The evidence of student learning TEQSA expects from a provider is outcome evidence: cohort progression, retention and completion rates, grade distributions by unit and by marker, moderation records, external referencing of marked work against comparable courses, and graduate outcomes, all of it read and acted on by the academic board. Course documents and assessment rubrics show what a provider intends. Outcome data shows whether students actually learned, and that is what Standards 1.4 and 5.3 of the Threshold Standards ask about.
This article sets out each kind of evidence, what TEQSA does with it, and the mistakes that turn a good provider's data into a weak application, drawing on fifteen years of TEQSA registration and renewal work with private providers.
What evidence of student learning TEQSA expects and why
Standard 1.4 of the Higher Education Standards Framework (Threshold Standards) 2021 requires that learning outcomes are specified, that assessment is designed to demonstrate their achievement, and that methods are in place to ensure grades are comparable with those of other providers. Standard 5.3 requires the provider to monitor and review course performance, including student progress and outcomes, and to use the results to improve. Read together, they mean a provider must be able to show not just that it assesses students but that the assessment produces trustworthy results, and that somebody with authority looks at those results and does something.
This is where the shift from Confirmed Evidence Tables to self-assurance bites hardest. A self-assurance report that says "our graduates achieve the learning outcomes" has to point to the data that proves it. In my experience the providers who struggle most at renewal are not the ones with poor outcomes; they are the ones who cannot produce the outcomes at all, because nobody was collecting them in a form the academic board could read.
Progression, retention and completion
The first layer is cohort data. Assessors want to see, by course and by intake, how many students commenced, how many progressed to the next study period, how many withdrew, and how many completed within the expected duration. They read these figures against the provider's own admission criteria, because a course admitting students without the assumed background will show it in first-year attrition before it shows anywhere else.
The mistake I see most is reporting these figures only as institution-wide totals. A provider with a healthy overall retention rate can conceal a single course losing half its cohort in the first semester, and TEQSA's annual data collection lets assessors see that even when the application does not. Present the data disaggregated by course, mode, location and, where numbers permit, by cohort characteristics such as international, mature-age or pathway entry. Then explain what the academic board concluded from it. A number without an interpretation is not evidence of monitoring.
Grade distributions and moderation
The second layer is what happens inside a unit. Assessors look at grade distributions by unit and, where a unit has multiple markers or campuses, by marker. A unit where every student receives a distinction tells them either that the assessment is too easy or that the marking is uncalibrated, and either way the grades cannot be relied on as evidence of learning. A unit where the fail rate spikes in one study period and nobody asked why tells them the monitoring in Standard 5.3 is not operating.
Moderation records are the answer to that question. TEQSA's guidance notes on assessment are useful reading here, with the caveat that guidance notes are not themselves Threshold Standards. TEQSA expects to see pre-assessment moderation of tasks and rubrics, and post-assessment moderation of a sample of marked work, with the outcomes documented and any adjustments to grades recorded. Our article on assessment integrity and TEQSA covers the integrity side of this in more detail; for present purposes the point is that moderation is what converts a grade from a marker's opinion into an institutional judgment. Where a provider uses sessional staff heavily, assessors read the moderation records with particular care.
External referencing of marked work
Standard 1.4 requires methods to ensure that grades are comparable with those of other providers, and the sector's main answer is external referencing: sending a sample of marked student work, with the task and rubric, to an academic at another institution who reports on whether the standard applied is consistent with their own. The provider then records the reviewer's findings and what it did about them.
In my experience this is the piece of evidence most often missing from a first registration application and most often perfunctory at renewal. A new provider cannot have referenced work it has not yet marked, so TEQSA reads the policy, the schedule and the names of the institutions it intends to benchmark against. A renewing provider is expected to have done it, on a cycle covering every course, and to show the academic board receiving the reports. A single external review of one unit four years ago does not meet the standard as written. Our guide to documenting and demonstrating assessment standards sets out what a referencing file looks like when it is complete.
Graduate outcomes and employer feedback
The third layer is what happens after graduation. TEQSA reads the provider's graduate destinations, further study rates and, for professionally oriented courses, employer and industry feedback. For accredited professions the outcome data also includes registration and licensing results. None of this is in the provider's direct control, which is exactly why assessors value it: it is evidence of learning that the provider did not produce for itself.
The related mistake is treating a graduate survey as a marketing exercise. A survey with a twelve per cent response rate and a single question about satisfaction is not outcome evidence. Assessors look for a systematic approach, a response rate the provider has worked to improve, questions that map to the course learning outcomes, and a record of the academic board receiving the results alongside the progression and grade data. Our article on TEQSA standards and student outcomes explains why the regulator has moved its attention so firmly in this direction.
How the academic board is expected to use it
All of the above is raw material. What TEQSA actually assesses is the loop: data collected, reported to the academic board, discussed, acted on, and the action later checked. The academic board's minutes and papers are where the loop becomes visible. An annual course performance report that arrives at the board, is noted and is filed is evidence that data exists. A report that generates a resolution requiring the course coordinator to revise a unit's assessment, followed six months later by a paper reporting the revised distribution, is evidence of learning being monitored and improved.
I encourage clients to build a standing agenda item and a fixed reporting template, so that the same measures arrive at every scheduled meeting in the same form and trends are visible without anyone having to reconstruct them. That routine is what an assessor recognises as a quality assurance system rather than a set of documents.
Common ways the evidence falls short
Several patterns recur in the applications that draw a request for further information on this ground. Outcome data reported in aggregate rather than by course, and grade distributions with no comparison across markers or study periods. Moderation policies with no moderation records. External referencing described as a future intention by a provider that has been operating for five years. Graduate outcomes based on a handful of testimonials.
And, most commonly of all, good data that never reached the academic board or reached it without any recorded discussion.
Each of these has the same underlying cause: the evidence was assembled for the application rather than produced by the operation. The standards are written in the present tense, and TEQSA reads them that way.
Building evidence of student learning TEQSA will accept
The fix is procedural rather than clever. Decide which measures the academic board will see, at what interval, in what format, and disaggregated how. Put moderation and external referencing on a calendar that covers every course over the registration period. Keep the records where they are produced, not in a folder made for the assessor. And write the self-assurance report from the minutes, so that every claim about student learning points to a meeting at which a governing body considered the evidence and decided something.
Done this way, the evidence of student learning TEQSA expects is simply a by-product of running the provider well. Assembled the other way, it rarely survives an assessor's first question.
Download the Darlo Re-registration Evidence Index Template
— a structured index that maps outcome data, moderation and referencing records to Standards 1.4 and 5.3, drawn from our TEQSA registration and governance work with private providers. Get the template
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Frequently asked questions
What does TEQSA mean by evidence of student learning?
Outcome evidence rather than intentions: progression, retention and completion by course, grade distributions, moderation records, external referencing of marked work against other providers, and graduate outcomes, together with the academic board's documented response to them.
Does a new provider need external referencing evidence at initial registration?
Not results, because there is no marked work yet, but TEQSA expects a policy, a schedule and identified benchmarking partners, and it will expect completed referencing reports at renewal.
How often should the academic board see outcome data?
In my experience at least each study period for progression and grade data, with a full annual course performance report, so that trends are visible and the minutes show the board acting on them.
What is the most common weakness in this area?
Aggregate data that hides course-level problems, and data that exists but never reached the academic board with a recorded discussion and decision.
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.