Academia

In Stella v Griffith University [2025] QCA 203 Bradley JA comments 

 [5] The respondent (the University) is a university established by statute to advance, develop and disseminate knowledge and promote scholarship, with a focus on study, research, and recognition in the form of conferring degrees. 

[6] A well-tempered university serves the public interest, including in ways identified in Schedule 4, Part 2 of the Right to Information Act 2009 (Qld) (RTI Act). It can promote open discussion of public affairs, contribute to positive and informed debate on important issues or matters of serious interest, ensure effective oversight of expenditure of public funds, allow or assist inquiry into possible deficiencies in the conduct or administration of an agency or official, advance the fair treatment of individuals and other entities in accordance with the law in their dealings with agencies, contribute to the protection of the environment, reveal environmental or health risks or measures relating to public health and safety, contribute to the maintenance of peace and order, contribute to the administration of justice generally or for a person, and contribute to innovation and the facilitation of research. 

[7] Students share a status as members of the university with the chancellor and others in administration, and the academic staff in teaching and research roles. The relationship between university members has been described as domestic.  Its quality may vary from time to time. It may be at its best when aligned and directed to the university’s noble objects; and at its least when splintered or transactional. The relationship is not that between a customer and a service provider.Mr Stella s analysis of a student as a “client” of a university is wholly inadequate. 

[8] Whatever the state of the relationship, it is important that university decision-makers can engage openly with colleagues about how they should deal with a complaint about a student’s conduct. Such a decision concerns the interactions between and amongst students, staff, and administrators. It affects the relationship between the members of the university. In Mr Stella s case, the complaint involved questions about intellectual freedom – in the form of critical and open debate and inquiry in a public forum, and the desire “to afford others respect and courtesy in the manner of its exercise.” Such decisions call for prudent judgment. They were part of the internal management and domestic affairs of the University.

TEQSA

The Education Department's 'Modernising and Strengthening TEQSA’s Powers' Consultation Paper embodies a very belated recognition of defective governance in the tertiary education sector. 

The paper states 

A better and fairer higher education sector requires robust and modern regulation to align with government and community expectations. This is important because a successful higher education sector is vital to Australia’s future. Higher education creates the knowledge, skills and research essential for a prosperous, innovative and fair nation. This Consultation Paper invites views about the future regulation of Australian higher education and on potential changes to the Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act) to allow the Tertiary Education Quality and Standards Agency (TEQSA) to step in and act when it’s justified in the public interest. 

 

The Consultation Paper focuses on four areas for potential amendments: • A regulatory system that puts students first; • A modern regulator with powers to address emerging and systemic challenges; • Opportunities to streamline regulation for universities and other higher education providers, so they can focus on teaching and learning; and • A system that supports a joined up tertiary system, helping more Australians get the skills and qualifications they need. 

 

1.2 The need to modernise and strengthen TEQSA’s powers to better meet the standards students, staff and the community expect of our universities The TEQSA Act is the enabling legislation that establishes Australia’s independent, national regulator of higher education, TEQSA. The Act has not had a significant review since it was legislated almost 15 years ago. The tertiary education sector in Australia has changed over that time and faces new challenges that did not exist when TEQSA was established. 

 

The regulatory and policy landscape in which TEQSA exists has evolved since it was created. In the past year the National Student Ombudsman (NSO) and the Australian Tertiary Education Commission (ATEC) have been established. In this new regulatory environment, it’s vital TEQSA has the right powers to continue to deliver for students. 

 

In addition to recommendations from the Australian Universities Accord (Universities Accord), recent public processes have highlighted concerns on university governance. For example, the current Senate Inquiry has heard concerns about governing body representation, financial management, workplace fairness, and provider accountability. 

 

TEQSA needs better tools to be able to step in and act when it’s justified in the public interest. It also needs to be able to respond to systemic risks, not just the compliance of individual providers. 

 

Modernising and strengthening TEQSA’s powers will allow it to take timely and appropriate actions to ensure universities are meeting the standards students, staff and the community expect. There is also an opportunity to consider how changes to the TEQSA Act can support greater productivity by supporting a joined up tertiary system. The Australian Government has a goal to lift the tertiary attainment of working age people which requires a modern regulatory approach. The right changes to the TEQSA Act will help achieve this goal. 

 

Scope of consultation 

 

The Australian Government is committed to ensuring the higher education regulatory system is student-centred, sustainable, and meets contemporary expectations. To support this aim, the Government will engage with a wide range of stakeholders to capture views on the emerging challenges higher education faces, ways to address these, and how best to ensure TEQSA’s regulatory framework is fit-for-purpose for the decades to come. 

 

Consultation is not focused on changes to the Higher Education Standards Framework, the role of the ATEC, or wider program design and funding arrangements for higher education. However, changes to the TEQSA Act may have implications for these areas. 

 

The nature of any proposed changes to the TEQSA Act will be informed by input to this consultation process. Any changes will be subject to decisions of the Australian Government that will carefully weigh the costs and benefits of any changes to regulatory burden, including through a formal Impact Assessment. 

 

Background 

 

Tertiary Education Quality and Standards Agency (TEQSA) 

 

Australia’s higher education sector operates in a system made up of TEQSA, the Australian Government, state and territory governments, statutory bodies, and independent integrity bodies. TEQSA itself was established in 2011 following the Review of Australian Higher Education: Final Report (the Bradley Review). The Bradley Review highlighted the need for a national approach to tertiary education regulation and quality assurance. The creation of TEQSA simplified the regulatory landscape and reduced the number of federal, state and territory regulatory bodies, improving efficiency and alleviating burden on providers. 

 

TEQSA governance is overseen by a Commission, comprising up to five Commissioners, including a Chief Commissioner, and a Chief Executive Officer, supported by staff with regulatory, legal, and higher education expertise. TEQSA reports to the Minister for Education and works with the Department of Education, State and Territory governments, and other regulators. Its structure enables it to act as a national quality assurance body, applying the Higher Education Standards Framework (Threshold Standards) 2021 while seeking to balance institutional autonomy with public accountability. 

 

The Australian Government has adopted a tertiary education attainment target of at least 80% of the working age population with at least one tertiary qualification (Certificate III and above) by 2050. The 80% tertiary attainment target is a key recommendation of the Australian Universities Accord. 

 

Under the TEQSA Act, TEQSA’s core responsibilities include the initial registration of prospective providers and courses, cyclical re-registration of providers at least every seven years, provider category changes, and applications for self-accrediting authority and accreditation and re- accreditation of courses for non-self-accrediting authority providers. 

