The future of higher education consulting Australia-wide is a move away from writing applications and towards building institutions that can pass a regulator's scrutiny on their own. TEQSA's shift to self-assurance, the arrival of generic AI-drafted submissions and the pressure on fees are all pushing in the same direction, and within five years the consultants who survive will be the ones whose clients no longer need them for the next application.
This article sets out how I see the work changing, what is driving it, and what a provider should expect from an adviser now. It is written from fifteen years of TEQSA registration and accreditation work, and from a growing conviction that the old model was never really serving clients well.
What consulting used to be
For most of the last decade the product was the document. A provider engaged a consultant to produce an application, the consultant produced it, and the provider lodged it. Under the Confirmed Evidence Table regime that model worked well enough, because the assessment was largely a matter of matching evidence to a checklist and a skilled writer could make a thin institution look complete.
Our article on higher education consultants in Australia looks at what that market became. The short version is that it grew, fragmented, and filled with people who had written one successful application and assumed they could write another. The client bought pages. Whether the institution behind the pages was sound was somebody else's problem, usually the board's, and usually discovered at re-registration.
Why self-assurance ended the document model
TEQSA has retired Confirmed Evidence Tables for higher education registration and now asks for a self-assurance report, capped at ten pages, supported by an evidence index and independent reviews of governance. The renewal application guide sets out what is required. Assessment is risk-based, drawing on compliance history and annual data, and TEQSA does not ask for evidence against every standard.
Many providers read this as a lowering of the bar. It is the opposite. A ten-page report cannot hide a weak institution behind volume, and an evidence index that points at documents which do not show operation is exposed the moment an assessor opens one. The report has to be true, specific and grounded in records the provider already keeps, and no consultant can write that from the outside. The only way to produce it is to have built the systems it describes.
Generic AI drafting is making scrutiny sharper
At the same time as self-assurance arrived, so did applications drafted by generative AI. I have read several. They are fluent, well structured, and interchangeable, because the tool produces the same reasonable-sounding account of governance and quality assurance for every provider that asks it. Assessors have read them too, and in my experience an application that reads like every other now draws more scrutiny rather than less, because it signals that nobody inside the institution wrote it.
That is a problem for the consultants whose value was fluent prose, and it is the reason higher education experts remain essential in a different form. The scarce skill is no longer writing. It is knowing what a functioning academic board looks like, what moderation records should contain, what a risk register that is actually used reads like, and being able to tell a client the honest gap between what they have and what the standard in the present tense requires.
The future of higher education consulting Australia's providers should expect
The first change is in what is sold. The product is becoming the institution rather than the application: governance design, policy suites that staff can actually follow, academic board induction, evidence systems that generate the self-assurance report as a by-product of ordinary operation. The application becomes a snapshot of something that already works, which is also the fastest path through TEQSA because a complete, specific and true application avoids requests for further information.
The second change is in pricing. TEQSA's own application fees are fixed and published, and advisers' fees are drifting the same way. Hourly billing rewards the consultant for a long assessment and punishes the client for one. Fixed-fee engagements scoped to an outcome, whether that is a lodged application or a governance review, align the interests and are becoming the norm among serious advisers. A provider should ask any consultant what happens to the fee if an RFI arrives, and should be wary of an answer that involves more hours.
The third change is in where responsibility sits. The non-delegation principle has always applied: governing bodies are responsible for the application, consultants advise, boards decide, and the record must show it. Self-assurance makes that visible in a way it never was, because the report is a statement by the provider about itself. The consultant who drafts a board's self-assessment without the board doing the assessing is setting the client up to be found out.
What this means for the sector
I think the future of higher education consulting Australia-wide is smaller in headcount and larger in substance. Fewer people will make a living producing documents, and the ones who remain will look more like institutional builders than writers. Providers will engage them earlier, for longer, and for the purpose of not needing them at the next renewal. That is a better sector, and our piece on the future of higher education and TEQSA in Australia describes the regulatory environment it will operate in.
The question I would put to any provider choosing an adviser is simple. Will this person leave you with an institution that can explain itself to TEQSA without them, or with a document that only they understand?
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Frequently asked questions
Has TEQSA's move to self-assurance made applications easier?
No. A ten-page self-assurance report supported by an evidence index cannot hide a weak institution behind volume, and TEQSA's risk-based assessment tests whether the evidence shows the standards operating. The bar is higher, not lower.
Can a consultant write our self-assurance report?
A consultant can advise on structure and evidence, but the report is the provider's statement about itself and the governing body is non-delegably responsible for it. The board must do the assessing and the record must show it did.
Are AI-drafted TEQSA applications a problem?
In my experience they draw more scrutiny, because generic prose signals that the institution did not write its own account. Assessors look for specific, provider-particular evidence, which AI tools cannot supply.
Should we expect fixed fees from a TEQSA consultant?
Increasingly, yes. Fixed fees scoped to an outcome align the consultant's interest with a short, clean assessment. Ask what happens to the fee if a request for further information arrives.
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.