To register a masters degree with TEQSA you apply for course accreditation of an AQF level 9 qualification, and the application succeeds or fails on five things: whether the learning outcomes genuinely meet the level 9 descriptor, whether the volume of learning and entry pathways match the AQF's rules for masters, whether the course contains a real research or capstone component, whether the staff are qualified at least one level higher or have equivalent standing, and whether the design has been benchmarked against comparable masters degrees. Providers who hold self-accrediting authority in the relevant field can approve the course themselves; everyone else lodges it with the regulator.
This article sets out what a level 9 application must show and describes the most common way I have seen it fail, which is a bachelor-level course dressed as a masters. It draws on fifteen years of TEQSA course accreditation work with private providers, and it assumes you have already read our general guide to course design for TEQSA accreditation.
A note on terminology: accreditation, not registration
Strictly, TEQSA registers providers and accredits courses. A provider searching for how to register masters degree TEQSA-accredited offerings is really asking about course accreditation under Part 3 of the TEQSA Act, and the assessment is made against the Higher Education Standards Framework (Threshold Standards) 2021. The distinction matters in practice because a provider must already be registered, or be applying for registration at the same time, before a masters degree can be accredited.
The fees follow the distinction. For a registered provider the 2026 substantive course accreditation fee is $19,100 per course, or $4,800 for a nested related course. For a prospective provider accrediting courses alongside initial registration the substantive fee is $44,700 per course, according to TEQSA's application-based fees schedule. Fees exclude GST and are not refundable.
What does the AQF level 9 descriptor actually require?
The AQF level descriptors describe level 9 graduates as having advanced and integrated understanding of a complex body of knowledge in one or more disciplines, together with expert cognitive and technical skills to investigate, analyse and synthesise complex information, generate and evaluate complex ideas, and apply that knowledge with creativity and initiative to new situations in professional practice or scholarship. The descriptor also requires the ability to plan and execute a substantial research-based project, capstone experience or piece of scholarship.
Assessors read course learning outcomes against those words. In my experience the level 9 outcomes that fail are the ones that could sit unchanged in a bachelor degree: demonstrate knowledge of, apply techniques to, communicate effectively with. Level 9 language is about integration, evaluation, autonomy and the generation of new understanding, and the assessment tasks have to require those things rather than merely mention them in the rubric. My article on AQF levels for course designers sets out how the descriptors escalate from level 7 to 9.
Volume of learning and entry pathways
The AQF gives a masters (coursework) a volume of learning of one to two years, and the length depends on what the student brings. The framework's guidance is that the two-year form follows a level 7 bachelor degree, a shorter form follows a level 8 qualification or a four-year bachelor in the same discipline, and an extended masters may run to three or four years where professional registration requires it. TEQSA reads the entry rules and the duration together, and the two must reconcile.
This is where the most common design error appears. A provider offers a one-year masters, admits students straight from a three-year bachelor in a different field, and describes the result as a level 9 qualification. The volume of learning does not support the claim, and no amount of good teaching fixes the arithmetic. The remedy is either to require the appropriate prior learning at entry, to lengthen the course, or to nest a graduate certificate and graduate diploma so that each entry point has a defensible volume of learning attached to it. Nested awards must each stand on their own, and each attracts its own accreditation fee.
The research component and how TEQSA reads it
A coursework masters does not need to be a research degree, but it does need the substantial research-based project, capstone or scholarship that the descriptor requires. Standard 3.1 of the Threshold Standards requires course content and learning activities to engage with advanced knowledge and inquiry consistent with the level of study, and assessors look for where in the course that engagement is assessed.
In my experience a single reflective essay in the final unit does not satisfy them. What does is an identifiable component, typically a research methods unit followed by a supervised project, industry investigation or capstone, in which the student frames a question, gathers and analyses evidence, and produces work that could be judged for its contribution. The application should show the supervision arrangements, the assessment criteria and how ethics approval is handled where human participants are involved. Where the provider has no research activity of its own, the application needs to explain how staff will supervise credibly, which brings us to staffing.
