IHEA Submission | ATEC Review of Research Requirements: ‘Australian University Category’ in the Higher Education Standards Framework

7 September 2026: IHEA responded to the Australian Tertiary Education Commission (ATEC) Review of Research Requirements: ‘Australian University Category’ in the Higher Education Standards Framework (Threshold Standards).

IHEA represents Australia’s five private universities and 80 independent higher education providers. These institutions make a vital contribution to Australia’s higher education and research ecosystem, but they operate under materially different funding, scale and structural conditions from the large, research−intensive Table A universities.

IHEA strongly supports the policy objective of enabling greater research specialisation and institutional differentiation, as articulated in Recommendation 37.f.ii of the Australian Universities Accord Final Report and the 2025 Strategic Examination of Research Development (SERD). A university should be able to demonstrate research excellence, capability and sustainability through a focused research profile without being required to replicate the breadth, scale, research workforce or infrastructure of a large research−intensive university.

The consultation paper provides a basis for considering greater specialisation, but the detailed regulatory model and drafting have not yet been developed. IHEA therefore considers further consultation essential before changes are finalised, including on the evidence required, how different research profiles would be assessed by TEQSA.

The objective should be a clear and credible research quality threshold that allows universities to demonstrate capability and sustainability through research profiles that reflect their missions, strengths, scale and circumstances.