 

TEQSA regulates the sector against the Threshold Standards, which set the baseline requirements for providers to enter and operate in Australia, as established by the TEQSA Act and Australian Qualifications Framework (AQF). They are high-level and principles-based and are designed to recognise the diversity and institutional autonomy of higher education providers in Australia. 

 

Australian Skills Quality Authority (ASQA) 

 

The Australian Skills Quality Authority (ASQA) was also established in 2011 by the National Vocational Education and Training Regulator Act 2011. Similar to TEQSA, it adopted a national approach to the regulation of vocational education and training (VET) in Australia, alongside state regulatory bodies for VET in Victoria and Western Australia, supported by referral of powers. Together, TEQSA and ASQA regulate tertiary education in Australia. 

 

The Australian Universities Accord 

 

More recently, the Universities Accord was developed across 2023 and 2024 to provide a comprehensive assessment of Australia’s higher education system and a blueprint for the sector’s future. The Universities Accord called for better measures to ensure providers protect students and their interests, an increase in provider diversity to support innovation and productivity, work to address governance failings, and for First Nations self-determination to be at the heart of the tertiary education system. 

 

The Universities Accord also recognised the sector faces new challenges and needs an effective way to deal with these. It acknowledged that fragmented requirements across a number of Acts creates complexity for providers and also identified links between the higher education and VET sectors that could help create stronger shared purpose across tertiary education in Australia. 

 

Australian Tertiary Education Commission (ATEC) 

 

The ATEC is a key recommendation from the Universities Accord and began operating in an interim capacity from 1 July 2025, and permanently from 1 January 2026, subject to the passage of legislation. 

 

Legislation establishing the ATEC will outline its mandate, including driving the implementation of funding reforms, promoting a more joined-up and equitable tertiary education system, and fostering partnerships with First Nations peoples and organisations to embed their perspectives throughout the sector. 

 

A central function of the ATEC will be to negotiate and enter enhanced mission-based compacts with publicly funded higher education providers. These compacts will articulate each provider’s mission, strategic direction and performance objectives, and outline how institutions will contribute to the achievement of national objectives. 

 

The ATEC will be distinct from TEQSA and its regulatory functions and should remain so to protect regulatory independence. However, both will collaborate on matters of shared relevance to enhance the quality, performance and outcomes of the sector and improve student experience. For example, if the ATEC identifies systemic non-compliance of a provider while managing mission-based compacts, it will consider referring such matters to TEQSA for investigation. 

 

National Student Ombudsman 

 

The NSO commenced operations in February this year as part of the Commonwealth Ombudsman and is an independent mechanism for student complaints about higher education providers. The NSO was a recommendation of the Universities Accord. It may receive student complaints on a range of issues, such as gender-based violence, antisemitism and other forms of racism, disciplinary processes, course administration, and reasonable adjustments for students with disability or special circumstances. 

 

The NSO can consider whether decisions and actions by higher education providers are unreasonable, unjust, oppressive, discriminatory or otherwise wrong. It can pursue a number of remedies, for instance recommending a provider takes specific steps to resolve the complaint, offering a restorative engagement process between the student and provider if appropriate or sharing information with relevant regulators for further action if needed. 

 

National Higher Education Code to Prevent and Respond to Gender-based Violence 

 

The Universities Accord (National Higher Education Code to Prevent and Respond to Gender-Based Violence) Act 2025 (the Code) empowers the Minister for Education to establish a mandatory national code requiring universities and higher education providers to prevent and respond to gender-based violence. 

 

Once established as a legislative instrument, compliance with the Code will be a statutory condition under the Higher Education Support Act 2003. Compliance with the Code may be enforced using civil penalties, infringement notices, injunctions and enforceable undertakings. Providers must adopt a whole-of-organisation, trauma-informed approach covering leadership, prevention, training, accountability, and student accommodation, with executive responsibility and regular reporting. Compliance with the Code will be administered by a new Gender-Based Violence Reform Branch within the Department of Education, which will ensure universities are held accountable for safety both on and off campus. 

 

TEQSA’s powers and operation 

 

The TEQSA Act provides TEQSA with legislative powers to regulate all Australian higher education providers. In addition to its registration and accreditation role, TEQSA conducts annual risk assessments for each provider, and monitors risk at the individual provider level in response to complaints or other relevant concerns. TEQSA’s functions also include broader analysis of information about higher education providers and quality assurance practice in higher education. 

 

TEQSA has two mechanisms to deal with non-compliance or contraventions of its legislative framework: • It has enforcement powers that can be used, including civil penalties, enforceable undertakings, injunctions and infringement notices. • It can also impose administrative sanctions, including shortening or cancelling a provider’s registration or course accreditation. 

 

However, its use of enforcement powers for non-compliance with the Threshold Standards is complex and resource-intensive, requiring multiple procedural steps before TEQSA can take action against a non-compliant provider. This limits TEQSA’s ability to take direct, proportionate and timely enforcement action. 

 

Cancellation of registration or course accreditation are severe regulatory interventions designed for widespread or significant non-compliance. Such action lacks proportionality and timeliness where responses to discrete or immediate issues may be more appropriate. In most cases, due to the significant negative impacts on students, sanctions are neither feasible nor appropriate unless all other options have been exhausted. 

The paper features '16 key questions to inform potential reform to the future direction of Australia’s higher education regulatory system'. 

A regulatory system that puts students first 

The Universities Accord highlighted the need for TEQSA’s powers to be reviewed regularly, and adjusted as necessary, to enable an agile and forward-leaning regulator that supports a dynamic tertiary education system. 

TEQSA’s regulatory activities are focused on the initial registration and cyclical re-registration and accreditation of providers and courses. This approach aims to assure quality and assess a provider’s compliance with the Threshold Standards. 

However, course accreditation and reaccreditation impose significant regulatory burden on providers and TEQSA’s resources, and do not always align with the most pressing risks to students, the sector, or those with the most significant impacts. There is an opportunity to consider how TEQSA might adopt a more risk- and impact-informed approach while maintaining robust quality assurance across the sector to better protect student interests and sector sustainability. 

One approach could include a positive duty on providers to take reasonable and proportionate actions to comply with the Threshold Standards. A positive duty means TEQSA could act early, for example, where providers fail to take reasonable steps to protect students, rather than waiting for negative student outcomes to occur before acting. Under a legislated positive duty, providers would need to demonstrate they meet the Threshold Standards actively and continuously, through mechanisms such as regular reporting, monitoring, evaluation and evidence of preventive or supporting actions. 

