The benchmarking higher education TEQSA requires is set out in Standard 5.3.4 of the Threshold Standards: regular external referencing of student cohort success against comparable courses elsewhere, covering progression, attrition and completion rates, and the assessment methods and grading of selected units. It is more than a compliance task because it is the only mechanism in the standards that tests a provider's own judgement about quality, and TEQSA reads the results to see whether the academic board acted on them.
This article explains what to benchmark, with whom, how to run the exercise, and how to turn findings into decisions the regulator can see, drawing on fifteen years of TEQSA registration and accreditation work.
What does Standard 5.3.4 actually require?
The Higher Education Standards Framework (Threshold Standards) 2021 says at 5.3.4 that review and improvement activities include regular external referencing of the success of student cohorts against comparable courses of study. It then specifies two things. Paragraph (a) is analysis of progression rates, attrition rates, completion times and rates, comparing locations of delivery where applicable. Paragraph (b) is the assessment methods and grading of students' achievement of learning outcomes for selected units within courses.
Three words in that standard do most of the work: "regular" means a cycle rather than an event before renewal, "external" means the comparator is outside the provider, and "comparable" means a course of similar level, field and, ideally, cohort. A provider that compares its business diploma with a university's research masters has not benchmarked anything. Standard 1.4.1 adds that learning outcomes must be informed by national and international comparators, which is benchmarking at the design stage. TEQSA's guidance notes expand on this, though guidance notes are not themselves Threshold Standards.
What should a private provider benchmark?
Start with the outcomes data in paragraph (a), because it is the easier half: progression, attrition and completion for each course, split by cohort and by location or mode where the provider has more than one. The comparator can be published national data for the field, a peer provider's figures under a benchmarking agreement, or both. The point is to know whether a 25 per cent first-year attrition rate is normal for the field or a warning.
Then the assessment half in paragraph (b), which is where the benchmarking higher education TEQSA assessors examine most carefully. Select two or three units per course per cycle and exchange assessment tasks, rubrics and marked samples with a peer institution teaching a comparable unit. Each side reviews the other's samples blind and reports whether the grades reflect the standard claimed. Course design can be benchmarked too, and that feeds the review process described in our article on course reviews and continuous improvement for TEQSA.
Who do you benchmark with?
This is the question that stalls most private providers, because they assume a university will not engage with them. In my experience that assumption is often wrong at discipline level: an academic teaching a comparable unit is usually willing to exchange samples with a peer where the exchange is reciprocal and the workload contained. Peer private providers in the same field are the other natural partners.
What matters to TEQSA is that the partner is genuinely comparable and independent. A benchmarking agreement with a provider under common ownership, or whose staff also teach at yours, does not meet the external requirement in substance. Assessors will ask who the partner is and how the courses compare, and a thin answer undermines every result that follows.
How to run the exercise so it produces evidence
Document the design before you start: which courses, which units, what comparator, what method, who reviews and when the results go to the academic board. A written benchmarking plan approved by the academic board is itself evidence under 5.3.4, and in my experience assessors read it before any results. Then run the exchange, collect the reviewer reports and data comparison, and write a short analysis of what was found and what it means.
The analysis is where most providers stop, and it is the wrong place to stop. Standard 5.3 is about monitoring, review and improvement, and a report that sits in a folder shows monitoring but not improvement. Our guide to building an evidence-based course review report for TEQSA shows how the benchmarking results feed the course review.
How TEQSA reads benchmarking in higher education
Assessors look for three things in sequence. The results themselves, to see whether outcomes and grading sit within a reasonable range of comparable courses. The academic board minutes where the results were tabled, to see whether anyone asked a question. And what changed: a rubric revised, a unit redesigned, an admission threshold adjusted, a support intervention introduced, and whether the next cycle showed the change working.
That third step is what makes benchmarking higher education TEQSA can trust, and it is the reason I tell clients to benchmark for their own sake before the regulator's. A provider that found its grading a half-band generous compared with peers, tightened moderation, and can show the distribution moving is demonstrating exactly the self-assurance TEQSA asks for. A provider whose results were favourable has still shown the loop working, provided the minutes record the board considering them. The wider evidence picture is covered in our article on evidence of student learning and what TEQSA expects.
Benchmarking is how you find out whether you are right
Every provider believes its standards are sound. Benchmarking is the only part of the Threshold Standards that tests that belief against someone else's judgement, and the providers who do it seriously are the ones who stop being surprised at renewal. It costs some academic time and a reciprocal relationship with a peer. It buys knowledge of where your courses actually sit, a record that the academic board acts on evidence, and an answer ready for the first question an assessor asks about Standard 5.3.
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Frequently asked questions
How often does TEQSA expect benchmarking to occur?
Standard 5.3.4 says "regular" without setting a frequency. In my experience an annual cycle covering outcomes data for every course, and assessment benchmarking of two or three units per course across a review period, is what assessors regard as regular.
Can a private provider benchmark with a university?
Yes, and many do at discipline level. What matters is that the comparator course is comparable in level and field and that the partner is independent of the provider. A benchmarking partner under common ownership or with shared staff does not satisfy the external requirement in substance.
What data does Standard 5.3.4 require?
Paragraph (a) requires analysis of progression, attrition, completion times and rates against comparable courses, comparing delivery locations where applicable. Paragraph (b) requires external referencing of assessment methods and grading for selected units of study.
Is a benchmarking report enough on its own?
No. TEQSA reads benchmarking as part of monitoring, review and improvement under Standard 5.3, so assessors expect to see the results considered by the academic board and any resulting changes to courses, assessment or support, followed by evidence of whether those changes worked.
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.