TEQSA evidence and documentation comes in three kinds, and the difference between them decides whether an application succeeds: policies, which show what the provider says it does; records, which show the policy being applied to a particular student, course or decision; and data, which show the pattern across all of them over time. Assessors expect all three for every domain of the Threshold Standards, and an application that offers only the first is offering evidence of existence when the standards, written in the present tense, require evidence of operation.
This article walks through the seven domains and names the documents and records that evidence each, then explains how an evidence index ties them to the self-assurance report. It draws on fifteen years of assembling TEQSA registration and renewal submissions for private providers, and on the requests for further information that follow when the three kinds are confused.
Policy, record and data: the distinction that organises everything
A policy is a statement of intent adopted by a governing body. A record is a document produced when the policy was applied: an admission decision, a credit assessment, a set of minutes, a complaint file, a moderation report. Data is what the records look like in aggregate: admission outcomes by pathway, progression and attrition by course, complaint volumes and resolution times, grade distributions by unit.
The Threshold Standards rarely ask for a policy alone. Standard 1.1.1, for example, requires that admission is based on academic preparation and proficiency, which is evidenced by the admission policy, by records of individual admission decisions, and by data showing that students admitted under each pathway went on to succeed. A provider that supplies the policy and nothing else has answered a third of the question, and since TEQSA retired Confirmed Evidence Tables in favour of self-assurance, the assessor is no longer telling you which two thirds are missing. The reasons providers find this hard are examined in our article on the difficulty of providing evidence for TEQSA registration.
Domain 1: students, from admission to certification
Domain 1 covers admission, credit, orientation and progression, learning outcomes and assessment, and qualifications and certification. The policy layer is the admissions policy, credit and RPL policy, assessment policy and certification policy. The record layer is admission files showing the basis of each decision, credit decisions with the learning outcomes mapping behind them, orientation attendance, at-risk student interventions, moderated assessment samples with marker comments, and testamurs and transcripts issued.
The data layer is where assessors spend their time on an operating provider: admission outcomes by entry pathway, progression and completion rates by course and cohort, grade distributions with outliers explained, and the volume and outcome of academic appeals. For a prospective provider without students, the record and data layers are replaced by the templates, forms and reporting design that will produce them, and assessors check that those exist and match the policies.
Domain 2: the learning environment
Domain 2 covers facilities, diversity and equity, wellbeing and safety, and grievances and complaints. The policies are the equity, wellbeing, critical incident and complaints policies. The records are the lease or facilities agreement, the accessibility audit, the welfare referral register, the critical incident log, and every complaint file with its timeline. The data is complaint volumes, categories and resolution times, and any incidents reported to the governing body.
The most common gap is a complaints policy with no complaints behind it. Assessors do not read an empty complaints register as evidence of a contented student body; they read it as evidence that students do not know how to complain or that the register is not kept. A register with entries, resolution times within policy, and a report to the board is what the standard looks like in operation.
Domain 3: teaching, staffing and resources
Domain 3 covers course design, staffing and learning resources. The policy layer is the course design and approval policy, the academic staffing policy and the learning resources policy. The record layer is the course documents themselves, the staffing matrix with CVs, staff appointment records, scholarship activity records, library and learning system access records, and evidence of educational support offered to students.
The data is teaching evaluation results, staff qualification profiles by course, library and learning platform usage, and student feedback on resources. Where teaching is delivered online, assessors look for platform analytics that show students actually using the resources the policy promises. The documents that make up the policy layer across all domains are listed in our article on TEQSA-ready policies and procedures.
Domain 4 and Domain 5: research and institutional quality assurance
Domain 4 applies only to providers with research or research training, and for most private providers the evidence is a statement that it does not apply. Domain 5 applies to everyone. It covers course approval and accreditation, academic and research integrity, monitoring, review and improvement, and delivery with other parties. This is the domain where the difference between a policy and a record is most visible, because Standard 5.3 requires an actual cycle of review to have taken place.
The policy layer is the course approval, academic integrity and course review policies. The record layer is academic board approval minutes, external course review reports, annual course reports, academic integrity case files and the register of breaches, third-party agreements and the monitoring reports on them. The data layer is the outcomes of the review cycle over time: what was found, what changed, and whether it worked. A provider at renewal that cannot show at least one completed cycle from review to action to evaluation has no Domain 5 evidence, however good its policies.
Domain 6 and Domain 7: governance and information
Domain 6 covers corporate governance, corporate monitoring and accountability, and academic governance. The policies are the constitution, terms of reference, delegations schedule, conflicts of interest policy and risk management framework. The records are board and academic board minutes and papers, the conflicts register with declarations, the risk register with review dates, fit and proper person declarations, financial reports to each meeting, and the independent reviews of governance TEQSA requires at renewal. The data is attendance, the flow of academic quality reports from the academic board to the corporate board, and the financial results against budget.
Domain 7 covers representation, information for students, and information management. The policies are marketing, student information and records management policies. The records are the published course information, the website as it stood on given dates, student agreements and the privacy and data security arrangements. The data is any complaints about misleading information and the results of the provider's own checks of its marketing against the accredited course.
How the evidence index makes TEQSA evidence and documentation usable
TEQSA's renewal of registration guide requires a self-assurance report of no more than ten pages, supported by an evidence index. The index is the document that turns a cupboard of files into a submission. It lists each standard, the provider's claim about it in a sentence, and the policy, records and data that support the claim, with a reference the assessor can follow.
In my experience the index does two jobs. It shows the assessor where to look, which shortens assessment and reduces requests for further information. And it shows the provider where the evidence is thin before the assessor does, because a row with a policy reference and nothing in the record and data columns is a gap that can be seen at a glance. The same structure works for an initial registration, with the record and data columns showing the templates and reporting design that will produce evidence once students arrive. A checklist form of it is in our TEQSA registration checklist for new providers.
What I tell providers about assembling the file
Build the index first, before any document is written or gathered, and fill it standard by standard with the three kinds of evidence. Where a policy exists but no record does, the answer is not to draft a better policy; it is to apply the one you have and keep the record. Where a record exists but the board never saw the pattern, the answer is a report. TEQSA evidence and documentation is, in the end, a description of a provider that knows what it does and can prove it, and the index is where that knowledge is laid out.
Download the Darlo Re-registration Evidence Index Template
— a standard-by-standard index with policy, record and data columns, drawn from our TEQSA registration and governance work with private providers. Get the template
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Frequently asked questions
What is the difference between a policy and evidence for TEQSA?
A policy states what the provider intends to do. Evidence of operation is the records produced when the policy was applied and the data showing the pattern across those records. TEQSA expects all three for each standard, because the standards are written in the present tense.
Does TEQSA require evidence against every Threshold Standard?
Not at renewal. TEQSA's assessment is risk-based and it does not require evidence against every standard, but the self-assurance report must be supported by an evidence index, and assessors may ask for evidence on any standard where risk or the provider's history warrants.
What is an evidence index?
A table listing each Threshold Standard, the provider's claim about it, and the policies, records and data that support the claim, with references an assessor can follow. It accompanies the self-assurance report at renewal and organises an initial registration application in the same way.
What evidence does TEQSA expect from a provider with no students yet?
Policies, the templates and forms that will produce records, and the reporting design that will produce data once students enrol, together with governance records showing the board adopted them. Assessors check that the templates match the policies and that the reporting design reaches the governing body.
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.