A modern regulatory approach should also consider the centrality of students in higher education, whether the TEQSA Act’s regulatory principles of necessity, risk, and proportionality should reference students more directly to embed a key aspect of the Universities Accord, and how to put First Nations people and Closing the Gap at the heart of the system. A modern regulatory approach could also reflect the evolving higher education landscape in Australia with the establishment of the NSO and the ATEC, subject to the passage of legislation. 

Questions: 1. What changes to the TEQSA Act are needed to ensure students are at the centre of the regulatory system? 

Question 2. What changes to the TEQSA Act and the regulatory system are required to allow TEQSA to take a more risk-based approach to regulation of the sector, prioritising engagement on risks which have the greatest impact – whether due to the number of students impacted or the significance of the matter? a. Does the TEQSA Act need to reduce the focus on cyclical assessment and prioritise rapid response to regulated risk more strongly? b. How should other regulatory activities be delivered? How should TEQSA provide oversight for these activities? 

Question 3. Should providers have a positive duty to comply, and maintain compliance, with the Threshold Standards, in order to better protect student and other stakeholder and community interests? How might this duty be framed? 

Question 4. Are any changes to the TEQSA Act and the regulatory system needed to support First Nations self-determination in higher education?   

A modern regulator with powers to address emerging and systematic challenges 

Specific powers under the TEQSA Act are not directly linked to the public interest, the protection of students and their learning, or the protection of Australia’s reputation for quality higher education. Changes to the TEQSA Act could address this and remove constraints on TEQSA’s ability to act in a timely way and adopt a more proactive approach. 

In particular, TEQSA does not have powers to act quickly in response to acute risks, many of which can evolve suddenly and have serious impacts on large numbers of students, including vulnerable students. Immediate and high-impact events can compromise student welfare, institutional stability and public confidence in Australia’s higher education system. Examples could include serious financial risks, governance failures, fraudulent conduct, or failures in the delivery of offshore education. 

An alternative approach could be to apply a graduated, risk-based response to compliance concerns. This includes identifying emerging risks early, setting expectations clearly, and where necessary, enforcing compliance through proportionate regulatory action. 

TEQSA also has limited powers to address systemic risks, which pose broad risks to students, academic integrity, and the quality and reputation of Australian higher education. These risks could stem from structural weaknesses in governance, compliance gaps or external events that affect multiple providers simultaneously. 

In some instances, TEQSA’s ability to identify and respond to systemic and emerging risks is constrained by its legislative framework, focussing on individual providers, and data that is provider-specific and fragmented. Strengthening TEQSA’s access to integrated, sector-wide data would enable earlier detection of emerging risks and more strategic enforcement action. The TEQSA Act does not currently allow for the creation of binding legislative instruments, such as enforceable codes, which could be used to address recurring or cross-cutting risks. The Australian Parliament has created powers to make enforceable codes through other legislation, an example of which is the National Code of Practice for Providers of Education and Training to Overseas Students 2018. More recently, the Parliament passed the Universities Accord (National Higher Education Code to Prevent and Respond to Gender-based Violence) Act 2025 establishing a mandatory National Higher Education Code to Prevent and Respond to Gender-based Violence. 

Question 5. How can TEQSA’s regulatory focus shift more towards proactive risk prevention or should it remain primarily on compliance with the Threshold Standards? 

Question 6. How can TEQSA be empowered to use a wider range of timely enforcement approaches when justified and in the public interest? a. This might include civil penalties, injunctions, compliance notices, enforceable undertakings, and/or suspension powers, in relation to non-compliance with the Threshold Standards. 

Question 7. Should TEQSA have new powers to immediately suspend a provider’s registration in response to acute risks? What should be the grounds for suspending a provider registration? 

Question 8. Currently there is a cascading regulatory system where the Minister sets the Threshold Standards for providers and may choose to make Codes where legislation allows, and TEQSA may choose to issue guidance such as Statements of Regulatory Expectation. Is the overall regulatory architecture working effectively to manage risks in the sector? Is any change to this needed? 

Question 9. What powers does TEQSA need to step in when it is justified and in the public interest? For example, in the event of a serious failure in governance, should TEQSA have the power to appoint a monitor, independent adviser or administrator to the governing body? 

Question 10. Are there other powers TEQSA should have, comparable to other modern regulators, when balanced against the need for an efficient and streamlined regulatory approach? 

Opportunities to streamline regulation for universities and other education providers, so they can focus on teaching and learning 

In line with the Government’s productivity agenda, there are opportunities to streamline regulation and reduce unnecessary compliance burden to improve efficiency, free up resources for innovation, and enable higher education providers to focus on delivering higher value activities such as teaching and learning. The Universities Accord also noted the need to identify areas of friction in reporting arrangements, seek ways to streamline regulation, and coordinate information sharing. There are opportunities to improve the coordination of regulatory action. The Ombudsman Act 1976 provides the NSO the power to refer a matter raised in a complaint, and related information and documents, to TEQSA if it suspects the matter could be dealt with more effectively by them. The TEQSA Act does not have a similar power allowing TEQSA to transfer complaints to the NSO or the Department of Education in the case of a complaint about gender-based violence. Similarly, TEQSA can review information the NSO has provided and consider whether an investigation or enforcement action is necessary or appropriate, but it does not have a role in ensuring providers properly implement recommendations of the NSO. Aligning regulation and permitting information sharing would reduce the potential for duplication and fragmentation of regulatory processes. Universities, as major recipients of public funding, are expected to support social mobility by widening participation and contributing skills, knowledge, research, and innovation. While the Threshold Standards set minimum requirements, there is scope to improve transparency and standardise performance information to better guide student choice and community understanding. Existing tools such as international rankings, Quality Indicators for Learning and Teaching data, and the ComparED website provide limited and sometimes opaque insights. In contrast, other sectors use rating systems to highlight quality and compliance, while others require significantly more public disclosure of information to demonstrate compliance.

Question 11. What regulatory requirements or actions could be accomplished in a more efficient way that may lead to increased productivity, while ensuring regulatory outcomes are achieved? 

Question 12. What opportunities exist to streamline regulation between TEQSA, the Department of Education, the National Student Ombudsman, or other Commonwealth, State and Territory government bodies? 

Question 13. Should TEQSA’s functions be broadened to allow better access to transfer complaints to other agencies, for example with the National Student Ombudsman? 

