Research consultants TEQSA applicants engage are worth the fee in exactly three situations: when a provider wants to offer a higher degree by research, when it wants to change category to University College or Australian University, and when its accredited coursework is at AQF level 9 or 10 in a field where scholarship must be demonstrably active. Outside those situations, most private providers do not need research advice.
This article explains what Domain 4 of the Threshold Standards requires, what changes when a provider moves into research training or a research-based category, and how to tell whether research advice is needed at all. It is written from fifteen years of TEQSA registration and category work with private providers.
What Domain 4 actually requires
Domain 4 of the Higher Education Standards Framework (Threshold Standards) 2021 covers Research and Research Training in two standards. Standard 4.1 requires research, where undertaken, to be conducted with integrity within a policy framework and with oversight. Standard 4.2 covers research training: supervision, candidature, examination and the research environment for higher degree by research students.
The first thing to notice is the conditional. Domain 4 applies where research or research training is undertaken. An Institute of Higher Education offering coursework degrees is not required to conduct research, and TEQSA does not assess it against Standard 4.2. What every provider is required to show is scholarship: Standard 3.2 requires staff to be active in scholarship that informs their teaching, and Standard 3.1 requires course content to be informed by current knowledge and scholarship. That is a lower bar than research, and it is the one most private providers should concentrate on.
When research consultants TEQSA applicants engage add value
The first situation is a higher degree by research. A provider that wants to accredit a Master of Philosophy or a professional doctorate with a research component takes on Standard 4.2 in full: a research training policy, supervisor eligibility and registration, candidature milestones, thesis examination by external examiners, and an environment in which the candidate can actually do the research. Building that from nothing is a specialist task.
The second is a change of category. The University College and Australian University categories in Part B1 carry research requirements that the Institute of Higher Education category does not. An Australian University must undertake research at the standard set by the Quality of Research Determination 2021 in at least three broad fields, offer higher degrees by research, and meet the research expectations in TEQSA's guidance note on research requirements for Australian universities. A change of category application under section 38 of the TEQSA Act costs $51,800, and the research evidence is what most providers underestimate. I have set out the data on this route in setting up a university in Australia.
The third is level 9 and 10 coursework with a substantial research project, which needs supervisors, an ethics pathway and a research integrity framework even if it is not a higher degree by research in the strict sense.
What research governance looks like at a small provider
Research governance needs a research policy adopted by the academic board, a research integrity framework aligned to the Australian Code for the Responsible Conduct of Research, an ethics review pathway, usually an arrangement with an external human research ethics committee, and a research committee that reports to the academic board.
In my experience the mistake is to create these documents for the application and never convene the committee. Standard 4.1 is written in the present tense, like every other standard, and TEQSA reads it for evidence of operation. A research committee with minutes, an ethics approval on file and an integrity case handled under the framework are the evidence. The governance and leadership dimension of this is covered in our article on the role of governance and leadership in setting up a university.
The University College and Australian University research criteria
Since 1 July 2021 there have been four provider categories. A University College is a step toward university status and is expected to demonstrate a developing research culture and, where it offers research training, compliance with Standard 4.2. An Australian University must meet the Quality of Research Determination across three broad fields and offer research training in those fields.
Where consultants earn their fee here is in the honest assessment of distance. A provider with twenty academic staff, most of them practitioners, and no research output is not eighteen months from University College. It is years and a substantial recruitment budget away, and research consultants TEQSA applicants should trust will say so. Innovation, incidentally, is not a Threshold Standard; providers that call themselves research and innovation institutes should be able to point to the research. That includes short courses, which I discuss in micro-credentials and the role of research and innovation.
How to decide whether you need research advice
Ask three questions: whether you intend to enrol a higher degree by research student within three years, whether you intend to apply for a change of category within five, and whether any course requires a supervised research project needing ethics approval. If the answer to all three is no, your regulatory task is scholarship under Standard 3.2, and the money is better spent on a staff scholarship plan.
If the answer to any of them is yes, engage someone who has built research governance before, and engage them early, because the research environment must be evidenced in operation before TEQSA will accredit the research degree or approve the category.
My view after fifteen years
Research is where private providers most often overreach. My advice is the same in every case: be excellent at scholarship first, build research governance only when a real research activity requires it, and treat the University College criteria as a destination to be earned rather than a label to be applied for.
Download the Darlo Threshold Standards Map
— a one-page map of every standard, including Domain 4 and Part B, showing which apply to your provider category, drawn from our TEQSA registration and governance work with private providers. Get the map
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Frequently asked questions
Does a private higher education provider have to do research?
Not unless it undertakes research or research training, or seeks the University College or Australian University category. Every provider must show scholarship under Standard 3.2, which is a different and lower requirement.
What does Standard 4.2 require for a higher degree by research?
A research training framework covering supervisor eligibility, candidature management, milestones, external examination of theses, and a research environment that supports the candidate, all operating before TEQSA will accredit the degree.
What research does an Australian University need?
Research at the standard set by the Quality of Research Determination 2021 in at least three broad fields of education, together with higher degrees by research, as set out in TEQSA's guidance note on research requirements.
Does a small provider need its own ethics committee?
Usually not. Most small providers meet Standard 4.1 through a written arrangement with an external human research ethics committee, provided the arrangement is documented and the academic board oversees its use.
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.