Category: Quality assurance

  • Risk-based quality regulation – drivers and dynamics in Australian higher education

    Risk-based quality regulation – drivers and dynamics in Australian higher education

    by Joseph David Blacklock, Jeanette Baird and Bjørn Stensaker

    Risk-based’ models for higher education quality regulation have been increasingly popular in higher education globally. At the same time there is limited knowledge of how risk-based regulation can be implemented effectively.

    Australia’s Tertiary Education Quality and Standards Agency (TEQSA) started to implement risk-based regulation in 2011, aiming at an approach balancing regulatory necessity, risk and proportionate regulation. Our recent published study analyses TEQSA’s evolution between 2011 and 2024 to contribute to an emerging body of research on the practice of risk-based regulation in higher education.

    The challenges of risk-based regulation

    Risk-based approaches are seen as a way to create more effective and efficient regulation, targeting resources to the areas or institutions of greatest risk. However, it is widely acknowledged that sector-specificities, political economy and social context exert a significant influence on the practice of risk-based regulation (Black and Baldwin, 2010). Choices made by the regulator also affect its stakeholders and its perceived effectiveness – consider, for example, whose ideas about risk are privileged. Balancing the expectations of these stakeholders, along with their federal mandate, has required much in the way of compromise.

    The evolution of TEQSA’s approaches

    Our study uses a conceptual framework suggested by Hood et al (2001) for comparative analyses of regimes of risk regulation that charts aspects respectively of context and content. With this as a starting point we end up with two theoretical constructs of ‘hyper-regulation’ and ‘dynamic regulation’ as a way to analyse the development of TEQSA over time. These opposing concepts of regulatory approach represent both theoretical and empirical executions of the risk-based model within higher education.

    From extensive document analysis, independent third-party analysis, and Delphi interviews, we identify three phases to TEQSA’s approach:

    • 2011-2013, marked by practices similar to ‘hyper-regulation’, including suspicion of institutions, burdensome requests for information and a perception that there was little ‘risk-based’ discrimination in use
    • 2014-2018, marked by the use of more indicators of ‘dynamic regulation’, including reduced evidence requirements for low-risk providers, sensitivity to the motivational postures of providers (Braithwaite et al. 1994), and more provider self-assurance
    • 2019-2024, marked by a broader approach to the identification of risks, greater attention to systemic risks, and more visible engagement with Federal Government policy, as well as the disruption of the pandemic.

    Across these three periods, we map a series of contextual and content factors to chart those that have remained more constant and those that have varied more widely over time.

    Of course, we do not suggest that TEQSA’s actions fit precisely into these timeframes, nor do we suggest that its actions have been guided by a wholly consistent regulatory philosophy in each phase. After the early and very visible adjustment of TEQSA’s approach, there has been an ongoing series of smaller changes, influenced also by the available resources, the views of successive TEQSA commissioners and the wider higher education landscape as a whole.

    Lessons learned

    Our analysis, building on ideas and perspectives from Hood, Rothstein and Baldwin offers a comparatively simple yet informative taxonomy for future empirical research.

    TEQSA’s start-up phase, in which a hyper-regulatory approach was used, can be linked to a contextual need of the Federal Government at the time to support Australia’s international education industry, leading to the rather dominant judicial framing of its role. However, TEQSA’s initial regulatory stance failed to take account of the largely compliant regulatory posture of the universities that enrol around 90% of higher education students in Australia, and of the strength of this interest group. The new agency was understandably nervous about Government perceptions of its performance, however, a broader initial charting of stakeholder risk perspectives could have provided better guardrails. Similarly, a wider questioning of the sources of risk in TEQSA’s first and second phases could have highlighted more systemic risks.

    A further lesson for new risk-based regulators is to ensure that the regulator itself has a strong understanding of risks in the sector, to guide its analyses, and can readily obtain the data to generate robust risk assessments.

    Our study illustrates that risk-based regulation in practice is as negotiable as any other regulatory instrument. The ebb and flow of TEQSA’s engagement with the Federal Government and other stakeholders provides the context. As predicted by various authors, constant vigilance and regular recalibration are needed by the regulator as the external risk landscape changes and the wider interests of government and stakeholders dictate. The extent to which there is political tolerance for any ‘failure’ of a risk-based regulator is often unstated and always variable.