 

Question 14. How could the TEQSA Act be amended to ensure providers are required to implement recommendations made by the National Student Ombudsman? 

 

Question 15. More broadly, would more standardised public disclosure of information across areas including student outcomes, teaching quality and research impact improve accountability, assist students in choosing courses of study or providers, assist Government to assess the effectiveness of public investment, and help providers to demonstrate compliance? How might such a system work? 

 

A system that supports a joined up tertiary system, helping more Australians get the skills and qualifications they need Almost half of the over 200 registered higher education providers in Australia deliver VET courses, including 28 TAFE institutes, and there are six universities that are dual sector providers. Thirty- three providers also deliver both higher education and VET under the Education Services for Overseas Students (ESOS) Framework. 

The Universities Accord recognised that Australia’s long-term needs for knowledge, skills and workforce development require a stronger, more coherent relationship between the tertiary and VET systems. Building connections and transition pathways between the sectors will benefit students by providing better opportunities for lifelong learning and skills development. The Australian Government allocated $27.7 million in the 2024-25 Budget for measures to help deliver a joined up tertiary system, in line with recommendations from the Universities Accord. This includes better Recognition of Prior Learning and Credit Transfer, developing a National Skills Taxonomy and breaking down existing structural barriers between higher education and VET. The Australian Government has also recently tasked the ATEC with developing a Tertiary Roadmap to dismantle barriers between TAFE and university systems, facilitate seamless student transitions, and align qualifications with Australia’s future skills needs via a newly formed Tertiary System Advisory Council. 

TEQSA and ASQA have shared jurisdiction over providers that deliver higher education and VET courses to international students under the ESOS Framework. The states and territories also have an important role in the governance and regulation of VET. TEQSA and ASQA have commenced work to improve the regulatory approach for dual-sector providers through the development of a Dual sector regulatory strategy. This includes initiatives to: • improve information sharing between ASQA and TEQSA • align regulatory requirements between ASQA and TEQSA, and • uplift academic and corporate governance across the VET and higher education sectors. Greater streamlining between TEQSA and ASQA will help tertiary education providers respond effectively to students and meet the requirements of a more joined-up sector that encourages more dual-sector provision. 

Question 16. Are changes to the TEQSA Act needed to support better joined-up arrangements across higher education and vocational education? a. What are the current regulatory challenges faced by students and providers and how could changes to the TEQSA legislation support a more streamlined experience?

Law Teaching Standards

The Admissions Committee of the Legal Services Council (Council) and the Law Admissions Consultative Committee (LACC) Consultation paper on proposed revisions to the Accreditation Standards for Australian Law Courses notes 

The Council is a statutory body that oversees the operation of the Legal Profession Uniform Law in New South Wales, Victoria and Western Australia. 

The Council’s Admissions Committee develops the Legal Profession Uniform Admission Rules and provides advice to the Council about admissions matters. 

The LACC is a national group that reports to the Council of Chief Justices of Australia and New Zealand. The LACC’s main role is to forge consensus on admission and admission-related matters nationally, between the bodies represented by its members. The Council provides the LACC with secretariat support. 

The Admissions Committee and the LACC work closely together to facilitate national consistency in admissions matters. 

About this consultation 

LACC first published the Accreditation Standards for Australian Law Courses (Standards) in July 2018. The Standards set important minimum standards for the accreditation of law courses. The Standards also seek to give law schools greater certainty about the matters which an admitting authority will consider relevant when accrediting, monitoring or re-accrediting a law course. In late 2023, the Committees became aware of some emerging issues in relation to the accreditation of law courses, partly arising as a result of the COVID-19 pandemic. The Committees resolved to undertake an initial targeted consultation to explore how these issues might be addressed. Key issues under exploration included how the Standards might be enhanced to respond to the prevalence of virtual or online delivery and given the emergence of new digital technologies. The initial consultation also explored other matters, such as the use of intensives or block delivery models. 

Having considered the range of views expressed in initial consultation submissions in late 2024, the Committees have developed draft revised Standards (Draft Revised Standards) for public consultation. The Draft Revised Standards are attached (Attachment A). 

Relevant overarching policy considerations 

In developing the Draft Revised Standards, the Committees have given particular consideration to the desirability of minimum standards for the accreditation of law courses across Australia which are fit for purpose in the context of widespread online or blended delivery and other developments in contemporary Australian legal education, so as to further national consistency. 

Other policy considerations the Committees have taken into account include: • the legislative objective of regulation which is efficient, effective, targeted and proportionate and the development of accreditation policies and procedures which are consistent, uniform and transparent across Australia • recognition of the broader national higher education regulatory landscape and higher education policy settings, including the role of the Tertiary Education Quality and Standards Agency (TEQSA) and its regulatory and enforcement powers • the importance of innovation in the design and delivery of law courses to achieve enhanced student learning outcomes • equity, accessibility, diversity and inclusion for students to be able to attain a legal qualification and enter the legal profession, and • potential implementation impacts on law course providers. 

Proposed revisions to the Standards 

The Committees propose revisions to update, clarify and streamline the Standards in relation to the delivery of law courses, and support effective online learning with respect to teaching hours and the introduction of new requirements for active learning and invigilated assessments. The proposed revisions would also introduce additional guidance for intensives and block learning models and make other minor changes. The Committees propose a transitional period, as set out below. 

Online delivery of law courses 

The Committees are aware of the growth in the number of law courses being delivered online and are concerned to ensure that the Standards support online delivery which is appropriate and effective in achieving student learning outcomes. 

The proposed revisions to the Standards reflect the existing position that law courses may be delivered fully in-person, fully online or via a blended delivery model. In this context, the Committees propose new requirements to support the effectiveness of online delivery, including by setting minimum standards for active learning and student engagement (set out in the next section).  

This approach aligns with the national regulation of tertiary education providers which, to promote innovation, flexibility and focus on learning design and delivery outcomes across providers, does not prescribe types of delivery modes. It also recognises that policy at the national level acknowledges online learning as a legitimate way to promote equity, access and inclusion in higher education. 

The Committees have heard initial consultation feedback about the importance of ensuring that certain cohorts of students, such as women, First Nations people, those living in regional, rural, remote and very remote (RRRR) areas and those from neurodiverse backgrounds or with a disability, have improved access to legal education by law courses being offered fully or partially online. This enhances diversity of representation across the legal profession and in RRRR areas seeking to attract lawyers. The Committees recognise the role of the Standards in supporting these objectives, while maintaining appropriate minimum standards in relation to law courses. 

