector. TEQSA will also be closely monitoring other pandemic-related developments, such as changes in transnational education.

The establishment of the Higher Education Integrity Unit has prompted a sharper focus on issues of academic integrity, and their impact on the quality and reputation of the higher education sector. TEQSA’s role in implementing new legislation to block websites offering contract cheating services is an important start. Other areas of focus, with an emphasis on collaborating with providers, include admissions standards and cyber security threats.

This corporate plan also covers the proposed commencement of revised cost recovery arrangements for TEQSA’s regulation. This initiative in line with government policy had been deferred due to the impacts of the pandemic. TEQSA has been consulting the sector closely on cost recovery during 2021, in preparation for the expected commencement on 1 January 2022.

TEQSA will continue to engage providers and other stakeholders on our performance as a regulator, and on developments in quality assurance. In past years, this has included an annual stakeholder survey as well as meetings with peak bodies, forums with groups of providers, visits with individual providers, and the annual TEQSA conference.

The Commission will be focused on the timeliness and responsiveness of TEQSA’s registration, re-registration and course accreditation services, and the quality of TEQSA’s compliance and risk assessments, including in response to concerns regarding the higher education sector raised directly by members of the broader community.

In responding to the COVID-19 pandemic, TEQSA will continue to exercise its duty of care in ensuring the welfare and productivity of TEQSA staff. Significant investments in TEQSA’s business processes and information management, which began in 2019-20, are expected to
improve agency operations.

This plan is a ‘live’ document, revised as the agency adapts and responds to changes in our operating environment and in Australia’s higher education sector.

Professor Peter Coaldrake AO
Chief Commissioner

Professor Joan Cooper

August 2021

TEQSA’s vision

Public confidence in the excellence of Australian higher education.

TEQSA’s purpose

TEQSA’s purpose is to deliver quality assurance that protects the interests of students and the reputation and standing of Australian higher education.

As an independent quality assurance and regulatory agency, TEQSA adopts a risk-based approach that is guided by principles of necessity, risk and proportionality, and which supports quality, diversity, innovation, and excellence in tertiary education.

TEQSA has three strategic objectives in delivering its purpose:

  1. promote and support good practice and effective self-assurance across the sector
  2. identify, analyse and respond to risks to the sector
  3. ensure compliance with applicable legislation through effective and efficient regulation.

The core functions of TEQSA are to register all providers that offer higher education qualifications in or from Australia, and to accredit their courses (except for universities and other providers that have authority to accredit their own courses of study).

TEQSA’s compliance and quality assessments are carried out against the Higher Education Standards Framework (Threshold Standards) 2021, covering student participation, learning, teaching, research, quality assurance, governance, and information management.

TEQSA also provides advice and recommendations to the Commonwealth Minister for Education, and collects, analyses, interprets, and disseminates information relating to quality practice and improvements in higher education.

TEQSA’s performance: objectives, measures and targets

TEQSA’s purpose is supported through three key objectives, underpinned by both outcomes-based performance measures, and qualitative and quantitative targets to help in monitoring our progress and whether we are effective in delivering on our purpose. The plan includes specific deliverables for the first operational year.

More detailed targets are set out in TEQSA’s annual business plans for each of TEQSA’s organisational groups.

As a Commonwealth regulator, TEQSA is committed to best-practice regulation and embeds the principles of regulator best practice in all that we do. The following table demonstrates the alignment of TEQSA’s performance measures with the government-wide principles.

Principle of regulator best practice Relevant TEQSA performance measure
1. Continuous improvement and building trust
Regulators adopt a whole-of-system perspective, continuously improving their performance, capability and culture, to build trust and confidence in Australia’s regulatory settings.

We engage with all parts of the sector.

TEQSA’s assessment and compliance approach aligns with principles of regulatory necessity, risk and proportionality.

Assessment and compliance activities are streamlined and coordinated to ensure that regulatory activity is undertaken efficiently.

2. Risk-based and data-driven
Regulators maintain essential safeguards, using data and digital technology to manage risks proportionately to minimise regulatory burden and to support those they regulate to comply and grow.

