Indigenous Australians higher education participation remains well below population share: Aboriginal and Torres Strait Islander students made up 2.1 per cent of domestic undergraduate enrolments in 2021 against 3.4 per cent of the population aged 15 to 64, and 1.4 per cent of completions. For a registered provider that gap is not only a policy problem; Standard 2.2 of the Threshold Standards requires specific consideration of Aboriginal and Torres Strait Islander recruitment, admission, participation and completion, and TEQSA asks private providers to evidence it as much as universities.
This article sets out the figures, what the standard requires, and what I have seen work in fifteen years of preparing private providers for TEQSA registration and renewal, where the Indigenous participation section is too often a single paragraph copied from a university's website.
What the Indigenous Australians higher education data shows
The Department of Education's equity parity targets paper, prepared for the Universities Accord, records that First Nations students rose from 1.3 per cent of domestic undergraduate enrolments in 2008 to 2.1 per cent in 2021, against a population share of 3.4 per cent. The completion figure of 1.4 per cent shows that the gap widens between entry and graduation, which is the part of the problem a provider can most directly affect.
The broader tertiary picture is measured under the National Agreement on Closing the Gap. Target 6 is that by 2031, 70 per cent of Aboriginal and Torres Strait Islander people aged 25 to 34 will have completed a tertiary qualification at Certificate III or above. The Australian Institute of Health and Welfare reports the figure at 47 per cent in 2021 and below the trajectory needed to meet the target.
What Standard 2.2 actually requires
Standard 2.2.1 of the Threshold Standards requires institutional policies, practices and approaches to teaching and learning that accommodate student diversity and promote participation. Standard 2.2.2 is the one written for this topic: it requires specific consideration to be given to the recruitment, admission, participation and completion of Aboriginal and Torres Strait Islander peoples. A general equity policy that lists Indigenous students among nine cohorts does not meet a standard that singles them out.
TEQSA reads 2.2.2 alongside Standard 1.3, which requires support for transition and progression, and Standard 6.2, which requires the governing body to monitor how the provider is performing. Assessors do not expect a private provider with three hundred students to run a university's Indigenous education unit. They expect a considered answer to the question of what this provider, in this location, offering these courses, has done and will do, and evidence that the answer is being carried out.
Cultural safety is an operational question, not a statement
The phrase "culturally safe" appears in most applications I read. What assessors look for is the mechanism behind it. In my experience that means a named person or committee with responsibility for Indigenous student matters, a relationship with a local Aboriginal community organisation or elder that is documented rather than asserted, staff development on cultural safety with attendance records, and an admission pathway that recognises non-standard preparation without lowering the AQF outcome.
It also means data. A provider that cannot say how many Aboriginal and Torres Strait Islander students it has enrolled, retained and graduated cannot show it has given the matter specific consideration, because it has nothing to consider. The student management system should collect Indigenous status on enrolment, the academic board should see the figures at least annually, and where the numbers are small the report should say so rather than omit the item. The student support functions that make this real are described in our article on the role of student services and support.
Indigenous governance in a private provider
Universities are expected to have Indigenous representation in their governance, and the Universities Accord process has pressed that further. The Threshold Standards do not impose a governance composition requirement on a private provider, and I would not tell a client that TEQSA requires an Indigenous board member. What TEQSA does look for is that the governing body has turned its mind to the question and can show where the advice comes from.
For a small provider the credible arrangements I have seen are an Indigenous advisory group that reports to the academic board, an external Indigenous academic on the course advisory committee for a course with relevant content, or a formal agreement with a community organisation that reviews the provider's approach. Assessors ask who was consulted, when, and what changed as a result.
Where private providers fall short at renewal
At renewal of registration the question changes from "what is your plan" to "what happened". The pattern I see most often is a policy adopted before initial registration, no Indigenous enrolments recorded because the data was never collected, and no discussion in the academic board minutes across the registration period. That record does not show non-compliance with a number; it shows an absence of consideration, which is what 2.2.2 prohibits.
The providers that do well are not necessarily those with the most Indigenous students. They are the ones that can show the outcome data, the support offered, the review of what did and did not work, and the decision that followed. That is the same monitoring, review and improvement cycle Standard 5.3 requires everywhere else, and it is discussed further in our article on TEQSA standards and student outcomes.
My view on doing this properly
Indigenous Australians higher education participation is one of the few areas where the regulator's expectation, the public interest and the provider's own interest point the same way. Treat it as an operational commitment with a data trail, not as a paragraph in a policy, and the standard takes care of itself.
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Frequently asked questions
What does Standard 2.2.2 of the Threshold Standards require?
It requires a provider to give specific consideration to the recruitment, admission, participation and completion of Aboriginal and Torres Strait Islander peoples. TEQSA reads it as requiring evidence of that consideration in operation, not a general equity policy.
Must a private provider have an Indigenous board member?
No. The Threshold Standards do not prescribe board composition on this point. TEQSA looks for evidence that the governing body has considered Indigenous participation and can show where its advice comes from, such as an advisory group or a documented community relationship.
What is the Indigenous participation rate in Australian higher education?
Aboriginal and Torres Strait Islander students made up 2.1 per cent of domestic undergraduate enrolments in 2021, against 3.4 per cent of the population aged 15 to 64, according to the Department of Education's parity targets paper prepared for the Universities Accord.
What evidence does TEQSA look for on Indigenous students at renewal?
Enrolment, retention and completion data for Aboriginal and Torres Strait Islander students, the support and admission pathways offered, records of consultation, and academic board minutes showing the figures were reviewed and acted on across the registration period.
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.