Doctoral-qualified staff and the equivalence test
Standard 3.2 requires academic staff to hold a qualification in a relevant discipline at least one level higher than the course they teach, or to have equivalent relevant academic, professional or practice-based experience. For a level 9 course that means doctoral qualifications, and a masters degree taught entirely by masters-qualified staff will draw a request for further information on every unit.
Equivalence is a genuine route, and TEQSA accepts it, but it must be argued person by person. A practitioner with twenty years of senior professional practice, a record of published or industry-recognised work and experience supervising projects can be equivalent for a professional masters. A practitioner with a good job title is not. The application should include a staffing matrix that lists every unit, the staff who will teach and supervise it, their qualification, and where equivalence is claimed, the evidence for it. In my experience this matrix is the first document assessors open for a level 9 application.
Benchmarking against comparable masters degrees
Standard 5.1 requires that a course's design and learning outcomes be informed by external referencing and benchmarking. For a masters degree that means identifying two or three comparable level 9 courses at other providers, comparing structure, duration, entry requirements, learning outcomes and assessment, and recording where the proposed course differs and why. External academic review of the design, by someone with standing in the discipline and no connection to the provider, is the other half of the evidence.
The academic board must then consider the benchmarking and the reviewer's report before it approves the course. This is the non-delegation principle applied to course accreditation: a consultant or a course writer can prepare the analysis, but the academic board decides, and the minutes must show that it read the reviewer's concerns and either resolved them or explained why it did not. Our article on what TEQSA looks for in a new course describes how assessors read that approval record.
The inflated masters trap
Every year I see the same course arrive under a new name: a level 7 curriculum with a research methods unit added, a masters title on the cover, and a one-year duration chosen for the market rather than the learning. The staff are masters-qualified, the entry requirement is any bachelor degree, and the learning outcomes have been revised by replacing "apply" with "critically apply." TEQSA recognises it immediately, and the request for further information that follows usually asks for the level 9 mapping, the staffing matrix and the volume of learning rationale together.
The trap is expensive because it cannot be fixed by rewriting. The course has to be redesigned, the staff have to be recruited, and the cycle of design, external review and academic board approval, which in my experience takes three to four months, has to be run again. Providers who want to register masters degree TEQSA-accredited courses without that detour should test the design against the level 9 descriptor before anything else is written.
What I tell providers planning to register a masters degree with TEQSA
Start from the descriptor and the volume of learning, not from the market, and reconcile the duration to the entry pathways. Build the research component as an identifiable, supervised piece of work. Recruit or contract doctoral-qualified staff before you lodge, and argue equivalence carefully where you cannot. Benchmark, obtain external review, and let the academic board genuinely decide. A provider that does those things will find that to register masters degree TEQSA-approved courses is a matter of evidence rather than persuasion, which is the only footing on which an application should ever stand.
Download the New Course Readiness Checklist
— a standard-by-standard check for AQF level 9 course applications, drawn from our course accreditation work with private providers. Get the checklist
Want the full article?
Enter your email for free access to the rest of this guide and our TEQSA resource library.
Frequently asked questions
Can a private provider offer a masters degree in Australia?
Yes. Any registered higher education provider can apply to TEQSA for accreditation of an AQF level 9 course, and a provider with self-accrediting authority in the relevant field and level can approve it through its own academic board.
How long must a masters degree be under the AQF?
A masters (coursework) has a volume of learning of one to two years, depending on the entry qualification. Two years typically follows a level 7 bachelor degree, with shorter forms following a level 8 qualification or a four-year bachelor in the same discipline.
Do all staff teaching a masters degree need a PhD?
Standard 3.2 requires a qualification at least one level higher than the course, so a doctorate, or equivalent relevant academic, professional or practice-based experience. Equivalence must be evidenced for each person rather than asserted for the group.
What is the accreditation fee for a masters degree?
In 2026 a registered provider pays a substantive course accreditation fee of $19,100 per course, or $4,800 for a nested related course. A prospective provider accrediting courses with initial registration pays $44,700 per course, excluding GST.
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.