What TEQSA looks for in a new course comes down to six things: a course pitched at the correct AQF level, learning outcomes that are actually assessed, qualified staff who are in place rather than planned, adequate learning resources, external benchmarking and independent review, and substantive approval by your own academic board. Get those right and course accreditation is usually uneventful. Miss any of them and you can expect a lengthy request for further information.
Having worked on course accreditation applications for private providers for more than fifteen years, I can tell you the regulator's questions are remarkably consistent. This article sets out what TEQSA is assessing in a new course and where applications most often fall short.
What standards does TEQSA assess a new course against?
TEQSA does not assess a course against its own preferences. It assesses it against the Higher Education Standards Framework (Threshold Standards) 2021, with particular weight on the standards for course design, teaching, assessment, staffing and institutional quality assurance.
This matters because it tells you how to structure your thinking. A course accreditation application is not a marketing document or a curriculum handbook. It is an evidence-based demonstration that a specific set of standards has been met. The most useful habit a provider can adopt is to ask, for every claim in an application, which standard does this address, and what is the evidence?
If you are a non-self-accrediting provider, every new course goes through this process. If you hold self-accrediting authority for a discipline, the same standards still apply; the difference is that your own academic governance carries the assessment, and TEQSA tests it at re-registration.
Is the course pitched at the right AQF level?
The first thing an assessor will test is whether the course genuinely sits at the Australian Qualifications Framework level it claims. A Bachelor degree must produce graduates with the knowledge, skills and application described at AQF level 7. A Master by coursework must reach level 9. This is demonstrated through the course learning outcomes, the volume of learning, and the way units build in complexity across the course.
The most common problem here is learning outcomes written at the wrong level. A Master's course whose outcomes read describe, identify and explain will not survive scrutiny, because those verbs signal recall rather than the advanced, independent application the AQF requires at level 9.
Assessors look for a clear line from the AQF descriptors to the course learning outcomes, from those to the unit learning outcomes, and from those to the assessment tasks. If that chain breaks anywhere, the application is in difficulty.
Do the learning outcomes and assessment actually line up?
Standard 1.4 of the Threshold Standards requires that assessment is consistent with the learning outcomes being assessed, and that the methods used can confirm every specified outcome has been achieved. In practice, TEQSA reads your unit outlines closely and maps outcomes to tasks.
Assessors are alert to several patterns. One is the unit whose assessment is entirely essays and exams while its outcomes promise practical or professional skills. Another is the course learning outcome that is claimed but never assessed in any unit. A third is the capstone that does not synthesise the course as a whole.
A constructive alignment matrix, showing which units assess which course learning outcomes and how, is not a formality. It is often the single document an assessor spends most time with. Academic integrity sits here too: TEQSA expects to see how the assessment design itself limits contract cheating and misuse of generative AI, not just a policy that prohibits them.
Who will teach the new course, and are they qualified?
Standard 3.2 sets the expectations for staffing, and this is where a great many new course applications come undone. Teaching staff are expected to hold a qualification at least one AQF level above the course they teach, or equivalent professional and scholarly standing, and there must be enough of them, with the right mix, to deliver the course as designed.
TEQSA does not accept a staffing plan that consists of to be recruited. It wants named academics, their CVs, their qualifications and their currency in the discipline. It looks for a course coordinator with real authority over the course, and for evidence that staff are scholars in the field, not simply practitioners who have agreed to lecture.
For postgraduate courses, the need for staff with doctoral qualifications and a scholarly profile becomes a genuine constraint on what can credibly be offered. That constraint is better discovered in planning than in an assessor's report.
The New Course Readiness Checklist
A one-page self-assessment covering the six areas above, drawn from our TEQSA course accreditation work with private providers.
Are the learning resources and student support in place?
A new course needs a library collection or database access appropriate to the discipline and level, a learning management system that can deliver the course as designed, and, where relevant, specialist facilities such as laboratories, studios or clinical simulation spaces. TEQSA wants evidence that these exist, or that binding arrangements secure them before the course commences, rather than statements of intention.
