The global education market Australian providers can reach divides into four routes, and each needs a different regulatory permission: recruiting international students onshore requires CRICOS registration and an allocation under the government's managed growth settings, an offshore campus requires TEQSA's oversight of delivery outside Australia, a transnational partnership engages Standard 5.4 and the material change rules, and online export to students who never enter Australia needs no CRICOS registration but every other standard still applies. The opportunity is real, but the conditions on each route are tighter than they were three years ago.
This article describes the four routes, what each requires, and how current market settings affect the choice. It draws on fifteen years of TEQSA registration and CRICOS work with private providers.
Onshore international students under managed growth
The traditional route is to recruit students to study in Australia on student visas. That requires registration on CRICOS under the Education Services for Overseas Students Act 2000 and compliance with the National Code 2018, and TEQSA's advice is to apply for CRICOS after higher education registration is granted, with a decision on a high-quality application usually taking three to six months.
Since 2025 the volume of that route has been managed. The Department of Education's 2026 managed growth arrangements set a National Planning Level of 295,000 new overseas student commencements for 2026. Non-university higher education providers receive a minimum allocation of fifty, and otherwise an increase of around three per cent on average on their 2025 allocation, with no active provider allocated less than it had in 2025. Allocations are linked to offshore visa processing priority through a ministerial direction. For a new private provider, that means onshore international growth is a matter of building from a small allocation over several years rather than scaling quickly, and a business plan that assumes otherwise will not survive TEQSA's financial viability assessment.
Offshore campuses and delivery outside Australia
A registered provider can deliver its accredited courses outside Australia, and TEQSA's regulation follows the course. The Threshold Standards apply to every location at which a course is delivered, so the offshore campus needs facilities, staff, learning resources, student support and academic governance that meet the same standards as the Australian one. Assessors ask how the academic board oversees the offshore cohort, how assessment is moderated across locations, and whether student outcomes are compared.
The host country's regulator has its own requirements, usually including local licensing, and the two regimes must be reconciled in the provider's governance. In my experience an offshore campus is a five-year project for a private provider, and the providers that succeed treat it as a second institution under a single academic board rather than a franchise. TEQSA's fee schedule also lists an authorised offshore provider application at $36,800, and any new delivery location is a material change that must be notified within fourteen days. Our article on advancing internationalisation through TEQSA consulting covers the planning sequence.
Transnational partnerships and Standard 5.4
The most common offshore model for private providers is a partnership in which a foreign institution delivers the Australian provider's course, or part of it, under an agreement. Standard 5.4 on delivery with other parties governs this arrangement, and TEQSA reads it strictly. The Australian provider remains responsible for every aspect of the course, including admission, teaching quality, assessment, student support and the award, and it must be able to show that it is exercising that responsibility rather than describing it in a contract.
Two things follow. A new third-party delivery arrangement is a material change under section 29 of the TEQSA Act, and TEQSA's material change notification policy lists new third-party arrangements and failures of control over third parties among the events it expects to hear about within fourteen days. And the academic board must approve the arrangement and receive reports on it, with evidence of moderation, site visits and action where the partner's results diverge. In my experience the partnerships that go wrong are the ones where the Australian provider's only visibility was the partner's annual invoice. My article on internationalisation and TEQSA registration discusses how to structure the oversight.
Online export: the route with the fewest permissions and the most scrutiny
Delivering an accredited course online to students who remain in their own countries requires no CRICOS registration, because the ESOS Act concerns students on Australian student visas. That makes it the fastest route into the global education market Australian providers have, and the numbers are attractive because there is no allocation cap. It is also the route TEQSA examines most carefully at accreditation and renewal, because everything that can go wrong with online delivery goes wrong faster at a distance.
The questions are the ones any online course faces, with extra weight on identity verification, secured assessment, time-zone appropriate support and recognition rules in the countries it sells into. A degree that a graduate's home country will not recognise is a representation problem under Standard 7.1 as well as a commercial one. Micro-credentials are often the first product in this route, and our article on micro-credentials and international students explains why they need the same governance as an award.
Choosing a route in the global education market Australian providers compete in
In my experience the private providers that do well internationally choose one route, build the governance for it before they recruit, and add a second route only once the academic board is comfortably overseeing the first. The providers that struggle try all four at once with a single compliance officer. International work rewards specialisation and punishes stretched oversight, and TEQSA's assessment framework is built to notice the difference.
If you are weighing the options, start with the permission each requires and the governance each demands, then look at the market. Permissions take months, governance takes longer, and recruitment without either is a material change notification waiting to be written.
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Frequently asked questions
Do we need CRICOS registration to teach international students online from overseas?
No. CRICOS and the ESOS Act apply to students studying in Australia on student visas. Online delivery to students who remain offshore needs no CRICOS registration, but the course must still meet every Threshold Standard and the provider must understand recognition rules in the destination country.
How many international students can a new private provider recruit onshore?
Under the 2026 managed growth arrangements non-university higher education providers receive a minimum allocation of fifty new overseas student commencements, with existing providers receiving around three per cent growth on average on their 2025 allocation.
Is a transnational delivery partnership a material change?
Yes. TEQSA's material change notification policy lists new third-party delivery arrangements among the events that must be notified within fourteen days, and the Australian provider remains fully responsible for the course under Standard 5.4.
Does TEQSA regulate an Australian provider's offshore campus?
Yes. The Threshold Standards apply wherever an accredited course is delivered, and TEQSA expects the academic board to oversee the offshore cohort, moderate assessment across locations and compare outcomes with the Australian campus.
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.