This TEQSA compliance guide sets out what a registered private provider has to do, year in and year out, to stay compliant between registration and renewal: lodge the annual data returns, notify material changes within fourteen days, review the risk register, run course and governance reviews on schedule, keep an evidence index current, and prepare a self-assurance report the governing body can honestly sign. Registration is a licence to operate for a period. Compliance is the record that earns the next one.
The guide is organised as a calendar and a set of roles, because in fifteen years of TEQSA registration and renewal work I have found that providers who fail at compliance rarely fail from ignorance of the Standards. They fail because nobody owned the calendar.
Step one: understand what compliance means to TEQSA
TEQSA does not conduct audits in the sense that ASQA does. It regulates through assessments at registration, accreditation and renewal, through compliance assessments where risk indicates, through requests for further information, and through the annual data it collects. Between those points it relies on the provider to govern itself, and the Threshold Standards are written in the present tense to make that expectation explicit. A provider "has" a governing body, "monitors" outcomes, "addresses" breaches. Compliance is those verbs being true on any day TEQSA chooses to look.
The move from Confirmed Evidence Tables to self-assurance sharpened this. TEQSA now asks the provider to say which standards it meets and to point to the evidence, rather than filling in a table. That raises the evidentiary bar, because a self-assurance statement the evidence does not support is a false statement to the regulator. It also means the compliance work of years two, three and four is what the renewal application in year five is made of.
Step two: assign the roles
A compliance calendar without owners is a list. Before anything else, decide who holds each of four roles. The company secretary or compliance manager owns the calendar, the register of obligations and the evidence index. The CEO owns material change notifications and the relationship with TEQSA.
The two chairs hold the rest. The chair of the academic board owns the academic quality cycle: course reviews, integrity reporting, assessment moderation. The chair of the governing body owns the risk register, the governance reviews and the self-assurance report.
The non-delegation principle applies to every one of those. A consultant can build the calendar and draft the reports. The governing bodies remain responsible for compliance, and the record must show them deciding, not receiving. Our article on common TEQSA compliance mistakes lists what happens when that separation is lost.
Download the Darlo Re-registration Evidence Index Template
— a standard-by-standard index with owners, review dates and record locations, drawn from our TEQSA registration and governance work with private providers. Get the template
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Frequently asked questions
How often does TEQSA check on a registered provider?
TEQSA collects provider data annually, responds to material change notifications and complaints, and may conduct a compliance assessment where risk indicates. Formal assessment otherwise occurs at course accreditation, renewal of accreditation and renewal of registration.
What must be notified to TEQSA as a material change?
Under section 29 of the TEQSA Act, events that significantly affect the provider's ability to meet the Threshold Standards or that require a National Register update, notified within fourteen days of the provider reasonably becoming aware. TEQSA's policy lists ownership, CEO, safety, good standing, revenue, third-party delivery and major course changes.
When must a renewal of registration application be lodged?
At least 180 calendar days before the current registration period ends, with a self-assurance report of no more than ten pages, an evidence index, independent governance reviews and risk management evidence.
What is an evidence index?
A document mapping each Threshold Standard to the records showing it is met, with the location and currency of each record. It underpins the self-assurance report and should be updated continuously rather than assembled before renewal.
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.