The relevant changes in the Draft Revised Standards are as follows: • new clause 4.1 (The delivery of the law course) • adjusted and new definitions at clause 2.1 for “online”, “delivery mode”, “in-person” and “synchronous online learning”, as well as the deletion of the “face-to-face” definition, and • ancillary adjustments to clause 4.6 (Teaching of the law course and active learning) to extend current Standards to apply to the range of delivery modes possible for online learning. 

The revised definitions have been developed taking into account initial consultation feedback about the need for: • clearer definitions to respond to the widespread online delivery of law courses • clearer delineation between synchronous and other online learning, and having regard to consistency with the national regulation of tertiary education providers • a definition for “delivery mode” that does not limit the types of delivery modes permitted when tertiary education providers offer a course of study • updating the definition of “online” by removing references to technological hardware given the emergence of laptops, tablets, wearables and the possible development of other new types of hardware, and • removal of the “face-to-face” definition, as it was creating some confusion. Instead, the Committees propose that the definition of “in-person” will continue to apply with slight modification. 

Teaching hours, active learning and student engagement 

The Committees propose revisions in response to initial stakeholder feedback that the Standards: • be brought up-to-date by clarifying that teaching may be delivered not just in-person, but also through online or blended delivery modes, and • provide an indicative range of possible ways in which teaching may occur through the introduction of a definition for “teaching method”. 

Consistent with the clarifications for online learning, the Draft Revised Standards propose revisions at clause 4.5 (Content of the law course) and the introduction of new definitions at clause 2.1 for “delivery mode” and “teaching method” to provide clearer guidance as to what may count towards the 36 hours of teaching for each Priestley 11 subject. 

To support effective online delivery, the Committees also propose to make updates to the Standards in relation to active learning and student engagement. The Committees propose these revisions in response to initial stakeholder feedback that active learning and student engagement in an online learning environment is best supported by synchronous online learning, and that the Draft Revised Standards can best achieve consistency in accreditation by setting a threshold number of hours to promote active student learning and engagement that would apply across all delivery modes. 

The Draft Revised Standards propose revisions to clause 4.6 (Teaching the law course) by transferring commentary, with minor modification, about “active learning” to a new definition at clause 2.1 and by updating the definition of “direct interaction” to ensure it is appropriate for an online teaching and learning environment. 

The minor modifications to the definition of “active learning” remove the reference to “test” (so there is no confusion with assessments) and includes a reference to factual “scenarios”. The introduction of a new proposed requirement at clause 4.6 would allow an admitting authority to consider the number of hours provided by a law school for a student’s active learning and engagement in a Priestley 11 subject when considering whether a law course will enable a student to acquire an adequate level of understanding and competence. 

The Committees consider the provision of a minimum number of 18 hours for active learning and/or direct interaction, whether the student’s participation is in-person or through synchronous online learning, sets an appropriate balance between active and other learning. A minimum 18 hours is proposed as this would equate to 50% of the student experience with respect to the 36 hours of teaching for a Priestley 11 subject. 

Invigilated assessments 

In relation to assessments, the Committees received feedback in the initial stakeholder consultation that: • universities should continue to have flexibility to allow for best practice innovation in assessment design and to select the assessment method that best achieves the desired learning outcomes, and • it would be appropriate for a requirement to be imposed that at least 50% or half of all assessments for a Priestley 11 subject must be conducted by a form of invigilated assessment. 

This seeks to provide a sufficient level of assurance that a student has been appropriately awarded their grades and law degree. 

The Draft Revised Standards introduce a new requirement at clause 4.7 (Assessing understanding and competence) and new definitions for “assessment method” and “invigilation” at clause 2.1. 

The introduction of a new requirement at clause 4.7 would allow an admitting authority to consider for each unit of the law course that covers a Priestley 11 subject and statutory interpretation, the allocation of assessments, the assessment methods and whether a sufficient proportion of those assessments are conducted by invigilation (whether an online invigilated exam or another type of invigilated assessment). This will allow the admitting authority to ensure the law course provides an appropriate level of quality assurance that a student has been awarded a grade that accurately reflects their level of acquired understanding and competence. 

The Draft Revised Standards impose a new requirement at clause 4.7(b) that at least 50% of assessments for a unit covering a Priestley 11 subject and statutory interpretation be conducted by a form of invigilated assessment. The new requirement does not require any specific method of invigilated assessment to allow law schools flexibility to use a method of assessment that would best achieve the intended learning outcomes and suit the delivery mode. 

The introduction of a new definition for “assessment method” seeks to respond to initial stakeholder feedback that it would be helpful to include examples of the types of assessments that law schools may use in addition to examinations. 

The introduction of a new definition for “invigilation” seeks to confirm that supervision of an assessment applies to all types of delivery modes, including when an assessment is conducted in-person or online. 

Intensives and block learning models 

The Committees received initial stakeholder feedback that it would enhance national consistency of accreditation if there was additional guidance in the Standards about the use of intensives and block delivery and what is needed for a law course to be considered “intensive”. 

While the Committees are aware of two law schools that have already introduced block delivery of a whole law course, other stakeholders have expressed reservations about the appropriateness of intensive or block delivery models for Priestley 11 subjects. 

To respond to the initial stakeholder feedback, the Committees propose to update the Standards to include additional guidance that intensive or block delivery should only be used for Priestley 11 subjects where the law school satisfies the admitting authority that it is appropriate in all the circumstances. To support this, it is proposed that the Standards also provide commentary that an admitting authority may seek further information and data from a law school, and that the Standards include more information about the nature of accelerated modes of delivery, of which intensive or block learning models are a type. 

The proposed additional guidance acknowledges the practices of the Victorian and New South Wales admitting authorities which have already considered or are in the process of considering the offerings of the two law schools that have already introduced block delivery models for a whole law course. 

By making these amendments to the Standards, it is intended that law schools may make a case for delivery in accelerated mode (intensive or block delivery) by satisfying the admitting authority that it is appropriate in all the circumstances for Priestley 11 subjects to be delivered in the proposed way. It is also intended that law schools that adopt intensive or block delivery of Priestley 11 subjects would still need to meet the at least three-year (or equivalent) requirement for the duration of the law course and the proposed new minimum requirement for active learning and student engagement discussed above. It may be open to the admitting authority to consider whether a reduced number of teaching hours would be permissible for a Priestley 11 subject. The Draft Revised Standards propose amendments at clause 4.3 (The duration of the law course) in response to the initial stakeholder feedback. 