TEQSA monitors the performance of registered providers, identifies risks, assesses provider responses and where necessary, takes regulatory or other action.

Initiatives to respond to sector risks are delivered.

3. Collaboration and engagement
Regulators are transparent and responsive implementing regulations in a modern and collaborative way.

Education and guidance materials is developed in consultation with the sector and supports provider self-assurance.

TEQSA is open and transparent in its dealings with regulated entities.

Objective 1: Promote and support good practice and effective self-assurance across the sector

Performance measure - evidence of achievement of objectives Target

Education and guidance materials are developed in consultation with the sector and supports provider self-assurance.
(RBPP 3)

In 2021-22, publish guidance notes, good practice notes and other support materials about quality based on identified needs.

Support materials and initiatives are highly rated by providers.

In 2020-21, 81 per cent of stakeholders rated guidance materials as good or excellent
(source: stakeholder surveys or forums).

Resources developed to support providers are consistently accessed by providers.

In 2020-21, guidance notes were viewed more than 65,000 times on the TEQSA website
(source: website visits).

We engage with all parts of the sector.
(RBPP 1)

In 2021-22, a wide range of stakeholders are consulted in reviewing and implementing changes to legislation, instruments, or regulatory policy.

80 per cent or more of providers from across the sector participate annually in TEQSA engagement activities.

The student section of the TEQSA website is increasingly accessed.

In 2020-21, the student section of the website was viewed more than 10,500 times
(source: website visits).

Objective 2: Identify, analyse and respond to risks to the sector

Performance measure - evidence of achievement of objectives Target

TEQSA monitors the performance of registered providers, identifies risks, assesses provider responses and where necessary, takes regulatory or other action.
(RBPP 2)

In 2021-22, enhance the risk monitoring capability of the agency by incorporating broader and more timely sources of information about providers.

The annual risk assessment of providers and the sector is completed and key themes are shared with the sector.

TEQSA’s sector risk monitoring activity contributes to the setting of its risk priorities.

Initiatives to respond to sector risks are delivered. (RBPP 2)

In 2021-22, develop and implement projects to address academic integrity and contract cheating and cyber security.

An annual assessment of progress and outcomes of projects is undertaken, and the results are shared with stakeholders, including students, and other agencies.

Objective 3: Ensure compliance with applicable legislation through effective and efficient regulation

Performance measure - evidence of achievement of objectives Target

TEQSA’s assessment and compliance approach aligns with principles of regulatory necessity, risk and proportionality. (RBPP 1)

In 2021-22, implement and monitor the effectiveness of TEQSA’s Compliance Monitoring Framework.

TEQSA takes action to ensure that serious non-compliance by registered and non-registered providers is disrupted or addressed.

Assessment and compliance activities are streamlined and coordinated to ensure regulatory activity is undertaken efficiently.
(RBPP 1)

In 2021-22, work in partnership with ASQA to reduce the administrative burden associated with CRICOS registrations for dual sector providers.

The year-on-year trend in processing times demonstrate improvement.

In 2020-21, the median processing time for re-registrations was 315 days and for accreditations for registered providers was 173 days.

Increase in positive ratings from providers with regard to TEQSA’s efforts to reduce administrative burden.

In 2020-21, 65 per cent of respondents rated TEQSA as good or excellent in reducing administrative burden
(source: stakeholder survey).

TEQSA is open and transparent in its dealings with regulated entities. (RBPP 3)

In 2021-22, establish and implement a program of outreach with providers to support ongoing compliance and address emerging issues early.

TEQSA engages annually with all providers to address issues and assist providers in understanding their obligations.

TEQSA’s activity

TEQSA has a range of functions and activities to achieve its purpose that align to the three strategic objectives.

Objective 1: Promote and support good practice and effective self-assurance across the sector

TEQSA offers education and guidance to assist providers in meeting their obligations and to promote quality enhancement. These include application guides, guidance notes, good practice notes and, more recently, conferences, seminars, workshops, digital offerings and other tools.

