There is a growing sophistication in how Australia regulates higher education risk.
The sector has moved decisively toward a more structured, transparent, and risk-based model of oversight. The consultation on TEQSA’s proposed Regulatory Risk Framework (RRF) signals a system that is becoming more coherent: more explicit about what matters, and more disciplined in how risk is understood and assessed.
On most dimensions, this is a welcome development.
But there is one issue that sits uncomfortably within this emerging architecture.
It is rarely addressed directly.
And yet, it is increasingly shaping the viability of institutions across the sector.
Visa grant rates.
A Risk Framework Built on Institutional Control
The logic underpinning the RRF is sound.
It identifies key areas of provider-level risk (governance, financial sustainability, academic quality, student experience) and frames them in a way that emphasises institutional responsibility. Providers are expected to understand, monitor, and manage these risks through mature self-assurance systems.
This reflects a long-standing principle of higher education regulation:
institutions are accountable for the quality and sustainability of their operations.
In most cases, that principle holds.
A governing body can influence governance quality.
A provider can invest in teaching, staffing, and student support.
Financial performance can be managed through planning and oversight.
Risk, in this model, is something that can be acted upon.
The Variable That Sits Outside the Institution
International education complicates this picture.
A provider may meet all regulatory standards, recruit genuine students, and operate with strong governance… and still experience a collapse in enrolments.
The cause is not internal failure.
It is external constraint.
Visa grant rates (determined through government policy and its enactment) remain a decisive factor in student flows.
In effect, a critical input into institutional performance remains beyond institutional control.
The Missing Layer: Social Licence
Always contentious, visa grant rates are now a proxy for social licence.
Across the political spectrum, international education is now tied to debates about migration, housing, and infrastructure.
It is difficult to avoid the conclusion that sections of the political right have taken a more sceptical stance toward international students, and that the current government, sensing electoral pressure, is adjusting accordingly.
Visa settings become a lever, not just for migration, but for public reassurance.
Policy Signalling, Institutional Consequence
At the policy level, adjustments are framed as necessary.
At the institutional level, they translate into enrolment volatility, financial stress, and uncertainty.
Providers are left managing consequences they do not control.
The Elephant is Not for Moving
Risk-based regulation is evolving in the right direction.
But no framework is complete if it omits the most consequential variables shaping institutional outcomes.
Visa grant rates are, as they always have been, one of those variables.
And increasingly, they reflect political positioning as much as policy.
Until this is acknowledged, the conversation about risk remains incomplete.
The elephant remains… sitting squarely on the table.
Emeritus Professor Clive Smallman is a non-executive director, Academic Board chair and advisor working with several independent higher education providers.