Other minor revisions 

The Draft Revised Standards propose other minor revisions to update, clarify and streamline in response to initial stakeholder feedback. These include: • a new definition of “law course” at clause 2.1 that draws from the drafting in the Uniform Law Admission Rules12 and further commentary in the explanatory note at clause 4.2(a) to clarify the requirement for a coherent sequence of units applies to a law course that is a single degree and, for a combined or double degree, to the law component of the combined or double degree • a new definition of “unit” at clause 2.1 that is consistent with the TEQSA definition13 and accompanying revisions throughout the Draft Revised Standards, for example at clauses 4.2, 4.3 and 4.5, and • updates to the definition of “prescribed areas of knowledge” at clause 2.1 and elsewhere to include statutory interpretation. 

Regulatory landscape 

The LACC Standards operate alongside the Australian Law School Standards,14 developed by the Council of Australian Law Deans (CALD), as well as the broader national regulation of the higher education sector by TEQSA. 

When developing the Draft Revised Standards, the Committees have been mindful of TEQSA’s resourcing,  role and regulatory powers in maintaining academic integrity in the tertiary education sector, and TEQSA having particular focus on responding to commercial contract cheating services and the emergence of generative AI. The Committees have also considered what universities and law schools are required to do to meet the TEQSA academic integrity requirements. Each university is required to have an up-to-date academic integrity policy and procedures that respond to contract cheating and generative AI, and to comply with the TEQSA re-accreditation process, regular TEQSA audits, and respond to enquiries or participate in other initiatives. 

To support universities adapt and respond to contract cheating and generative AI, TEQSA has published extensive resources, guidance and best practice materials about how universities can maintain academic integrity with respect to these technological developments. Anyone, including universities, students and members of the public, can report an alleged contract cheating service to TEQSA. Regarding generative AI, TEQSA encourages universities to take the approach that “assessment and learning experiences equip students to participate ethically and actively in a society where AI is ubiquitous”. 

The Committees are mindful not to include requirements in the Standards that would replicate these aspects of TEQSA’s work. This aligns with the intended application of the Standards, that they complement and not duplicate the standards of CALD and TEQSA. 

Proposed implementation timing 

The Committees anticipate working towards a publication date in the second half of 2025, although this may depend on the nature of the feedback received through the consultation process. 

The Committees propose there be a staggered two-year implementation period to facilitate transition. 

During this period: 

• The final revised Standards will be published one year before the date of commencement. 

• In the year following commencement, the final revised Standards will apply to: o all applications for accreditation and re-accreditation, and o all other accredited law courses. It is anticipated that each admitting authority will communicate with law schools which are in this category. 

Governance

The Senate Education and Employment Legislation Committee has launched an inquiry into governance at Australian higher education providers. 

The Terms of Reference are 

 The adequacy of the powers available to the Tertiary Education Quality and Standards Agency to perform its role in identifying and addressing corporate governance issues at Australian higher education providers, with particular reference to: 

a. The composition of providers' governing bodies and the transparency, accountability and effectiveness of their functions and processes, including in relation to expenditure, risk management and conflicts of interest; 

b. The standard and accuracy of providers' financial reporting, and the effectiveness of financial safeguards and controls; 

c. Providers' compliance with legislative requirements, including compliance with workplace laws and regulations; 

d. The impact of providers' employment practices, executive remuneration, and the use of external consultants, on staff, students and the quality of higher education offered; and 

e. Any related matters. 

The committee will present its report on 4 April 2025, with submissions due by 3 March 2025.

Governance

The Tasmanian Legislative Council Select Committee final report on provisions of the University of Tasmania Act 1992 (Tas) touches - gingerly - on systemic problems in institutional governance that are evident in other Australian universities. 

The Committee made an overarching recommendation -

 As a priority, the Government conduct a comprehensive review of the University of Tasmania Act 1992, including matters specified in recommendations in this report, and promptly legislate the results of that review. 

It goes on to make 19 recommendations: 

 1. The Act be amended to include a preamble. 

2. The Act be amended to provide for casual staff to be included in the constitution of the University. 

3. Section 6 of the Act be reviewed and amended to ensure contemporary and appropriate functions are included. 

4. Consider a mechanism to assess the performance of the University against the functions in Section 6 of the Act. 

5. The Act be amended to establish restrictions or prohibitions on the disposal or long-term lease of land that has been granted to the University by the Crown, land purchased with public money, or Crown land. 

6. The Act be amended to provide for the constitution of the University Council to include a minimum of two student members, with at least one elected from the student body. 

7. The Act be amended to provide for the constitution of the University Council to include a minimum of two members of the academic staff elected by the academic staff. 

8. The Act be amended to provide for the constitution of the University Council to include a minimum of two members of the professional staff elected by the professional staff. 

9. The Act be amended to ensure there is more balance between the number of appointed and elected members on the University Council. 

10. The Act be amended to clarify the purpose and function of Ministerial appointments to the University Council. 

11. The Act be amended to ensure when considering the best interests of the University, University Council must explicitly include consideration of the University’s obligations to the Tasmanian community. 

12. The Act be amended to prescribe key requirements for the constitution and method of appointment of the Academic Senate, to ensure a higher proportion of academic representatives rather than managerial appointments and fewer ex officio appointments. 

13. The Act be amended to prescribe the functions of the Academic Senate to include a determinative role on core academic matters. 

14. Amend the Act in relation to annual reporting by the University, including: a. more specific detail on what the Annual Report is required to contain in relation to income and expenditure; b. a requirement to report on the delivery of the functions of the University; c. a requirement to include detail of all salaries, remuneration and fringe benefits for executive management roles at the University; and d. a requirement for more timely tabling of the University’s annual report in Parliament. 

15. In addition to the Annual Report, include a requirement in the Act for the University to produce: a. an annual corporate plan to be published at the beginning of the year; and b. an annual Environment, Society and Governance (ESG) report. 

16. Review Section 7(2) of the Act to retain Treasurer’s approval for University borrowings and ensure it reflects contemporary borrowing and borrowing-like arrangements. 

17. Consider formalising processes for regular Parliamentary scrutiny of the University, including: a. The Annual Report b. The annual corporate plan c. Major infrastructure projects 

18. The Act be amended to include a requirement to protect and promote academic freedom. 

19. The Joint Standing Committee on Integrity consider an inquiry into the performance of the Integrity Commission and the Ombudsman in relation to complaints regarding the University of Tasmania.