The subject areas have varied and have been in response to identified needs. TEQSA uses feedback from a range of sources such as providers, the Higher Education Standards Panel, peak bodies and students, as well as observations from cyclical and compliance assessments and the annual risk cycle, to establish the areas and forms of support to be developed. In 2021-22, the work of the Higher Education Integrity Unit will also contribute to identifying and addressing the agency’s direction in actions to support the sector address risks and sharing good practice.

Objective 2: Identify, analyse and respond to risks to the sector

TEQSA undertakes an annual cycle of risk assessment for all registered higher education providers as a fundamental regulatory tool that informs TEQSA’s policy work and regulatory operations. We use the outcomes to engage the sector, and in certain instances individual providers, on key risks.

Over the last three years, TEQSA has responded to sector risks such as academic integrity, transparency of admission processes, English language proficiency, and sexual assault and sexual harassment.

TEQSA will continue to analyse and respond to these and other emerging sector-wide issues, firstly in collaboration with the sector, and then where necessary through regulation. The creation of TEQSA’s Higher Education Integrity Unit and the commencement of actions under the contract cheating legislative provisions in 2021 will be important tools for TEQSA.

Objective 3: Ensure compliance with applicable legislation through effective and efficient regulation

TEQSA’s core regulatory work includes:

  • assessing applications for registration and re-registration as a higher education provider
  • accrediting and re-accrediting courses offered by higher education providers
  • registering and re-registering providers delivering higher education courses, Foundation programs, and English Language Intensive Courses for Overseas Students (ELICOS) to international students
  • compliance monitoring and assessments, including in response to material change notifications received by, and complaints about, higher education providers
  • ensuring that regulated academic awards are not offered by unregistered providers.

Improving the efficiency of TEQSA’s regulatory activity, with a focus on reducing the administrative burden of regulation for higher education providers (particularly independent private providers that are subject to both registration and course accreditation), will remain a priority for TEQSA. Following the implementation of new provider category standards in July 2021, TEQSA will focus on monitoring providers compliance with the requirements of the new standards. The establishment of processes for the assessment of research quality under the new standards will also be undertaken during the period of this plan.

Operating context

TEQSA’s legislative framework

TEQSA’s guiding legislation is the TEQSA Act. The TEQSA Act confers TEQSA’s quality assurance and regulatory powers and functions.

TEQSA has responsibilities under the Education Service for Overseas Students Act 2000 (ESOS Act) in relation to all providers delivering higher education to overseas students studying in Australia. TEQSA also has responsibilities in relation to providers of Foundation programs and ELICOS to overseas students.

Recent amendments to the TEQSA Act will allow TEQSA to block access to websites offering contract cheating services and manage student records in the event of provider closure. This will be an early focus for the new Higher Education Integrity Unit established within TEQSA.

Operating environment

TEQSA’s operating environment is made up of 186 higher education providers across four provider registration categories offering a diverse range of courses of study to over 1.5 million higher education students. Around 80 per cent of providers are registered to also deliver higher education courses to international students. Approximately half of registered higher education providers also deliver vocational education and training courses.

Australia’s higher education sector currently comprises 44 universities and 142 typically small, independent for-profit and not-for-profit providers. The universities, mostly large and comprehensive in scope, account for some 90 per cent of Australia’s higher education students. It is anticipated, however, that in the next decade significant growth will occur in the independent sector.

The authority to self-accredit courses of study is granted to universities and a small number of providers in other categories. Providers without self-accrediting authority are required to have their courses of study accredited by TEQSA. As of April 2021, TEQSA had accredited 1200 courses offered across 11 broad fields, principally in the fields of: management and commerce; society and culture; health; and education.

The previous rapid growth and diversification of the sector, both in terms of provider and student profiles, has been profoundly disrupted by the COVID-19 pandemic. The high level of uncertainty is characterised principally by a sharp reduction in international student enrolments and changing patterns of students’ campus engagement. Specifically, international student numbers declined somewhere between 5 and 17 per cent in 2021 compared with the same time in 2020. In addition, the pressures associated with the pandemic has led to a marked acceleration in the pace of technology-mediated course delivery.

