TEQSA vs CRICOS comes down to this: TEQSA registration and course accreditation, under the TEQSA Act 2011, permit you to operate as a higher education provider and confer AQF awards; CRICOS registration, under the ESOS Act 2000, permits you to enrol students who hold a student visa. The first is about whether you are a legitimate higher education institution. The second is about whether you may offer your courses to overseas students studying in Australia. You need the first before you can apply for the second, and holding one says nothing about whether you hold the other.
This article sets out the two regimes side by side: the legislation, the registers, what each permits, the sequence, the fees, the renewal cycles, who assesses what, and the confusions I see most often after fifteen years of TEQSA and CRICOS work with private providers.
Two Acts, two purposes
The Tertiary Education Quality and Standards Agency Act 2011 established TEQSA as the national regulator of higher education. Registration under Part 3 of that Act, and accreditation of courses where the provider lacks self-accrediting authority, are the mechanisms by which an entity is recognised as a higher education provider and its awards as AQF qualifications. The standard applied is the Higher Education Standards Framework (Threshold Standards) 2021, and the concern is academic quality, governance, and the interests of students generally.
The Education Services for Overseas Students Act 2000 is consumer protection legislation for a specific group of students. It exists because a student who has moved countries on the strength of an enrolment is exposed in ways a domestic student is not, and because Australia's reputation as a destination depends on those students being protected. The standard applied is the National Code 2018, together with ESOS requirements on tuition protection and reporting. The concern is marketing and recruitment, agents, written agreements, student support, progress and attendance, and the provider's financial capacity to see enrolled students through.
Two registers, and what appears on each
TEQSA maintains the National Register of Higher Education Providers. An entry records the provider, its category, its registration period and conditions, and each accredited course with its AQF level and accreditation period. If a provider is not on the National Register it is not a higher education provider in Australia, whatever its marketing says.
CRICOS, the Commonwealth Register of Institutions and Courses for Overseas Students, is a separate register with its own provider codes and course codes. An entry records the provider, the courses it may offer to overseas students, the locations at which it may offer them and its approved capacity. A student visa application refers to a CRICOS course code, not to the National Register, and a course that is accredited by TEQSA but not on CRICOS cannot be offered to a student visa holder.
The two registers are maintained by different systems and updated separately. A course renamed on the National Register does not rename itself on CRICOS. In my experience the mismatch between the two is one of the most common findings when a provider's records are examined, and it is entirely avoidable.
Who assesses what
For higher education providers TEQSA is the ESOS agency as well as the higher education regulator, so both applications go to the same organisation. That leads providers to assume they are one process. They are not. The registration and accreditation assessment is conducted against the Threshold Standards; the CRICOS assessment is conducted against the National Code and the ESOS Act, by staff applying different criteria, and the CRICOS assessment still uses Confirmed Evidence Tables even though those have been retired for higher education registration.
Vocational providers deal with ASQA for their RTO registration and ASQA as ESOS agency for CRICOS. A dual-sector provider can therefore find itself with TEQSA for its higher education courses and CRICOS entries and ASQA for its VET courses and CRICOS entries, which is a genuine complication and a reason to keep the two registers reconciled. Our article on the accreditation journey from CRICOS to TEQSA walks through that path for VET providers moving up.
TEQSA vs CRICOS in sequence
The order is fixed. A new provider must be registered by TEQSA, with at least one accredited course, before it can apply for CRICOS registration. TEQSA's guidance on applying for CRICOS indicates that providers typically lodge about three months after registration is approved, that a decision on a high-quality application usually takes three to six months, that providers have twenty-eight days to respond to any concerns raised, and that the CRICOS code is issued two to four weeks after approval.
The consequence for planning is the figure TEQSA itself publishes: international delivery at least thirty-five months after first engagement with the regulator, or twenty-nine months after the registration application is lodged. Providers that build a business case on international enrolments in year one have misunderstood the sequence, and the article on CRICOS registration after TEQSA explains how to plan around it.
Fees and renewal cycles
The 2026 fee schedules make the scale of each regime clear. Initial TEQSA registration costs $14,700 for the preliminary assessment and $112,100 for the substantive assessment, with course accreditation for a prospective provider at $6,000 and $44,700 per course. Initial CRICOS registration is $24,500, with additional locations at $1,900 to $9,600 and additional courses at $600 to $5,200. Discounts of up to seventy per cent apply to providers with fewer than 5,000 EFTSL, fees exclude GST and are not refundable, and TEQSA revises them periodically on a cost-recovery basis.
Renewal runs on separate clocks. TEQSA registration is granted for up to seven years, and a renewal application must be lodged at least 180 calendar days before it ends, at a fee of $66,000 to $113,000 without self-accrediting authority. CRICOS registration has its own period and its own renewal, at $13,600 to $27,500. A provider that lets the two periods drift apart will find itself in an almost continuous cycle of applications, and one of the first things I do with a new client is look at whether the renewal dates can be brought closer together over time.
Obligations that continue after registration
Both regimes impose ongoing obligations, and they differ. Under the TEQSA Act, section 29 requires notification of material changes within fourteen days of the provider becoming aware, and the Threshold Standards apply continuously in the present tense. Under ESOS, the provider must report enrolments, variations and defaults through PRISMS, contribute to the Tuition Protection Service, maintain written agreements compliant with the National Code, monitor course progress and attendance, and manage deferrals, suspensions and cancellations by the rules. The ESOS obligations of providers supporting international students are set out in a separate article.
A failure under one regime can affect the other. A National Code breach that raises questions about governance or student welfare is relevant to Standard 2.3 and Standard 6.2; a TEQSA condition on registration is relevant to whether CRICOS registration should continue. TEQSA reads both files.
The confusions I see most often
The first confusion is the word "accreditation". Under TEQSA it means the accreditation of a course as an AQF qualification. Providers sometimes speak of "CRICOS accreditation", which does not exist; CRICOS registers courses that have already been accredited. The second is assuming that a course on CRICOS is automatically current on the National Register, or vice versa, when each must be maintained separately.
The third is the belief that CRICOS is a formality once TEQSA registration is held. The National Code has eleven standards, each with its own evidence, and a provider with no experience of agents, written agreements or attendance monitoring will need to build that capability before applying. The fourth, and the most costly, is treating international enrolments as the launch market. TEQSA vs CRICOS is not a choice between two options; it is a sequence, and the second step cannot be rushed.
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Frequently asked questions
Can I apply for TEQSA registration and CRICOS at the same time?
No. CRICOS registration requires the provider to already be registered by TEQSA with at least one accredited course. Providers typically lodge the CRICOS application about three months after TEQSA registration is approved.
Is TEQSA the CRICOS regulator for higher education providers?
Yes. For higher education providers TEQSA acts as the ESOS agency and assesses CRICOS applications, but against the National Code 2018 and the ESOS Act rather than the Threshold Standards. ASQA performs the same role for vocational providers.
Do TEQSA and CRICOS registration expire at the same time?
Not necessarily. Each has its own registration period and renewal process and fee. Providers should track both dates and, where possible, work towards aligning them over successive renewals.
What happens if a course is on the National Register but not on CRICOS?
It can be offered to domestic students and to overseas students who are not on a student visa, but it cannot be offered to student visa holders until it is added to CRICOS.
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.