The recommendations reflect a range of findings -

 1. The original University of Tasmania Act 1889 contained a preamble which was removed in 1951. 

2. There is broad support for reinstating a preamble in the Act. 

3. The Dawkins reforms of the 1980s, and various reforms since, have resulted in significant changes to funding models, leading to corporatisation of the Australian higher education system. 

4. With increased corporatisation, it is important universities achieve an appropriate balance between being a public institution and generating funds. There is a need for greater independent scrutiny, transparency and accountability to ensure this balance is being achieved. 

5. Concern was expressed that the University appears to prioritise commercial over community interests in its core functions, with a significant focus on corporatisation, which undermines the University’s core role and identity.  

6. The University considers the current Act constitutes its membership as the active, living, collegial community engaged in the University's tasks of learning, teaching and research. The University is to serve and be accountable to these members. 

7. Section 3 of the Act does not include casual staff in the definition of academic and professional staff, therefore in Section 5 of the Act causal staff are not included in the constitution of the University. 

8. Witnesses pointed to inconsistencies between membership of the University and representation on the University Council. 

9. The Committee received evidence of a perception the University has deviated from its core functions of education and research specified in Section 6 of the Act, and has shifted to a more commercial focus. 

10. The University does not consider commercial activity should be prescribed as a function of the University in the Act. 

11. The University recognises the physical, educational and financial barriers that impact access to higher education in Tasmania and outlined a number of measures to assist in overcoming these barriers, with regard to principles of merit and equity. 

12. There is an opportunity to review Section 6 of the Act to ensure the functions of the University as prescribed are contemporary and appropriate, and provide a basis for accountability of governance and decision-making. 

13. Calls were made for regular independent review of the University to provide greater accountability in relation to delivering on the functions in the Act. 

14. There is a perception that the exercise of the powers outlined in Section 7 are not required to be accountable to the functions prescribed in Section 6. 

15. There is a perception that there is not an explicit relationship between the exercise of the powers outlined in Section 7 to the functions prescribed in Section 6. 

16. Section 7(1) provides for the University to exercise its powers “both in Tasmania and elsewhere, all things necessary or convenient to be done for or in connection with the performance of its functions.” 

17. The powers prescribed in Section 7 of the Act are comparable to those provided for in the acts of other universities. 

18. When the 1992 Act was passed by Parliament, the Hansard does not include any discussion of the intent or purpose of removing restrictions on the disposal of the land vested to the University in Sandy Bay (as specified in Schedule 3 of the Act). 

19. In removing restrictions on the disposal of vested land in the 1992 Act, it is not clear whether the wholesale disposal of the Sandy Bay campus was contemplated. 

20. Evidence provided to the Committee raised concerns about the absence of restrictions in the Act on the power of the University to dispose of the vested land in Sandy Bay. 

21. The University regards the powers under the Act are appropriate and necessary in order to manage the financial position of the University and deliver its functions in a challenging funding environment. 

22. Australian public universities operate on land that has been granted to them by the Crown, land purchased with public money, or Crown land. All the public universities in the Australian States – except for the University of Tasmania – are subject to legislative restrictions or prohibitions on the selling or dealing with land. 

23. Since the University was established in 1889, there have been several changes to the governance structures prescribed in the Act. 

24. The Act was reformed in 2001, reducing the membership of the University Council from 24 to 17, as a response to the Federal Government’s drive to reform governance of Australian universities. 

25. The Act was further reformed in 2004 aligning membership appointments with the national governance protocols, reducing the size of the University Council to operate with a minimum operating level of 10 members and maximum of 14. 

26. The Act exists as part of a complex framework and legislation that regulates public universities in Australia, including the TEQSA act and its subordinate legislation. 

27. Witnesses identified there was a need for balance between managerial leadership and academic leadership in the dual governance model employed by modern universities. 

28. Witnesses expressed a view that values of managerialism can be inconsistent with the values of academic decision-making. 

29. In response to national reforms and consistent with national trends, the Act has been amended in 2001, 2004 and 2012, decreasing the size and changing the composition of the University Council. The number of members on Council is consistent with other Australian universities, albeit at the lower end of the range. 

30. By national standards, the proportion of elected staff and student positions on University Council is low compared to other Australian universities and concerns were raised that this decrease has resulted in reduced democratic representation on University Council. 

31. There are contested views on the Act’s current requirements regarding the constitution of the University Council. 

32. Concerns were expressed regarding the lack of academic staff and professional staff representation on University Council and witnesses called for an increase in the number of these positions. 

33. University governing bodies across the sector typically have two student members, with at least one elected by the student body. 

34. Under previous iterations of the Act, the student member on the University Council was elected by the student body, via a process designed by the Tasmanian University Union. 

35. While previously an elected position, currently the Act prescribes that the University Council appoints a student member to Council after consultation with relevant student associations. It is unclear whether the Act requires University Council to consult those associations on reappointment of student members. 

36. Under Section 8 of the Act, the number of members appointed to the University Council may be up to four times the number of members elected to the Council. 

37. Concerns were raised that the high proportion of members appointed to the University Council has resulted the development of a self-perpetuating culture, a lack of vigorous debate or dissenting views, and a tendency for ‘group think’ in Council decision-making. 

38. While the Act prescribes two Council members are appointed by the Minister, there is no requirement for, or practice of, those members maintaining a relationship with, or providing reports to the Minister. 

39. The Act prescribes the Minister appoints two Council members, however provides no guidance or requirements regarding the purpose or function of those appointments, as distinct from positions appointed through other means under the Act. 

40. When recruiting for vacant positions, the University Council uses a skills and attributes matrix to identify the expertise required to ensure an appropriate and ongoing balance of skills among members of Council. Recruitment for vacant Council positions is then publicly advertised. 

41. Historically, the University Council included a position for two members of Parliament, however these positions were removed when the Act was amended in 2001. No dedicated positions for members of Parliament are prescribed under legislation for any Australian university council. 

42. Concerns were raised regarding the level of accountability of University Council under the Act, in particular the lack of accountability to the wider community which constitutes the University or the broader Tasmanian community it serves. 

43. Evidence suggested there is potential for conflict under the Act between the University Council’s consideration of ‘the best interest of the university’ and the overarching function of the University to ‘promote the social, cultural and economic welfare of the community and make available for those purposes the resources of the university’. It is unclear how such a conflict should be resolved. 