    Joseph David Blacklock is a graduate of the University of Oslo’s Master’s of Higher Education degree, with a special interest in risk-based regulation and government instruments for managing quality within higher education.

    Jeanette Baird consults on tertiary education quality assurance and strategy in Australia and internationally. She is Adjunct Professor of Higher Education at Divine Word University in Papua New Guinea and an Honorary Senior Fellow of the Centre for the Study of Higher Education at the University of Melbourne.

    Bjørn Stensaker is a professor of higher education at University of Oslo, specializing in studies of policy, reform and change in higher education. He has published widely on these issues in a range of academic journals and other outlets.

    This blog is based on our article in Policy Reviews in Higher Education (online 29 April 2025):

    Blacklock, JD, Baird, J & Stensaker, B (2025) ‘Evolutionary stages in risk-based quality regulation in Australian higher education 2011–2024’ Policy Reviews in Higher Education, 1–23.

    Author: SRHE News Blog

    An international learned society, concerned with supporting research and researchers into Higher Education

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  • Mind the policy gaps: regulating quality and ethics in digitalised and privatised crossborder education

    Mind the policy gaps: regulating quality and ethics in digitalised and privatised crossborder education

    by Hans de Wit, Tessa DeLaquil, Ellen Hazelkorn and Hamish Coates

    Hans de Wit, Ellen Hazelkorn and Hamish Coates are editors and Tessa DeLaquil is associate editor of Policy Reviews in Higher Education. This blog is based on their editorial for issue 1, 2025.

    Transnational education (TNE), also referred to as crossborder education, is growing and morphing in all kinds of interesting ways which, while exciting for innovators, surface important policy, regulatory, quality and ethical concerns. It is therefore vital that these developments do not slip around or through policy gaps. This is especially true for on-line TNE which is less visible than traditional campus-based higher education. Thus, it is vital that governments take the necessary actions to regulate and quality assure such education and training expansion and to inform the sector and broader public. Correspondingly, there is a pressing need for more policy research into the massive transformations shaking global higher education.

    TNE and its online variants have been part of international higher education for a few decades. As Coates, Xie, and Hong (2020) foreshadowed, it has seen a rapid increase after the Covid-19 pandemic. In recent years, TNE operations have grown and diversified substantially. Wilkins and Huisman (2025) identify eleven types of TNE providers and propose the following definition to help handle this diversity: ‘Transnational education is a form of education that borrows or transfers elements of one country’s higher education, as well as that country’s culture and values, to another country.’

    International collaboration and networking have never been more important than at this time of geopolitical and geoeconomic disruption and a decline in multilateral mechanisms. But TNE’s expansion is matched by growing risks.

    International student mobility at risk

    International degree student mobility (when students pursue a bachelor, master and/or doctoral degree abroad) continues to be dominant, with over six million students studying abroad, double the number of 10 years ago. It is anticipated that this number will further increase in the coming decade to over 8 million, but its growth is decreasing, and its geographical path from the ‘global south’ to the ‘global north’ is shifting towards a more diverse direction. Geopolitical and nationalist forces as well as concerns about adequate academic services (accommodation in particular) in high-income countries in the global north are recent factors in the slowing down of the growth in student mobility to Australia, North America and Europe, the leading destinations. The increased availability and quality of higher education, primarily at the undergraduate level, in middle-income countries in Asia, Latin America and parts of the Middle East, also shape the decrease in student mobility towards the global north.

    Several ‘sending countries’, for instance, China, South Korea and Turkey, are also becoming receiving countries. Countries like Kazakhstan, Uzbekistan, Ukraine (until the Russian invasion), Egypt and some of the Caribbean countries have also become study destinations for students from neighbouring low-income countries. These countries provide them with higher education and other forms of postsecondary education sometimes in their public sector but mostly in private institutions and by foreign providers.

    An alternative TNE model?

