The CRICOS TEQSA accreditation journey for higher education runs in one direction only: TEQSA registration and course accreditation come first, CRICOS registration comes afterwards, and international recruitment comes last. An operator who knows CRICOS from the VET or ELICOS world usually expects to lodge the two together, and cannot. There is no higher education CRICOS application without a registered higher education provider and an accredited course to attach it to.
This article is for that operator. It sets out the correct order, what CRICOS adds once TEQSA is the regulator rather than ASQA, and the whole path from idea to first international intake as I have walked it with clients in our TEQSA registration practice.
Why the order is TEQSA first and CRICOS second
Under the ESOS Act 2000, a provider can only be registered on CRICOS for a course if it is already approved to deliver that course to domestic students. For higher education, that approval is registration under Part 3 of the TEQSA Act and accreditation of the course under the Threshold Standards. TEQSA is the ESOS agency for higher education, so it administers both, but it administers them in sequence.
The practical consequence is that the CRICOS TEQSA accreditation journey has two applications with two fees and two assessment periods. The first is initial registration with concurrent course accreditation. The second is a CRICOS application lodged after the first is approved. TEQSA's own guidance says providers typically lodge the CRICOS application around three months after the registration decision, and that a high-quality CRICOS application is usually decided in three to six months, with a CRICOS code issued two to four weeks after approval. All of that is set out on TEQSA's page on how to apply for CRICOS registration.
The differences between the two registrations are unpacked in TEQSA accreditation vs CRICOS registration.
What CRICOS under TEQSA adds to a registered provider
An RTO operator already knows the National Code: written agreements, agent management, course progress monitoring, deferrals and cancellations, complaints and appeals. Those eleven standards do not change when the regulator changes. What changes is the evidence base they sit on.
TEQSA assesses a CRICOS application against the National Code and against the provider's capacity to support international students under Standards 2.2, 2.3 and 2.4 of the Threshold Standards, with particular attention to the wellbeing, safety and grievance arrangements a higher education cohort needs. It also looks at the financial position, because international revenue changes a provider's risk profile, and at whether the provider's recruitment materials match the accredited course. Confirmed Evidence Tables, retired for higher education registration, are still used for CRICOS, so the application is more structured than the self-assurance approach used for registration itself. The obligations that follow once students arrive are covered in supporting international students under TEQSA and ESOS.
The CRICOS TEQSA accreditation journey from idea to intake
Here is the journey as TEQSA describes it and as I have seen it run. Engagement with TEQSA begins at least six months before the registration application is lodged. Preparation of that application takes, in my experience, six to twelve months, including a course design, external review and academic board cycle of three to four months. The registration application then has a preliminary assessment within thirty days and a substantive assessment with a decision due within nine months of commencement, extendable by a further period of up to nine months.
After the registration decision the CRICOS application is prepared and lodged, typically about three months later, and decided in three to six months if it is complete. The CRICOS code follows within a month. TEQSA advises recruiting at least five months before delivery so that students can apply for visas at least eight weeks before the course starts. Put together, TEQSA's own estimate is that delivery to international students begins at least thirty-five months after first engagement, or twenty-nine months after the registration application.
In fifteen years I have not seen that compressed by much, and I have seen it stretched considerably by requests for further information at either stage. What happens after the registration decision is set out in more detail in CRICOS registration after TEQSA.
My advice: plan the second application while writing the first
The operators who move fastest along the CRICOS TEQSA accreditation journey are those who design the registration application with CRICOS in mind. That means the wellbeing, safety and grievance policies are written for an international cohort from the outset, the financial model includes the international revenue scenario and the Tuition Protection Service obligations, the agent management policy exists before it is needed, and the governing body has minuted its decision to seek CRICOS as part of its strategy.
Do not lodge the CRICOS application in a hurry to meet a recruitment target. A CRICOS application that draws concerns gives you twenty-eight days to respond, and a weak response delays the code and the intake. Build the second application from the evidence base of the first, lodge it complete, and the sequence runs as TEQSA describes it.
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Frequently asked questions
Can a new higher education provider apply for TEQSA registration and CRICOS at the same time?
No. CRICOS registration for a higher education course requires the provider to be registered and the course accredited first. The CRICOS application is lodged after the registration decision.
How long after TEQSA registration can international students start?
TEQSA estimates delivery to international students at least twenty-nine months after the registration application is lodged, allowing for the CRICOS assessment, code issue, recruitment and visa processing.
Does an RTO's existing CRICOS registration carry over to higher education?
No. CRICOS registration is course-specific and sits on the underlying approval. Higher education courses need TEQSA accreditation and a separate CRICOS application, even where the entity already holds CRICOS for VET courses.
What does a CRICOS application cost for a higher education provider?
TEQSA's published fee for initial CRICOS registration is $24,500, excluding GST and separate from the fees for registration and course accreditation.
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.