March 16, 2026
IRU response to proposed changes to the Higher Education Standards Framework (Threshold Standards) 2021
The Innovative Research Universities (IRU) welcomes the opportunity to provide feedback on proposed changes to the Higher Education Standards Framework (Threshold Standards) 2021.
The Threshold Standards play a critical role in maintaining the high quality of Australia’s higher education system and providing the basis for regulation and registration by the Tertiary Education Quality and Standards Agency (TEQSA).
The IRU supports the important role of the Higher Education Standards Panel (HESP) in providing independent advice to government on the Threshold Standards and regulation. We welcome the HESP’s stated commitment to transparent and inclusive consultation processes to inform its advice on potential updates to the Standards.
In previous policy submissions (including through the Australian Universities Accord), the IRU has supported the ongoing role of the Threshold Standards to provide a standard baseline for universities, while also allowing for increased differentiation among institutions and greater focus on the distinct needs of their students and communities.
In our recent submissions, we have also noted the increasing multiple layers of regulation and reporting that apply to Australian universities and called for a whole-of-system review to identify existing duplication/overlap and opportunities for streamlining. We welcome the recent announcement by Education Minister the Hon Jason Clare MP of a new Better Regulation Working Group, designed to “streamline processes and improve efficiency”. This will hopefully allow universities to focus more resources on their core functions of teaching and research, and create room for more innovation and differentiation.
The IRU supports the establishment of the new Australian Tertiary Education Commission (ATEC) to improve stewardship of the tertiary system. We agree in principle that the functions of the HESP could be incorporated within the ATEC, but we have recommended that the ATEC should maintain an advisory committee like the HESP to provide it with independent advice on the Threshold Standards and their implementation. Under the new ATEC, there should also be a clear demarcation between the new mission-based compact agreements (which should focus on differentiation of institutional missions and performance) and compliance/regulation activities linked to the Threshold Standards.
We provide more detailed feedback below on each of the four priority areas discussed in the consultation paper. We welcome the HESP’s commitment to open consultation on proposed changes to the Threshold Standards and recognise that there is an inherent tension between early engagement to stimulate discussion on priorities for change and being able to provide more detail about specific changes.
In general, the IRU supports the intent of periodic review and targeted amendments to ensure that the Threshold Standards remain relevant and up-to-date. However in some specific cases (as outlined below) we believe that more detail will be needed before we can provide a clear view on the pros and cons of specific changes. The short timeline for this consultation process has also made it difficult to consult broadly across our member universities.
We seek to engage constructively with the HESP, ATEC and TEQSA on these important issues. We have provided our initial feedback on each of the four priority areas below and would be happy to continue to engage on more detailed proposals for changes to the Threshold Standards as they are developed.
