by: Michelle Mosiere

Recent developments across the sector point to one clear shift – expectations around risk are tightening, and regulators are becoming more explicit about what “good” looks like in practice. There are four recent updates in particular worth paying attention to:

1. Student Safety & Complaints Handling Under Scrutiny

The National Student Ombudsman (NSO) has criticised how some universities are handling student complaints, particularly around safety, delays, and lack of transparency.

This is no longer just an operational issue. It’s being treated as:

• A student safety risk
• A governance failure
• A reputational exposure

There’s a clear expectation that complaints processes are consistent, monitored, and visible at an executive level – not handled in silos.

2. TEQSA’s New Risk Framework (Consultation Open)

TEQSA has opened consultation on a new regulatory risk framework (as at 20 March), signalling a more targeted and data-driven approach to regulation.

This is not a minor adjustment – it signals a more structured and explicit approach to how TEQSA will:

• Assess provider risk profiles
• Prioritise regulatory attention
• Determine monitoring intensity and intervention

The direction of travel is clear:

• More targeted regulation (less one-size-fits-all)
• Greater reliance on risk indicators and data
• Stronger linkage between provider behaviour and regulatory scrutiny

For providers, this raises the bar on internal capability. It won’t be enough to say you manage risk. You will need to demonstrate:

• Clear risk identification frameworks
• Active monitoring and reporting
• Evidence of mitigation actions and follow-through

If your risk register is static, compliance-driven, or disconnected from decision-making, it will not stand up in this environment.

3. Possible Changes to the HESF

Early signals suggest the HESF may be overhauled to better reflect current sector risks.

While details are still emerging, the intent appears to be:

• Simplifying and clarifying standards
• Aligning more closely with contemporary risks (including student safety and quality assurance)
• Reducing ambiguity in expectations

This matters because the HESF underpins everything: governance, academic quality, student support, and risk management.

Any changes are likely to:

• Increase expectations around self-assurance
• Strengthen requirements for evidence of effectiveness, not just compliance
• Further embed risk-based thinking across all Domains

Providers that treat the HESF as a checklist will struggle. The direction is towards demonstrating that systems actually work in practice.

4. International Student Policy Tightening

Ongoing changes to international student settings, including visa costs and post-study work arrangements, are adding pressure across the sector.

While these sit outside provider control, they introduce real risk at an institutional level including:

• Enrolment volatility and revenue exposure
• Increased reliance on fewer markets or cohorts
• Heightened scrutiny on recruitment practices and agent management

For providers, this reinforces the need for:

• Clear oversight of international strategy and dependencies
• Strong controls around third-party recruitment
• Evidence of sustainable enrolment and financial planning

This is no longer just a market issue; it is increasingly being viewed through a regulatory and risk lens.

What This Means

Across all four updates, the message is consistent:

Risk is now central to how providers are assessed – not just a side function.

Providers should be able to clearly demonstrate:

• How issues are identified and escalated
• How risks are monitored and acted on
• How data is used to drive decisions

The real exposure isn’t a lack of frameworks – it’s a lack of evidence that they’re working.

How DVE Can Support

DVE is working with providers across the sector to strengthen risk maturity in practical, defensible ways — not just frameworks on paper.

This includes:

• Reviews of complaints handling and student safety processes
• Uplift of risk frameworks and registers to align with TEQSA expectations
• Governance and reporting improvements to support board-level assurance
• Targeted health checks to identify gaps ahead of regulatory scrutiny

If you’re unsure whether your current approach would hold up under increased scrutiny, it’s worth having that conversation early. Contact us via info@dvesolutions.com.au or 1800 870 677.