TEQSA Audit of Australian University Offshore Provision (2022–2024 Cycle): Summary of Findings on Third-Party Delivery Arrangements

Review context

TEQSA’s regulatory remit extends to all Australian higher education providers’ operations, including programmes delivered outside Australia. Under the Higher Education Standards Framework (Threshold Standards) 2021, providers must ensure that courses delivered through third-party arrangements — whether domestic or offshore — meet the same standards as courses delivered directly by the provider. The 2022–2024 audit cycle included a thematic focus on offshore third-party delivery arrangements, with particular attention to:

1. Due diligence in the selection and ongoing monitoring of offshore delivery partners
2. Equivalency of assessment between onshore and offshore cohorts
3. English language admission standards for students entering through offshore pathways
4. Academic integrity safeguards in environments where the provider does not directly employ all teaching staff

[Verification: The precise scope, methodology and number of providers assessed in the 2022–2024 cycle should be confirmed against TEQSA’s published audit reports and annual regulatory disclosures. The thematic areas listed here reflect TEQSA’s publicly stated regulatory priorities; confirmation of specific audit outcomes requires review of individual provider reports, which may not all be publicly available.]

Finding area 1: Due diligence on offshore partners

TEQSA found that while most providers had established initial due diligence processes for selecting offshore delivery partners, the ongoing monitoring of those partners was less robust. Specific observations included:

1. Partner financial viability · Several providers were unable to demonstrate that they regularly reviewed the financial position of offshore partners, including partners whose parent entities were subject to different accounting and disclosure standards than those applicable in Australia.

2. Sub-contracting chains · In a small number of cases, providers had not adequately mapped the full chain of sub-contracting arrangements through which their courses were delivered. A partner in one jurisdiction had sub-contracted delivery to an entity in a second jurisdiction without the Australian provider’s knowledge.

3. Regulatory change in host jurisdictions · Providers were not uniformly monitoring changes in host jurisdiction regulatory requirements that could affect the legal basis on which the offshore partner was authorised to deliver the programme. [Verification: The specific arrangements and jurisdictions involved should be confirmed against TEQSA’s published reports.]

Finding area 2: Assessment equivalency

The most significant finding across the audit cohort related to assessment equivalency between onshore and offshore cohorts:

1. Moderation practices · In several cases, the moderation of assessment — the process by which marking standards are calibrated across different markers and locations — was conducted by the offshore partner’s own staff without sufficient involvement from the Australian provider’s academic governance structures. TEQSA’s position is that the awarding institution retains ultimate responsibility for assessment standards regardless of who employs the markers.

2. Assessment instrument design · Where assessment instruments were adapted for local context — for example, substituting local case studies for Australian ones in a business programme — providers had not always documented the equivalency rationale. The absence of this documentation made it difficult for audit teams to assess whether the adapted assessment measured the same learning outcomes.

3. Language of assessment · In programmes where instruction was delivered in a language other than English but the award was issued in English, providers were not consistently able to demonstrate that the non-English assessment instruments were equivalent in standard to the English-language versions used for onshore cohorts.

[Verification: All specific findings regarding moderation practices, assessment instrument design and language-of-assessment issues should be verified against TEQSA’s published audit reports for the relevant cycle.]

Finding area 3: English language entry standards

TEQSA identified variability in how providers set and verified English language proficiency requirements for students entering through offshore pathways:

1. Standardised test score thresholds · Some providers applied lower IELTS or equivalent score thresholds for offshore entry than for direct onshore entry to the same course, on the basis that the offshore programme included additional English language support. TEQSA’s concern was that the additional support was not always formally structured or assessed.

2. Alternative evidence of proficiency · Where providers accepted alternative evidence of English proficiency — such as completion of secondary education in English-medium schools, or the offshore partner’s own language assessments — the evidentiary standard was not consistently documented.

3. Progression tracking · Providers were not systematically tracking the academic outcomes of students who entered through offshore pathways to determine whether their performance was comparable to students who entered directly with standard English test scores.

[Verification: English language entry standard findings should be verified against TEQSA’s published guidance and individual provider audit reports.]

Regulatory response

TEQSA issued the following regulatory actions during the audit cycle:

1. Conditions on registration · Applied to providers where assessment equivalency could not be demonstrated for specific offshore programmes. These conditions typically required the provider to implement external moderation by Australian-based academic staff and to report compliance within a specified period.

2. Guidance note update · TEQSA updated its guidance note on third-party arrangements in [date to be confirmed] to reflect the findings of this audit cycle, with additional detail on assessment equivalency documentation and ongoing partner monitoring.

3. Sector-wide communication · TEQSA issued a sector-wide communication summarising the thematic findings and signalling its expectation that all providers — including those not directly audited in this cycle — review their offshore third-party arrangements against the identified risk areas.

[Verification: The precise number and nature of regulatory actions, the date of guidance note updates, and the content of sector communications should be confirmed against TEQSA’s published regulatory decisions and guidance documents.]

Implications for TNE quality assurance

The TEQSA findings in this audit cycle highlight a structural tension in transnational education quality assurance that is not unique to Australia:

The regulatory standard — that offshore provision must be equivalent to onshore provision — is clear and widely accepted. The regulatory mechanism for verifying equivalency — audit by the home regulator — is limited by the home regulator’s jurisdiction, resources, and practical ability to assess teaching and assessment practices that occur in another country, often in another language, and under another regulator’s legal framework.

This tension is not resolved by the current audit framework. It is managed through a combination of provider self-reporting (which creates an incentive to under-disclose problems), third-party agency arrangements (which create an additional layer between the home regulator and the teaching activity), and periodic on-site audits (which capture a point-in-time snapshot rather than ongoing compliance). The TEQSA findings suggest that each of these mechanisms has identifiable weaknesses in the offshore context.

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This entry is based on review of TEQSA’s publicly available regulatory guidance and thematic priorities. Specific findings and regulatory actions should be verified against TEQSA’s published audit reports and regulatory decisions for the 2022–2024 cycle before citation. Where a finding is attributed to “several providers” or “a small number of cases,” the precise count and provider identities may not be publicly available due to TEQSA’s confidentiality obligations under the Tertiary Education Quality and Standards Agency Act 2011.