The TEQSA registration process is easiest to navigate when five people know exactly what is theirs to do: the owner sets the mandate and funds it, the CEO runs the project, the chair makes the governing body's decisions visible, the academic board chair owns the courses and academic policy, and the company secretary keeps the record that proves all of it. Most stalled applications I have seen were stalled because one of those five roles was vacant, or because two of them were the same person and nobody noticed the conflict.
This article walks through the stages of registration from the perspective of each role, drawing on fifteen years of TEQSA registration work with private providers. For the stages themselves, our step-by-step guide to the TEQSA registration application process is the reference; this piece is about who does what.
Stage one: the decision to proceed
The owner's job at this stage is to decide, in writing, that the organisation will seek registration as a higher education provider, and to commit the money. The application-based fees alone run to $14,700 for the preliminary assessment and $112,100 for the substantive assessment of an initial registration, plus $6,000 and $44,700 per course for accreditation lodged with it, and those figures are before staff, premises, external reviews and advisers. An owner who has not confronted the full cost will pull back at the worst moment, usually mid-assessment.
The CEO's job is to translate that decision into a plan with a date. In my experience the path from decision to a domestic registration decision runs eighteen to twenty-four months, and TEQSA asks prospective providers to engage with it at least six months before lodging. The chair and company secretary may not yet exist at this stage, and that is the first trap: the governing body needs to be in place before the plan is approved, so that the record shows the board adopting the plan rather than inheriting it. Our article on how long TEQSA registration takes explains where the time goes.
Stage two: building the governance that will own the application
This is the chair's stage. The governing body must be constituted under Standard 6.1 of the Threshold Standards with independent members who have relevant expertise, and it must begin meeting, minuting and deciding well before the application is lodged. The chair's specific task is to make sure the board actually governs: that it receives papers, asks questions, records dissent, and approves the constitution, the delegations schedule, the risk framework and the policy suite as its own decisions.
The academic board chair's task begins here too. Under Standard 6.3 the academic board must have authority over academic quality, and in practice it must exist and be operating before it can approve a course. The chair should be an academic with standing in the field, independent of the owner and the CEO, and the terms of reference should give the board the power to decline. The company secretary's task at this stage is to establish the register of minutes, resolutions, declarations of interest and policy versions that every later stage will depend on. If that register is started late, the record cannot be reconstructed honestly.
Stage three: designing the courses and writing the application
The academic board chair now carries the most weight. Each course must be designed against Standard 3.1, benchmarked against the discipline, staffed under Standard 3.2, externally reviewed, and approved by the academic board on a documented basis. In my experience that cycle takes three to four months per course, and the courses cannot be finalised until the staffing is real. The chair's job is to run that cycle properly, not to sign what the CEO brings.
The CEO's job is to assemble the application against the application guide for prospective providers, coordinate the advisers, and make sure every claim in the narrative points to a document that exists and is dated. The owner's job is to stay out of the academic decisions and to complete a full and candid fit and proper person declaration, because TEQSA checks and an omission discovered later is far worse than a matter disclosed with context. The company secretary's job is to build the evidence index, standard by standard, and to confirm that every document in it was approved by the body the narrative says approved it.
Stage four: lodgement, preliminary and substantive assessment
At lodgement the chair signs, and the signature means something. The governing body is non-delegably responsible for the application; a consultant may have drafted it and the CEO may have assembled it, but the board must have considered it and resolved to lodge it, and the minutes must show that. TEQSA's indicative timeframes give thirty days for the preliminary assessment and nine months for a substantive decision, extendable by up to a further nine months.
During assessment the CEO is the point of contact, but the company secretary is the one who keeps the process honest. Every request for further information should be logged, every response should go through the board or the academic board as appropriate, and every new or amended document should be version-controlled so that the application does not quietly contradict itself. The academic board chair should expect questions about course approval and be ready to show the minutes. The owner should expect questions about ownership, funding and related-party arrangements and should answer them directly.
Stage five: the decision and the first year of registration
If registration is granted, the TEQSA registration process does not end; it changes shape. Registration is for a period of up to seven years, and in practice initial registrations are commonly for five with capacity to extend, and TEQSA will look again at renewal. The chair's job now is to keep the board doing what it did during the application: reviewing risk, receiving financial and academic reports, and monitoring conditions. The academic board chair's job is to make the annual course monitoring under Standard 5.3 real from the first year.
The CEO and company secretary share the material change obligation. Under section 29 of the TEQSA Act, events that significantly affect the provider's ability to meet the Standards, or that require a change to the National Register, must be notified within fourteen days of when the provider would reasonably be expected to have become aware. Ownership changes, a new CEO, significant revenue shifts and new third-party arrangements are all on TEQSA's list. The company secretary should hold a calendar of those triggers, and the CEO should treat the fourteen-day clock as a hard deadline. Our overview of getting registered with TEQSA in Australia covers the first-year obligations in more detail.
Where roles collide in the TEQSA registration process
In a small private provider the owner is often the CEO, sometimes the chair, and occasionally sits on the academic board. TEQSA does not prohibit that, but it reads it closely. The safeguards are structural: independent directors who can outvote the owner, an academic board chaired by an academic who is not the CEO, a conflicts register that is used at every meeting, and a company secretary who reports to the board rather than to management. Where those safeguards are absent, the assessor assumes the owner made every decision.
The best way to navigate the TEQSA registration process is to fill all five roles with five different people before the plan is approved, give each of them a written brief drawn from the stages above, and let the company secretary keep the record that will one day prove they each did their job.
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— a stage-by-stage brief for each governance role, drawn from our TEQSA registration and governance work with private providers. Get the guide
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Frequently asked questions
Who is responsible for a TEQSA registration application?
The governing body. Advisers can draft and management can assemble, but the board is non-delegably responsible for the application and for the provider's compliance, and the minutes must show it considered and resolved to lodge.
Can the owner chair the academic board?
It is strongly inadvisable. Standard 6.3 requires academic governance with authority over academic quality, independent of commercial decision-making, and an academic board chaired by the owner or CEO will be read by TEQSA as lacking that independence.
What does the company secretary do during registration?
The company secretary keeps the record: minutes, resolutions, declarations of interest, policy versions and the evidence index. During assessment they log every request for further information and version-control every response so the application stays consistent.
What must be notified to TEQSA after registration?
Material changes under section 29 of the TEQSA Act, including changes of ownership or CEO, incidents affecting student safety, significant revenue changes and new third-party delivery arrangements, within fourteen days of when the provider would reasonably be expected to have become aware.
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.