The TEQSA case studies below show the four ways a registration application most often goes wrong: a governing body that exists on paper, a staffing profile that cannot deliver the course at its AQF level, a course pitched at the wrong level, and financial projections that do not survive a stress test. In each case the request for further information asked a predictable question, and the fix was available months earlier if anyone had looked.
The four cases are anonymised composites, each combining features of several providers I have advised over fifteen years of TEQSA registration work, with details altered so that no provider is identifiable.
Why TEQSA case studies teach more than the standards do
The Threshold Standards are short and abstract. Standard 6.1 says a governing body must have the independence and expertise to direct the provider; it does not say what an assessor concludes when the only independent director was appointed a fortnight before lodgement. Cases fill that gap by showing how a weakness is read, what the regulator asks next, and what a credible answer looks like. Our summary of common mistakes in TEQSA applications lists the errors; this article shows them happening.
Case one: the board that met for the first time after lodgement
A prospective provider, owned by a couple who had run a registered training organisation, lodged an application with a constitution, a board charter and a policy suite adopted "by resolution of the board." The board consisted of the two owners and one independent director; the academic board had terms of reference and no members.
The request for further information asked for twelve months of board minutes, evidence of the independent director's induction and attendance, and the minutes at which each policy was adopted. There were none, because the board had not met and the policies had been adopted by circular resolution on a single day.
The fix took six months: two further independent directors with higher education experience, an academic board with external academic members, a run of real meetings with real papers, and re-adoption of every policy with a recorded discussion. The application that eventually succeeded was substantially the same set of documents with a governance record behind them. The pattern is described more fully in our article on governance mistakes that stall TEQSA applications.
Case two: the master's degree taught by bachelor graduates
A provider seeking to add an AQF level 9 master's course listed a teaching team whose highest qualifications were, with one exception, at bachelor and graduate diploma level. The course proposal argued that industry currency was the relevant expertise for a professionally oriented degree.
TEQSA's request went to Standard 3.2, which requires academic staff to be qualified to at least one AQF level above the course they teach, or to hold equivalent professional experience, and to be active in scholarship. Assessors asked for a staffing matrix mapping each unit to its staff, the basis on which each was considered qualified, and their scholarship over the preceding three years. The provider had no equivalence policy and no scholarship record. The fix was an equivalence framework approved by the academic board, two doctorally qualified unit coordinators, and a funded scholarship plan. The industry-currency argument is legitimate, but only when a policy defines it and a record applies it.
Case three: the diploma dressed as a bachelor degree
A provider with a strong reputation in a creative field proposed a three-year bachelor degree whose unit outlines, learning outcomes and assessment tasks had been carried across from an AQF level 5 diploma it delivered as a registered training organisation, with the units lengthened and multiplied.
The request for further information asked the provider to map the course learning outcomes to the AQF level 7 descriptors, to explain how the assessment tasks required students to demonstrate broad and coherent theoretical knowledge and independent judgment, and to show where the course was benchmarked against comparable bachelor degrees. The mapping revealed the problem: almost every task tested technical competence, and none required the analysis or critical evaluation the level 7 descriptor describes. The fix was a redesign led by an external academic in the discipline, a new capstone, revised final-year assessment, and an external course review before the academic board re-approved it. It took the best part of a year and could have been done before lodgement for a fraction of the cost.
Case four: the projections built on full enrolment
A prospective provider lodged a five-year financial model showing profitability from year two, based on enrolments that assumed every course would fill at its cap from the first intake. Working capital came from a director's personal loan, and there was no teach-out provision.
TEQSA asked, under Standard 6.2, for sensitivity analysis at fifty and seventy per cent of projected enrolments, evidence of the loan's terms and the director's capacity to fund it, and a costed teach-out plan. Under the lower scenarios the provider was insolvent by the end of year one. The fix was a revised model with staged course launches, a capital commitment documented in a shareholder agreement, and a teach-out arrangement with another registered provider. TEQSA's application guide for prospective providers describes the financial evidence expected; a single optimistic scenario is read as an absence of planning, not as confidence.
What the four cases have in common
In every case the document set was complete and the operation behind it was not: the board had not met, the staff had not been qualified against a policy, the course had not been designed at its level, the finances had not been tested. TEQSA's requests did not ask for more documents; they asked for evidence of things happening. That is the practical meaning of self-assurance, and it is why the fastest application is the one that is true before it is lodged. Our review of recent TEQSA registration outcomes and decisions shows the same pattern in the published record.
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Frequently asked questions
Are these TEQSA case studies real providers?
They are anonymised composites, each combining features of several providers I have advised, with details altered so that no provider is identifiable. TEQSA's own published decisions are on the National Register.
What does a request for further information usually ask for?
Evidence that something is happening rather than more documents: minutes, staffing matrices, learning outcome mappings, sensitivity analyses and records of decisions by the governing body or academic board.
Can industry experience substitute for a higher qualification?
Yes, under Standard 3.2, but only where the provider has an approved equivalence policy, applies it case by case with a written record, and can show the staff member is engaged in scholarship.
How long do these fixes take?
In my experience between six months and a year, because each depends on real events occurring: meetings held, staff appointed, a course redesigned and reviewed, or a capital commitment documented.
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.