A principal risk to the sector as a result of the pandemic is the financial viability of providers, which may drive significant change – including in ownership and structure – over the course of this corporate plan. The financial viability of providers – and any impacts on the quality of provider offerings – will be a focus of TEQSA’s monitoring and regulatory activity.

The broad challenge for TEQSA, as the sector regulator, will be in monitoring change and anticipating risks, and adjusting the quality assurance and regulatory focus and methodology. An important priority will be in enabling innovation and responsiveness to the impacts of the pandemic, while also ensuring that quality is maintained and enhanced, and that the interests of students are protected.

Specific challenges

Over the period covered by this Corporate Plan, TEQSA has a number of specific challenges additional to its standing regulatory and quality assurance practice. These include:

  • the ongoing impact of the COVID-19 pandemic on the sector, including the nature and quality of its products and offerings (such as online learning). Provider responses on the student experience will also be a priority
  • the compliance of providers with the research standards of the new provider category standards
  • sharpening our regulatory focus and model
  • the introduction of full cost recovery of its regulatory services from 1 January 2022. Following consideration of feedback from the sector, TEQSA will also need to finalise cost recovery arrangements and implement the necessary changes internally to cost and charge for activities subject to cost recovery.

TEQSA will be employing a variety of approaches in relation to the anticipated challenges including:

  • utilising the new resources of its Higher Education Integrity Unit to address significant integrity threats such as academic or contract cheating, and collaboration with other agencies in relation to issues such as cyber security and foreign interference
  • paying close attention to the ongoing financial viability of individual providers as well as the sustainability of financial models across the sector. The agency will also finalise arrangements for the management of students’ records in the event of provider closure
  • strategies to improve the timeliness of regulatory decision making, to manage the workload to reflect the level of risk and to manage the impact of the revised cost recovery arrangements
  • continued collaboration with ASQA to seek de-regulation opportunities including minimising regulatory overlap
  • early consultation with the sector and other stakeholders to assist with reviewing the regulatory model used by TEQSA
  • implementation of a comprehensive workforce strategy to attract and retain the required level of qualified, skilled and experienced staff.

TEQSA’s stakeholders

TEQSA engages with a range of stakeholders across the domestic and international higher education sector, government and professions to achieve its purpose.

Department of Education, Skills and Employment

TEQSA will continue to work closely with the department on policy-related matters, and on data held by the department (such as student information), which can be used to deliver more timely inputs for TEQSA’s risk assessments.

TEQSA will also continue to provide advice to the department regarding initiatives such as the Australian Qualifications Framework and the role of professional accreditation bodies.

Higher Education Standards Panel

The responsibilities of the HESP include monitoring the operation of, and recommending changes to, the Higher Education Standards Framework (Threshold Standards) 2021. More recently, the HESP has been given the role of advising and making recommendations to TEQSA regarding its performance, including: approaches to deregulation; strategic objectives; the corporate plan; streamlining of activities; and resourcing requirements.

Australian Skills Quality Authority

TEQSA will continue to meet regularly with the Australian Skills Quality Authority (ASQA), particularly in relation to ‘dual sector’ providers, including in developing best-practice regulatory approaches and methods.

Education Regulators and Immigration Committee

TEQSA will continue to contribute to the multi-agency Education Regulators and Immigration Committee (ERIC), to help safeguard the integrity and sustainability of the international education sector. TEQSA’s focus will be on identifying and mitigating risks and influencing whole-of-government operational settings.


TEQSA will continue to develop its Student Expert Advisory Group (SEAG) to discuss risks to student interests and to receive feedback on TEQSA’s activity and initiatives.

Provider peak bodies

TEQSA will work closely with provider peak bodies as part of its partnership approach with the sector, in particular, in relation to the regulatory framework and TEQSA’s performance. Peak bodies are an important source of information about a provider’s experience of working with TEQSA, while also detecting emerging risks for the sector.

