The TEQSA consultant international students need is not a person who lodges a CRICOS form; it is an adviser who can design a compliance system across five areas where private providers are most often found wanting, namely the CRICOS application itself, the ESOS procedures that sit behind it, agent management, course progress monitoring and any offshore delivery. In each area the adviser's job is to build something the provider will run without them, and to leave a record showing the governing body decided.
This article sets out where a consultant adds value on the international side and where they should not be doing the provider's work for it, drawn from fifteen years of TEQSA and CRICOS advisory work with private higher education providers.
Where a TEQSA consultant international students work starts: the CRICOS application
CRICOS registration is a second application, made after higher education registration, and it is assessed against the National Code 2018 rather than the Threshold Standards. TEQSA's guidance on applying for CRICOS estimates that a provider starting from first engagement will not deliver to international students for at least 35 months, or 29 months after lodging its higher education application, and it gives an applicant 28 days to respond to concerns raised during assessment. The initial CRICOS fee is $24,500 on the 2026 fee schedule.
A consultant's contribution at this stage is sequencing and completeness. In my experience the CRICOS applications that draw concerns are ones where the written agreement template, refund policy, agent agreement and course progress policy were drafted after the higher education application rather than alongside it, so that the two sets of documents disagree. The adviser's first task is to make the National Code layer consistent with the Threshold Standards policies already approved, which is a design job, not a form-filling one. The distinction between the two registrations is set out in our article on TEQSA accreditation versus CRICOS registration.
Designing ESOS compliance the provider can run
The National Code is procedural. It specifies what must be in a written agreement, what an orientation must cover, when a student can be reported, how long an appeal period runs. A consultant who knows it well can build the procedures, templates, registers and calendar in a few weeks. What a consultant cannot do is operate them, and the failure I see is a provider that treats the delivered procedure manual as compliance.
The adviser's job here is to design for the people who will do the work: a registrar who will issue confirmations of enrolment, an adviser who will run interventions, a finance officer who will process refunds under the Tuition Protection Service rules. Each procedure should name a role, a trigger, a deadline and a record. The substantive obligations each procedure serves are explained in our article on supporting international students under TEQSA and ESOS.
Agent management is where advisers earn their fee
Standard 4 of the National Code makes the provider responsible for its education agents: written agreements, monitoring, and termination where an agent behaves dishonestly. In my experience this is the area where a provider most needs outside experience, because the commercial pressure to accept any agent who brings students is strong and the consequences of a bad agent arrive slowly and then all at once.
A consultant should build the agent due diligence process, the agreement template, the performance monitoring against visa refusals, attrition and complaints, and the review cycle the governing body sees. The decision remains the provider's, and the board minutes should show that it was made on the basis of the data the process produced, not the consultant's say-so.
Course progress monitoring and the reporting decision
National Code Standard 8 requires the provider to monitor course progress and to report students who fail to meet requirements after an intervention strategy has been tried. Getting this wrong in either direction is costly: reporting too readily produces appeals and complaints, and failing to report leaves the provider with students whose visa condition it is not enforcing. A consultant's value is in designing the intervention strategy so that the academic progression process under Standard 1.3 of the Threshold Standards and the National Code process are one process with one file.
The reporting decision, though, is an academic and administrative judgment about a particular student, made by the provider's own staff. I have seen providers outsource that judgment to an adviser, and it does not survive scrutiny, because the regulator asks who decided and the answer has to be someone inside the institution.
Offshore delivery raises the stakes
Some providers want to deliver to international students in their home country, through a partner or their own campus. That engages Standard 5.4 of the Threshold Standards on delivery with other parties, TEQSA's authorised offshore provider arrangements, and, if the students will later come to Australia, the CRICOS rules on the onshore component. The fee for authorised offshore provider status is $36,800 on the same fee schedule.
The consultant's role in offshore delivery is largely governance: making sure the third-party agreement gives the provider control of admission, assessment and certification, that the academic board approves and reviews the arrangement, and that a new arrangement is notified to TEQSA as a material change within fourteen days. Shorter offerings delivered offshore raise their own questions, considered in our article on micro-credentials and international students.
What I tell providers about using an adviser on the international side
Use a TEQSA consultant international students work is designed by, not run by. The adviser should leave you with a system, trained people, a set of records that will fill themselves as students arrive, and board papers that show your governing body made the decisions. If the consultant is still needed to lodge every PRISMS entry a year after CRICOS registration, the engagement has failed.
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Frequently asked questions
Can a consultant lodge a CRICOS application on our behalf?
A consultant can prepare and help lodge it, but the provider is the applicant, the governing body is responsible for its contents, and the record must show the board approved it. TEQSA will direct its questions to the provider, not the adviser.
How long after TEQSA registration can we enrol international students?
TEQSA estimates delivery to international students at least 35 months after first engagement with the regulator, or 29 months after lodging the higher education application, once CRICOS assessment, visa processing and recruitment lead times are included.
What does a consultant do about education agents?
Build the due diligence process, agreement template, monitoring against visa refusals, attrition and complaints, and the review cycle the governing body sees. The decision to appoint or terminate an agent remains the provider's.
Do we need TEQSA approval to deliver offshore?
Delivery with another party engages Standard 5.4 of the Threshold Standards, and a new third-party arrangement is a material change to be notified within fourteen days. Delivering as an authorised offshore provider requires a separate application, with a fee of $36,800 on the 2026 schedule.
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.