Academic integrity TEQSA compliance rests on Standard 5.2 of the Threshold Standards, which requires a provider to have policies and mechanisms that prevent, detect and address academic misconduct, to train staff and students in integrity, and to keep the whole arrangement under review. TEQSA does not assess integrity by reading the policy. It assesses whether the policy is operating, whether breaches are actually found and dealt with, and whether the academic board sees the results.
This article works through what that looks like for a private provider: the policy, the education, the detection, the contract cheating and generative AI risks, and the reporting that closes the loop. It draws on fifteen years of TEQSA registration and accreditation work, most of it with providers small enough that one integrity failure can define an assessment.
What Standard 5.2 actually requires
Standard 5.2 sits in Domain 5, Institutional Quality Assurance, of the Higher Education Standards Framework (Threshold Standards) 2021. It is written in the present tense. The provider has policies, it has mechanisms, students and staff are informed, breaches are addressed. That tense matters, because it means the evidence TEQSA is entitled to ask for is evidence of operation, not of existence.
TEQSA has published a guidance note on academic integrity, and it is worth reading closely. It is also worth remembering that guidance notes are not themselves Threshold Standards. They tell you what the regulator has found persuasive elsewhere. They do not tell you what the standard says, and an assessor testing your provider against Standard 5.2 is testing it against the legislative instrument, not the note.
The policy is the easy part
Every provider I have worked with has an academic integrity policy. Many of them are good. The trouble is that a policy is a promise, and Standard 5.2 is about whether the promise is kept. Assessors read the policy for what it commits the provider to, and then look for the records that show the commitment being honoured: the register of alleged breaches, the outcomes, the appeals, the trend over time.
In my experience the weakest point is the register. A provider with three hundred students and no recorded breaches in two years is not a provider with no misconduct. It is a provider whose detection is not working, or whose staff are handling matters informally and leaving no trail. TEQSA reads an empty register as a finding against the provider, not for it, and it is right to.
Education before detection
Standard 5.2 requires that students and staff are informed about academic integrity and about the consequences of breaching it. The minimum I would expect to show an assessor is an integrity module in orientation, an integrity statement in every unit outline, and a record that teaching staff have been trained in how to recognise and refer suspected misconduct.
The better providers go further. They teach referencing and source use inside the discipline rather than in a generic library session, they explain why integrity matters to the value of the qualification the student is paying for, and they treat a first minor breach as a teaching moment with a recorded educative outcome. That approach produces a register that shows a curve: many minor matters early in a course, fewer later. Assessors understand what that curve means.
Contract cheating and TEQSA's powers
Contract cheating is the risk that changed the regulatory setting. Since 2020 the TEQSA Act has prohibited providing or advertising academic cheating services to students at Australian providers (sections 114A and 114B), and section 127A allows TEQSA to seek injunctions against online locations that facilitate those services. TEQSA has used those powers to have cheating websites blocked by Australian internet providers.
None of that relieves the provider of its own obligations. Assessors expect a provider to know that its students are targeted by cheating services, to have assessment designs that make outsourcing harder, and to have staff who can recognise the signs of a purchased assignment. Our article on assessment integrity and TEQSA best practice deals with the design side. The governance side is simpler to state: the academic board should be able to say what the provider's exposure to contract cheating is and what it did about it this year.
Generative AI is now part of Standard 5.2
TEQSA's June 2024 request for information required every provider to lodge a credible institutional action plan, overseen by its governance, addressing the risk generative AI poses to award integrity. The request for information made clear that TEQSA would follow up plans that were absent or insufficient. In practice that means AI is now assessed as an integrity matter under Standard 5.2, alongside the assessment design standards.
The mistake I see most often is treating detection software as the plan. TEQSA has not endorsed detection tools as sufficient, and an integrity approach that rests on them will not survive a careful assessor. The sector pattern is program-level assurance, with secured assessment points where the provider can be confident the work is the student's own. Our articles on what TEQSA compliance officers want to see on AI use and on AI considerations in higher education go into that design in more depth.
What the academic board should receive
This is where academic integrity TEQSA assessments are most often won or lost. Standard 6.3 places academic integrity within the academic board's oversight, and an assessor will look for it in the board's papers. I advise clients that the board should receive, at least each semester, a report showing the number of alleged breaches by type and unit, the outcomes, any appeals, the time taken to resolve matters, and any pattern the report author can see.
The report should also carry an account of what has changed. If a unit produces a cluster of similar breaches, the board should see the assessment redesign that followed and, a semester later, whether it worked. Our guide to documenting and demonstrating assessment standards explains how that evidence chain is assembled. A board that receives integrity reports and minutes its response is doing exactly what Standard 5.2 and Standard 6.3 together describe.
Where academic integrity TEQSA assessments go wrong
Three failures recur in my experience. The first is separation: the integrity policy lives in student administration, the assessment policy lives with academic staff, and nobody joins them up. The second is informality: staff resolve matters quietly, the register stays empty, and the provider cannot show the standard operating. The third is delegation upwards: the board notes an annual statement that integrity is "well managed" and asks nothing.
Each is fixable in a semester. Put integrity on the academic board's standing agenda, make every referral go through the register, and require the report to say what changed. The record you build will do more for you at renewal than any policy document, because it shows the standard working rather than asserting that it exists.
My view after fifteen years
Academic integrity TEQSA compliance is not a policy exercise. It is a matter of whether a provider can find its own misconduct, deal with it consistently, learn from it, and show a governing body doing the same. The providers that struggle at assessment are almost never the ones with the most breaches. They are the ones with the least evidence.
Download the Darlo Policy Suite Index
— a map of the policies and registers TEQSA expects to see operating under Domains 1 to 7, drawn from our TEQSA registration and governance work with private providers. Get the index
Want the full article?
Enter your email for free access to the rest of this guide and our TEQSA resource library.
Frequently asked questions
Does TEQSA require detection software for academic integrity?
No. Standard 5.2 requires mechanisms to prevent, detect and address misconduct, but TEQSA has not endorsed any detection tool as sufficient. Assessors look for assessment design, staff training and a working breach process, with software as one input at most.
Is the TEQSA academic integrity guidance note binding?
No. Guidance notes describe what TEQSA has found persuasive but they are not Threshold Standards. A provider is assessed against Standard 5.2 of the legislative instrument, and the note is best used as a reading aid rather than a checklist.
What integrity reporting should the academic board receive?
At least each semester: alleged breaches by type and unit, outcomes, appeals, resolution times, any patterns, and what changed in response. The minutes should record the board's discussion and any actions it required.
Can TEQSA take action against contract cheating services directly?
Yes. Sections 114A and 114B of the TEQSA Act prohibit providing or advertising academic cheating services, and section 127A allows TEQSA to seek injunctions against online locations that facilitate them, which it has used to have websites blocked.
Dr Brendan Moloney is CEO of Darlo Higher Education, Australia's largest specialist TEQSA consultancy. He holds a PhD from the University of Melbourne, is a Cambridge University Press author on governance in higher education, and has advised private providers on registration and course accreditation for more than fifteen years.