Industry professional bodies

TEQSA and industry professional accreditation bodies with links to the higher education sector have a mutual interest in maintaining and improving quality of the provision of Australian higher education.

TEQSA’s agreements with industry bodies facilitate the sharing of information and seek to reduce regulatory burden on higher education providers through joint and streamlined approaches to assessment.

Other stakeholders

TEQSA seeks to engage with its stakeholders at all levels through open, two-way communication; to reflect on feedback; and take action where appropriate. Our stakeholder engagement activities allow us to gain a greater understanding of the key issues in the higher education sector and help to build stakeholder capacity to meet regulatory requirements.

We have developed an engagement framework which outlines our commitment to working with stakeholders which includes a five-step stakeholder engagement model.

TEQSA’s capability and risk management

Governance and accountability

TEQSA’s Commissioners are appointed by the Minister for Education and are responsible for making regulatory decisions, setting strategic directions, monitoring risk in the sector and deciding on matters relating to the development of the agency’s quality assurance and regulatory framework. The Commissioners are also collectively the accountable authority for TEQSA under the Public Governance, Performance and Accountability Act 2013.

Subsection 154(1) of the TEQSA Act states that the CEO of TEQSA is responsible for the management and administration of TEQSA. Subsection 156(2) of the TEQSA Act states that for the purposes of the Public Service Act 1999, the CEO and staff of TEQSA together constitute a statutory agency, and the CEO is the head of that agency.

In order to deliver this corporate plan, TEQSA will need to continue to:

  • develop an effective plan to manage the workforce
  • continue to ensure access to an appropriate pool of subject matter experts
  • develop and maintain our information management and information technology systems
  • strengthen our relationships with providers and students.

Risk management

TEQSA’s Enterprise Risk Management Policy and framework identifies and addresses material risks relating to its functions, internal administration and stakeholder relationships. The framework is made up of a risk register, risk appetite statements, and accompanying controls.

TEQSA’s Audit and Risk Committee provides independent assurance to the Accountable Authority on TEQSA’s financial and non-financial performance reporting responsibilities, risk oversight and systems of internal control. This includes overseeing the internal audit program to ensure alignment with TEQSA’s risk profile.

During 2021-22, TEQSA will be focused on developing the agency’s risk culture, in particular increasing staff and system risk capabilities, and enhancing the efficacy of internal controls such as those relating to fraud and anti-corruption. Our key risks, and the way we will manage these risks, are described in the context of each of our capability requirements.

Regulatory processes and approach

TEQSA’s regulatory processes and approach need to support TEQSA’s achievement of its objectives. Inadequate processes and approaches create risks that TEQSA may not be able to identify and respond to significant and emerging sector risks in an efficient or effective manner, that TEQSA’s timeframes for assessments will be inconsistent with statutory deadlines or expectations of the sector, and that Australia’s reputation for quality higher education will be undermined.

To continue to develop its processes and approach, and to manage these risks, TEQSA will focus on:

  1. implementation of a comprehensive compliance monitoring framework, supported by appropriate operational processes
  2. building on communication and liaison mechanisms with Australian and international regulatory bodies, and with providers, peak bodies, students, and other stakeholders, to ensure that TEQSA keeps abreast of key developments in the sector
  3. ensuring clear documentation and reporting of each stage of its assessment processes to the CEO and Commissioners
  4. continuing to review and improve its business processes to enhance clarity and efficiency, and to better target key risks.

Workforce planning and human resources

TEQSA employees are required to be highly skilled with a wide range of knowledge and expertise in higher education, quality assurance, regulation, risk assessment and public sector administration. TEQSA seeks to be an employer of choice, offering employees diverse and challenging work that embraces innovation, diversity and agility.

Our workforce consists of specialist regulatory operations staff, as well as staff working in a range of functions that support our core regulatory capability and operations. These functions include policy and sector analysis, legal advice, risk analysis, information management, communications, stakeholder liaison, governance, information and communication technology, human resources, and finance.