44. The Act prescribes the overarching function of the Academic Senate to advise the University Council on all academic matters relating to the university, while the constitution, functions, powers and proceedings are specified in Ordinance. 

45. The University considers Academic Senate membership is best prescribed by ordinance rather than by the Act, as it allows for the necessary flexibility in membership, function and proceedings. 

46. Concerns were raised regarding the membership of the Academic Senate, including: a) b) c) a significant number of ex officio appointments; a majority of members are in upper-level management roles; elected members are a minority; and d) a small proportion of members being senior academic staff actively engaged in significant teaching and research. 

47. Concerns were expressed the Academic Senate is not constituted in a way which allows members to give frank and fearless advice, with a perception that the Senate is under the control of the executive management due to the top-down managerial structure and direct reporting lines. 

48. Concerns were expressed that Academic Senate membership does not adequately represent the views of staff and students, and that academic decision-making is being undertaken by those with managerial rather than academic roles. 

49. Concerns were expressed that the Academic Senate lacks genuine decision-making power, and instead performs a ‘rubber stamp’ function. 

50. The Chair of the Academic Senate acknowledged evidence received by this Inquiry and outlined changes made to the operations of the Senate in response, including: a) b) management now seeks exploratory feedback on new policies or initiatives; the establishment of a new monitoring and assurance committee (5 academic staff representatives and 1 student representative) to increase input from academic staff who are not currently in management roles; and c) recognition that student voice needs to be included in academic governance. 

51. The Act does not include any requirements to ensure accountability of executive decision- making. 

52. Concerns were expressed regarding inadequate consultation with staff and students in executive decision-making processes, resulting in a detrimental impact on staff and student experience and outcomes. 

53. The University has a Guide to Decision Making, however there does not appear to be a formal policy requiring consultation, nor does the Act contain a requirement for consultation in decision-making. 

54. Under the Commonwealth Funding model, the University must generate independent sources of revenue and funding in order to deliver core activities. 

55. Compared to other Australian universities, remuneration for the University Vice- Chancellor is above the median, however remuneration for academic and professional staff is at the lower end of the range. 

56. While it is not necessarily appropriate to legislate to limit or direct the remuneration of executive management at the University, greater scrutiny and accountability for these decisions is desirable. 

57. The Act’s requirement that the Annual Report contain ‘a full account of the income and expenditure of the University for the financial year to which it relates’ (Section 12(2)), does not ensure an appropriate and accountable level of detail in the report. 

58. As the Act allows 6 months after the end of the financial year for the Annual Report to be provided to the Governor, and 10 sitting days beyond that for the Minister to table it in Parliament, Annual Reports have commonly been tabled up to 8 months after the end of the financial year. 

59. In addition to the Annual Report, a corporate plan published at the beginning of the year would provide a further mechanism for transparency and accountability. 

60. The University has indicated a willingness to consider opportunities for more detailed and transparent financial reporting. 

61. The University has indicated a willingness to produce an Environment, Society and Governance (ESG) Report to provide accountability for key non-financial obligations. 

62. The Act prescribes a role for the University that directly references the broader Tasmanian community (Section 6(g)), however there is no requirement for accountability to the community in the delivery of that role. 

63. The Civic Universities Movement is a response by universities internationally to develop more explicit partnerships with their communities to address recognised challenges. 

64. While the Act requires Treasurer’s approval for University borrowings, the University has other borrowing-like arrangements that are not captured by this requirement. 

65. There is a lack of clarity on the relationship between the University and the State’s respective financial positions. 

66. The University has been established under statute, therefore it should be accountable to the Tasmanian public through the Parliament. 

67. The relationship between the University and State Parliament has changed over time, with fewer formal connections and a lack of active scrutiny. 

68. The reduction in connection over time between the University and the State Parliament has led to missed opportunities to identify and proactively address issues as they have arisen. 

69. While some Australian states have a Minister for Higher Education, the Tasmanian government does not include this as an explicit portfolio responsibility. 

70. While the University is a publicly-funded institution, there is no external scrutiny processes of its major infrastructure expenditure. 

71. The University considers academic freedom to be a fundamental value of a university, and that it is protected by its academic freedom and free speech policy. 

72. The University of Tasmania Act 1992 does not specifically include reference to academic freedom, independence and autonomy, which is consistent with legislation establishing many other Australian universities. 

73. Academic freedom is supported under the Tertiary Education Quality and Standards Agency and legislation such as the Higher Education Support Act 2003. 

74. The protection of academic freedom in policy does not provide the same level of protection as an enforceable requirement in legislation. 

75. There are conflicting views on whether it is necessary to protect academic freedom through inclusion in the University of Tasmania Act 1992. 

76. It was reported that managerial bullying and workplace culture issues have led to reluctance within the university workforce to speak out or criticise management for fear of reprisal. 

77. Casualisation of the University workforce and associated lack of job security has contributed to a reluctance to speak out or criticise management. 

78. The use of gagging clauses (including non- disclosure agreements and non-disparagement clauses) functions to reduce public criticism of the University by former staff. 

79. The University’s complaint management mechanism, the Safe and Fair Communities Unit, is not considered by some staff and students to be a reliable, safe or independent means to seek redress for managerial bullying. 

80. Currently, in relation to the University of Tasmania, the Tasmanian Ombudsman has a statutory role for administrative complaints and the Tasmanian Integrity Commission has a statutory role for misconduct complaints.  

81. There is a lack of confidence in the internal University and external statutory complaint handling and dispute resolution processes. 

82. The University needs to be mindful of its performance and ranking in order to continue to attract domestic and international students, and maintain the quality and rigour of its academic staff and research outputs. 

83. It is challenging for a relatively small, state-wide university located across multiple regional and capital city campuses to maximise student access while also maintaining teaching and research of a high quality. 

84. A regional presence is important to encourage student access to higher education, as well as providing the opportunity for the University to respond more effectively to skills needs state-wide. 

85. There is an apparent reduction in the degree to which the University values its art, cultural, heritage and scientific collections, and a reduction in the provision of public lectures, music and theatre performances. 

86. The Alumni Advisory Committee was inactive from 2017 to 2023, and there appears to have been no similarly structured mechanism for engagement of alumni and advice to the University. 

87. A lack of opportunity for Alumni to be engaged and involved in the University risks diminishing support for the University, including financial contributions such as donations and bequests. 

88. In 2018, the independently incorporated University Foundation was dissolved and the University Foundation Committee of the Council was established. Concerns were raised that this would result in a lack of transparency in relation to bequests and philanthropic ddonations