The blended learning TEQSA will accept is blended learning that can show the same outcomes, the same academic oversight and the same student support in the online half of the course as in the face-to-face half. The Threshold Standards are mode-neutral: they do not contain a separate set of rules for hybrid delivery, but they do require that every mode of delivery meets every relevant standard, and that is where hybrid courses are usually caught.
This article explains how the mode-neutral standards apply to hybrid courses, which sections assessors read most closely, and what evidence a part-online course has to carry. It draws on fifteen years of TEQSA registration and accreditation work with private providers, most of which now deliver something blended whether or not they call it that.
What does the Threshold Standards say about blended learning?
Nothing by name, which is the point. The Higher Education Standards Framework (Threshold Standards) 2021 refers throughout to "mode of delivery" and "place of study" without privileging any mode. Standard 3.1.4 requires that each course be designed to enable achievement of expected learning outcomes regardless of a student's place of study or the mode of delivery. Standard 1.3.6 requires equivalent opportunities for transition and progression irrespective of mode or place of study.
Read together, those two sentences are the whole test for a hybrid course. The provider has to show that a student who does two-thirds of a unit online reaches the same outcomes, with the same support, as a student who sits in the room. Assessors are asking whether the provider has designed for equivalence and can prove it. TEQSA's guidance notes on technology-enhanced learning are useful background, though guidance notes are not themselves Threshold Standards.
How do assessors read a hybrid course design?
The design specification under Standard 3.1.1 must state structure, duration and modes of delivery. The first mistake I see is a specification that says "blended" and stops there. Assessors want to know which components are online, which are on campus, whether the online components are synchronous or self-paced, and what the student does in each hour of the indicative workload.
The second thing they read is the alignment between assessment and mode. If a practical skill was assessed in a workshop, and the workshop moved online during redesign, the assessment method under Standard 1.4.3 must still be capable of confirming that outcome. A course assessed as if it were fully on campus signals that the blend was a delivery decision rather than a design decision. Our article on what to include in course design for TEQSA accreditation covers the specification in more detail.
Learning environment: Standard 2.1 applies online as well
Standard 2.1.1 requires facilities fit for their educational purpose that accommodate the numbers using them. Standard 2.1.2 requires secure, continuous access to electronic information and communication services for students and staff, allowing for reasonable maintenance outages. For a hybrid course the learning management system is a facility in that sense, and assessors treat it as one.
That means evidence of capacity, uptime and support, not just a licence. In my experience the useful documents are the LMS service agreement, the outage log, the helpdesk hours, and a short account of what happens when the platform fails during a timed assessment. Standard 3.3.3 adds that learning resources must not present unexpected barriers, costs or technology requirements, which means stating the hardware and bandwidth a student needs before they enrol. The broader digital quality picture is set out in our piece on TEQSA and online education.
Staffing and support in the online half
Standard 3.2.5 requires teaching staff to be accessible to students seeking individual assistance at a level consistent with the cohort's needs, and Standard 3.3.4 requires learning support consistent with mode of study, including arrangements for maintaining contact with off-campus students. The blended learning TEQSA assessors question is the version where the on-campus students get a tutor and the online students get a discussion forum nobody moderates.
Evidence here is operational: workload allocations that include online consultation time, a stated response-time commitment for online queries, records showing it is met, and a named academic responsible for the online cohort. Staff CVs should also show, under Standard 3.2.3(b), skills relevant to the modes of delivery, which usually means documented training in online pedagogy rather than an assumption that a good lecturer is a good online facilitator.
What engagement data does TEQSA expect from blended learning?
Standard 5.3 requires monitoring of student success and external referencing of cohort outcomes, and Standard 5.3.4(a) specifically asks for comparison across locations of delivery where applicable. For a hybrid course I read that as an expectation that the provider can separate its data by mode. Progression, attrition and grade distributions for the online-heavy students should be reported to the academic board alongside the on-campus figures.
Where the two diverge, the academic board's minutes should show the question being asked and something being done. That record is the single most persuasive item in a blended learning TEQSA application, because it shows equivalence being monitored rather than assumed. A provider that cannot split its data by mode has told the assessor it does not know whether Standard 1.3.6 is met. The direction of travel across the sector is discussed in our articles on how online learning is changing TEQSA accreditation and the future of distance education under TEQSA registration.
Design the blend, then evidence it
Blended delivery is not a regulatory problem. Undesigned blended delivery is. The providers I see move through accreditation cleanly are the ones whose course documents say precisely what happens online and in the room, whose assessments were built for the mode they run in, whose LMS is treated as infrastructure, and whose academic board sees mode-split data every study period. None of that is onerous once set up, and all of it is what the mode-neutral standards require.
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Frequently asked questions
Does TEQSA require separate accreditation for the online version of a course?
No. A course of study is accredited with its modes of delivery specified under Standard 3.1.1. If a provider adds a substantially new mode after accreditation, that is a change to the course that may need to be notified to TEQSA, and the provider should check the material change requirements before proceeding.
What proportion of a course can be delivered online in a blended model?
The Threshold Standards do not set a percentage. What matters is that learning outcomes are achievable regardless of mode under Standard 3.1.4 and that students have equivalent support and progression opportunities under Standard 1.3.6. International students on student visas are subject to separate limits on online study under the ESOS framework.
What evidence does TEQSA want about the learning management system?
Evidence that it is fit for purpose and reliable: capacity for the enrolled numbers, continuous secure access with only reasonable maintenance outages, user training, technical support arrangements, and a plan for platform failure during assessment. A licence alone does not demonstrate Standard 2.1.2.
Do online teaching staff need different qualifications?
The qualification requirement in Standard 3.2.3(c) is the same for every mode. Standard 3.2.3(b) additionally requires skills in teaching and assessment relevant to the modes of delivery, so staff teaching online should be able to show training or experience in online pedagogy.
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.