Support services matter too: academic skills support, English language support for the cohort you intend to admit, and the transition arrangements described in Standard 1.3. For courses involving placements or work-integrated learning, the regulator will look at how placements are sourced, supervised and assessed, and at the agreements underpinning them.
Has the course been benchmarked and externally reviewed?
This is one of the most underestimated requirements. Standard 5.1 requires that a course be approved through the provider's own academic governance processes, informed by external referencing or other benchmarking. Standard 5.3 requires ongoing comparison against courses at other institutions. TEQSA's own guidance notes expand on what it expects here, although it is worth remembering that guidance notes are not themselves Threshold Standards.
In practical terms, TEQSA expects the course to have been compared with comparable Australian courses, and an independent, appropriately qualified external reviewer to have examined the course design, learning outcomes and assessment and produced a written report. It then expects to see what you did with that report.
An external review that recommended changes, followed by an academic board decision adopting them, is far more persuasive than a review that found nothing to improve. Our external course review service exists for precisely this step.
Did your own academic board approve it properly?
TEQSA is very interested in how a course arrived at the point of application. The Threshold Standards place responsibility for course approval squarely with the academic board or equivalent, and the regulator reads the board papers and minutes. It wants to see that the board received a complete proposal, engaged with the external review and benchmarking, asked questions, and approved the course on academic judgment rather than commercial pressure from the corporate arm.
This is a governance question as much as a curriculum question, and it is where the non-delegable responsibility of the governing bodies becomes visible. A course designed elsewhere and rubber-stamped by the board, without real engagement with its academic merits, has not met the standard, however good the curriculum may be.
Is the course viable, and is the market real?
TEQSA is not a commercial regulator, but it expects a credible basis for offering a course. Assessors look at enrolment projections, at the evidence of demand behind them, at whether the course remains deliverable below forecast, and at what happens to enrolled students if it is discontinued. A financial model that only works at ambitious enrolment numbers invites questions.
Where a course leads to a regulated profession or claims professional recognition, TEQSA will also want to see where the relevant professional body stands, and it will be sceptical of language implying accreditation that has not yet been granted.
What has changed in how TEQSA assesses new courses?
Two developments are worth noting. The first is that TEQSA has moved toward a self-assurance approach, in which the provider must demonstrate its own capacity to assure quality rather than simply submitting evidence for TEQSA to check. In my view this raises the bar. A provider now has to show that it understands why each standard matters and how its own systems will keep meeting it, not just that a document exists.
The second is the effect of generative AI on applications. Assessors are now well accustomed to fluent, well-structured applications whose content is generic and whose evidence is thin. A document that reads well but does not describe your actual staff, facilities, governance decisions and course is, if anything, more likely to draw scrutiny than a plainer document that is specific and true.
Where new course applications most often fall short
The recurring themes are worth stating plainly: learning outcomes not at the claimed AQF level; assessment that does not test the stated outcomes; staffing that is aspirational rather than in place; external review not done or not acted on; and academic board approval that is procedural rather than substantive. Underlying all of these is a tendency to treat the application as a persuasive document rather than an evidentiary one.
A new course is a considerable investment for any private provider. Getting the accreditation application right the first time is the difference between launching in the intake you planned for and losing a year to requests for further information. If you would like an honest read on where your course stands, you can talk to us.
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Frequently asked questions
How long does TEQSA course accreditation take?
TEQSA's published timeframes for course accreditation run to several months from a complete application, and requests for further information extend that. Providers should plan a new course at least twelve months ahead of the intended first intake.
Does a self-accrediting provider need TEQSA to accredit a new course?
No. A provider with self-accrediting authority in a discipline approves its own courses through its academic board, but the same Threshold Standards apply and TEQSA reviews the process at re-registration.
What qualifications do staff need to teach a new higher education course?
Under Standard 3.2, teaching staff generally need a qualification at least one AQF level above the course they teach, or equivalent professional and scholarly standing, plus current knowledge of the discipline and of teaching in it.
Is an external review of a new course mandatory?
The Threshold Standards require course approval to be informed by external referencing or benchmarking, and in practice TEQSA expects a written independent review of the course design, learning outcomes and assessment before the academic board approves it.
Dr Brendan Moloney is CEO of Darlo Higher Education, a 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.