    Given the increased competition for international students and the resulting risks of falling numbers and related financial security for universities, TNE has emerged as an alternative source of revenue. According to Ilieva and Tsiligiris (2023), United Kingdom TNE topped more than 530,000 students in 2021. In the same year, its higher education institutions attracted approximately 680,000 international students. It is likely that TNE will surpass inward student mobility.

     As the United Kingdom case makes clear, TNE originally was primarily a ‘north-south’ phenomenon, in which universities from high-income and mostly Anglophone countries, offered degree programmes through branch campuses, franchise operations and articulation programmes. Asia was the recipient region of most TNE arrangements, followed by the Middle East. As in student mobility, TNE is more diverse globally both in provision and in reception.

    The big trend in TNE is the shift to online education with limited in-person teaching. A (2024) report of Studyportals found over 15,000 English-taught online programmes globally. And although 92 per cent of these programmes are supplied by the four big Anglophone countries – the United Kingdom, United States, Canada and Australia – the number of programmes offered outside those four doubled since 2019 from 623–1212, primarily in Business and Management, Computer Sciences and IT.

    Private higher education institutions

    This global growth in online delivery of education goes hand in hand with the growth in various forms of private higher education. Over 50% of the institutions of higher education and over one-third of global enrolment are in private institutions, many of which are commercial in nature. Private higher education has become the dominant growth area in higher education, as a result of the lack of funding for public higher education as well as traditional HE’s sluggish response to diverse learner needs. Although most private higher education, in particular for-profit, is taking place in the global south, it is also present in high-income countries, and one can see a rise in private higher education recently in Western Europe, for instance, Germany and France.

    TNE is often a commercial activity. It is increasingly a way for public universities to support international and other operations as public funding wanes. Most for-profit private higher education targets particular fields and education services and tends to be more online than in person. There is an array of ownership and institutional structures, involving a range of players.

    Establishing regulations and standards

    TNE, especially online TNE, is likely to become the major form of international delivery of education for local and international students especially where growing demand cannot be met domestically. Growth is also increasingly motivated by an institution’s or country’s financial challenges or strategic priorities – situations that are likely to intensify. This shift could help overcome some of the inequities associated with mobility and address concerns associated with climate change but online TNE is significantly more difficult to regulate.

    A concerning feature of the global TNE market is how learners and countries can easily become victims. Fraud is associated with the exponential rise in the number of fake colleges and accreditors, and document falsification. This is partly due to different conceptions and regulatory approaches to accreditation/QA of TNE and the absence of trustworthy information. Indeed, the deficiency in comprehensive and accessible information is partly responsible for on-going interest in and use of global rankings as a proxy for quality.

    A need for clearer and stronger TNE and online quality assurance

    The trend in growth of private for-profit higher education, TNE and online delivery is clear and given its growing presence requires more policy attention by national, regional and global agencies. As mentioned, public universities are increasingly active in TNE and online education targeting countries and learners underserved in their home countries whilst  looking for other sources of income as a result of decreasing public support and other factors.

    The Global Convention on the Recognition of Qualifications makes clear the importance of ensuring there are no differences in quality or standards between learners in the home or host country regardless of whether the delivery of education programmes and learning activities is undertaken in a formal, non-formal or informal setting, in face-to-face, virtual or hybrid formats, traditional or non-traditional modes. Accordingly, there are growing concerns about insufficient regulation and the multilateral framework covering international education, and especially online TNE.

    In response, there is a need for clearer and stronger accreditation/quality assurance and standards by national regulators, regional networks and organisations such as UNESCO, INQAAHE, the International Association of Universities (IAU) with regards to public and private involvement in TNE, and online education. This is an emerging frontier for tertiary education, and much more research is required on this growing phenomenon.

    Professor Ellen Hazelkorn is Joint Managing Partner, BH Associates. She is Professor Emeritus, Technological University Dublin.

    Hamish Coates is professor of public policy, director of the Higher Education Futures Lab, and global tertiary education expert.

    Hans de Wit is Professor Emeritus and Distinguished Fellow of the Boston College Center for International Higher Education, Senior Fellow of the international Association of Universities.

    Tessa DeLaquil is postdoctoral research fellow at the School of Education at University College Dublin.

    Author: SRHE News Blog

    An international learned society, concerned with supporting research and researchers into Higher Education

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