The role of consultants TEQSA applicants need is that of an adviser to a decision-maker, not a substitute for one. Across an accreditation a good consultant tells the provider what the standards require, how far it currently falls short, what to build, what evidence to keep, and how an assessor will read the result. The governing body and the academic board make every decision, and the record shows them doing it. A consultant who crosses that line, however well-intentioned, damages the application they were hired to help.
I run a consultancy, so the reader is entitled to some scepticism about what follows. What I can offer is fifteen years of watching engagements succeed and fail in our own TEQSA registration practice and in the applications of providers who came to us after another arrangement had gone wrong.
Why the role of consultants TEQSA sees is a governance question
TEQSA does not regulate consultants. It regulates providers, and it holds the provider's governing body responsible under Domain 6 of the Threshold Standards for the institution's compliance and for the application it lodges. That responsibility is non-delegable. A board can take advice from anyone, but the decision to adopt a policy, approve a course, appoint a Dean or lodge an application must be the board's own, made at a meeting that happened, on papers the members read.
That is why consultants appear in TEQSA's field of view only through the governance record. Assessors notice when a consultant's name is on every board paper, when the academic board's minutes read as if the consultant presented the courses and the members received them, or when policies are dated before the body that supposedly adopted them first met. None of that is illegal. All of it tells the assessor that the governance may not work without the consultant in the room, and the standards are concerned with whether it works at all.
What a consultant should do across an accreditation
The legitimate role is wide. At the outset a consultant should run a gap analysis against every applicable standard and tell the provider, in writing, where it stands and what the honest timeline is. In the build phase the consultant should advise on the governance structure, the policy suite, the staffing plan and the course design, and should sit with the academic leaders while they do the work rather than doing it for them. In the application phase the consultant should structure the self-assurance report, map every claim to evidence, and critique the whole before lodgement. After lodgement, the consultant should help the provider understand and respond to requests for further information.
Throughout, the consultant should be candid about problems the provider does not want to hear. The most valuable thing I do for most clients is tell them that a course is not ready, a board is not independent enough, or an application should wait six months. A consultant who only ever agrees with the client is not advising them. The full range of what consultancies in this field offer is described in TEQSA higher education consultants: a comprehensive guide.
What a consultant should not do
A consultant should not sit on the governing body or the academic board while advising on the application. The conflict is obvious, and assessors read it as the provider having outsourced its governance. A consultant should not draft minutes of meetings they did not attend, or resolutions for meetings that have not been held. A consultant should not write the self-assurance report in the first person as though they were the provider and hand it over for signature; the report is the board's account and the board has to own the words.
A consultant should also not promise an outcome. TEQSA's decision is TEQSA's, and anyone who guarantees registration is either not being straight with the client or has misunderstood the regulator. What a consultant can promise is a complete, specific, true application lodged on a realistic timeline, which in my experience is the fastest route to a decision because it avoids the requests for further information that turn nine months into eighteen. What a specialist accreditation consultant does day to day is set out in TEQSA consultant: higher education accreditation consultant.
Authorship: whose application is it?
Authorship is where the principle becomes practical. Every document in an application has an author of record, and TEQSA reads the governance trail to find out who it was. The safe arrangement is that consultants produce drafts as advice, those drafts go to the responsible body as papers for decision, the body considers them, amends what it wants amended, and adopts them in its own name, with minutes that show the consideration. The consultant's contribution is real and visible, and so is the board's judgment.
The unsafe arrangement is a set of finished documents delivered to the provider and adopted by circular resolution the same week, with a self-assurance report the CEO has read once. In that arrangement the provider cannot answer an assessor's questions without ringing the consultant, and assessors have a reliable instinct for it. Under self-assurance the provider's account of itself is the application, and an account written by someone else reads as exactly that. The narrower question of writing assistance, and where it ends, is covered in TEQSA application writing help.
The engagement model that works
In my experience the engagement that produces good outcomes has four features. It starts early, ideally before the governing body is constituted, so that the structure is right from the first meeting. It is scoped around advice, drafting and critique, with decision rights written into the engagement letter as belonging to the provider. It reports to the board as well as to management, so the directors hear the consultant's assessment directly and not through the CEO. And it plans for its own exit: the provider should be able to run its governance, its policy cycle and its reporting without the consultant well before the application is lodged, because TEQSA will look again at renewal and the consultant may not be there.
That model is slower at the start than handing over a template set. It is faster at the end, because the application is the provider's own and the assessor can see that it is. TEQSA's application guide for new providers is written on the assumption that the provider is answering for itself, and the engagement should be built on the same assumption.
My advice: hire for candour and keep the decisions
If I were choosing a consultant for my own provider, I would look for someone who has read a great many TEQSA decisions, who will tell me things I do not want to hear, who will put their advice in writing to the board, and who is uninterested in being the author of my application. The role of consultants TEQSA applicants benefit from is exactly that: expert advice, delivered to a governing body that reads it, weighs it and decides. Keep the decisions where the law puts them and a good consultant will make the whole accreditation faster and more certain. Give the decisions away and the best consultant in the country cannot protect you from the record that results.
Download the Darlo Governance Readiness Checklist
— a one-page self-assessment of whether your governing bodies are making, and recording, their own decisions, drawn from our TEQSA registration and governance work with private providers. Get the checklist
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Frequently asked questions
Does TEQSA object to providers using consultants?
No. TEQSA regulates providers, not consultants, and expects the governing body to take advice. What it looks for is evidence that the provider's own bodies made the decisions the application attributes to them.
Can a consultant sit on our academic board?
Not while advising on the application. The conflict of interest is direct, and assessors read it as governance that depends on the consultant rather than the provider.
Who should sign off the self-assurance report?
The governing body, after considering it as a paper for decision and recording that consideration in the minutes. The report is the board's account of the provider's compliance, whoever helped draft it.
Can a consultant guarantee TEQSA registration?
No. The decision belongs to TEQSA under the TEQSA Act. A consultant can commit to a complete, specific and true application on a realistic timeline, which is the fastest path to a decision, but not to the decision itself.
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.