TEQSA’s key risks regarding workforce planning and human resources are that:

  1. it will not be able to attract, retain or effectively manage the required level of suitably qualified, skilled, and experienced staff
  2. staff individual and/or collective health and wellbeing does not support positive operational outcomes, particularly in the context of the COVID-19 pandemic.

To meet its capability requirements and to address the identified risks, workforce planning and human resource management over 2021-22 will focus on formalising operational workforce planning, development of a comprehensive workforce strategy for 2021-25 and the development and implementation of an agency culture plan.

We will promote opportunities to:

  • equip staff with transferable skills through development opportunities, through a commitment to constant skill renewal, and by building a lifelong learning culture
  • strengthen stakeholder relationships through improved engagement and performance outcomes
  • better integrate our systems and processes with technology
  • increase diversity of thought through an inclusive workforce that leverages the benefits of flexible working
  • work collaboratively within the APS and the higher education sector.

TEQSA external experts

In undertaking regulatory assessments, TEQSA engages external experts in a range of discipline areas. These expert assignments are predominantly for regulatory operations in the areas of course accreditation and registration applications.

TEQSA also engages experts to provide and develop advice on thematic issues of relevance to the sector, such as online learning and academic integrity.

During 2021-22, we will continuously review and manage our Register of TEQSA Experts to ensure appropriate diversity, level and areas of expertise across TEQSA’s quality assurance and regulatory priorities, in line with our risk assessments. This includes updating the public register of Experts biannually to ensure transparency.

To address the risk that the publication of the Register could compromise the independence of experts used by TEQSA, conflicts of interest are managed by case managers through an established process.

Information and Communications Technology and Information Management capability

Timely access to, and appropriate use of, trusted data and supporting information and communications technology are required by TEQSA for informed decision making, and to enable innovation and support high quality regulation. It is also critical in the context of the increased emphasis on remote working caused by the COVID-19 pandemic.

The key risks in this area are that:

  • TEQSA’s framework to identify, classify and management information assets may not be adequate
  • TEQSA may not be able to deliver adequate ICT services to allow it to effectively perform its functions
  • information systems are compromised as a consequence of inadequate or ineffective security measures.

To manage these risks, and to ensure that TEQSA has the capability it requires, TEQSA’s information management priorities include:

  • integrating existing data systems
  • implementing a records management system for the agency and for students records for closed providers
  • replacement of the case management system
  • undertaking an Independent Registered Assessors Program (IRAP) Assessment to review security controls and implement improvements
  • developing an analytics and predictive capacity for monitoring the sector.

TEQSA digital communications

TEQSA makes use of a range of digital communication channels to promote and support good practice, improve compliance and enhance quality. These include the TEQSA website, social media (Twitter, LinkedIn) and e-newsletters. TEQSA’s digital products are targeted at key audiences including students, providers and academics, as well as media, peak bodies, government agencies and partner agencies in other jurisdictions.

During 2021-22, TEQSA will upgrade the website to the latest version of GovCMS, ensuring the site’s continued functionality while improving the user experience and meeting higher accessibility standards. To support communications with students around academic integrity and other priorities, TEQSA will build upon the student communications framework and strategy established in 2019-20. In addition, to improve security and the user experience, TEQSA will investigate options to upgrade its email newsletter management system. TEQSA aims to increase its social media followers by 15 per cent during the period.

Legal capability

TEQSA operates in an evolving statutory framework, with important amendments to the TEQSA Act, ESOS Act and subordinate legislation. Those amendments include the expansion of the Tuition Protection Service, the prohibition of contract cheating, reforms to provider categories and the management of student records. TEQSA is also required to manage a wide range of compliance obligations as a Commonwealth agency, including in relation to its resource management, human resources, privacy and accountability obligations.

In 2021-22, TEQSA’s Legal Group will work closely with its Commissioners, CEO and other operational groups to ensure that its capabilities reflect the needs of the agency, particularly in the context of the additional responsibilities in relation to commercial academic cheating, management of student records and reforms to provider categories. The Legal Group will also support the ongoing evolution of TEQSA’s approach to regulation and quality assurance.