The funding system I have described parts 1 to 5 of this series of posts applies in full to the higher education providers listed on ‘Table A’ of the Higher Education Support Act 2003. The public universities and the Batchelor Institute of Indigenous Tertiary Education appear on Table A.

This post looks at the situation of other higher education providers. This includes 5 private universities, 8 university colleges and 166 other higher education providers.

Provider registration by TEQSA does not confer any funding entitlements. It is necessary but not sufficient for funding.

No non-Table A provider has any statutory right to Commonwealth supported places. Four of the five private universities are, however, listed on Table B of HESA 2003. This entitles them to research funding and some other government funding but not CSPs. This post describes how non-Table A providers can get CSPs under the new system.

All legislative references in what follows are to the Higher Education Support Act 2003 unless otherwise specified, ‘current’ signalling the legislation now in force, ‘new’ signalling the amending bill, the  Universities Accord (Opening the Doors of Opportunity) Bill 2026.

Eligibility for Commonwealth supported places

In the new funding system, as now, eligibility for Commonwealth supported places is based on history and politics, not any objective criteria.

The minister, rather than ATEC, will decide whether a provider should be eligible for CSPs. This is done by putting providers on a list in the Commonwealth Grant Scheme Guidelines: new section 30-1(10(a)(ii).

We can see the current policy on adding providers from the 2026 funding agreements. They make reference to CSPs for TAFEs and ‘other high-quality not-for-profit specialist providers’. Five TAFEs have been added since last year. NIDA is also new to the list. The only new not-for-profit is Excelsia University College, although I would not call it a specialist provider, as CSP allocations to teaching, early childhood, social work and counselling courses suggest.

There is no specific power for ATEC to advise on provider additions, but possibly it could do so as incidental to advisory subjects in section 41 of the ATEC Act 2026 including (a) policy settings for higher education and (e) the ‘diversity of the higher education system’.

While eligibility is conferred by the minister ATEC will decide whether or not to allocate CSPs.

Total CSPs for non-Table A providers

The minister will set separate total allocation pool amounts for Table A and non-Table A providers: new section 30-5(1).

For both groups the allocation must be made before 1 July (except for 2027): new section 30-5(2).

The total dollar allocation for non-Table A providers in 2026 was $39.3 million compared to $7.8 billion for Table As. I don’t expect major non-Table A growth despite some new providers being added.

This total can be varied up subsequently: new section 30-5(2). While the minister can decide the initial allocation on any grounds, the increase requires him to consider advice given by ATEC and whether an increase would promote the objects of the Higher Education Support Act 2003: new section 30-5(7). It reads as if ATEC has more influence over the variation, although the minister can ignore ATEC’s advice after having considered it.

Restrictions on allocations to non-Table A providers

ATEC can only allocate places to non-Table A providers in a ‘priority class of course’: new section 30-35. This replaces the current ‘national priority’ system.

The priority class of courses will be specified in the Commonwealth Grant Scheme Guidelines: new section 30-40. This makes it a ministerial decision.

The main difference with the old system is that the Commonwealth Grant Scheme Guidelines can specify a priority class of courses for one provider or a class of higher education providers: new section 30-40(a)&(b).

Effectively this lets the minister micromanage non-Table A allocations in a way that he cannot for Table A institutions. For example, I would not be surprised if he restricted performing arts places to NIDA, preventing TAFE courses in this field.

ATEC allocations to non-Table A providers

Once the minister has told ATEC, through the Commonwealth Grant Scheme Guidelines, exactly what types of courses at which providers should receive CSPs he cannot say precisely how many places.

Under the ATEC Act 2026, the section 71(2)(c) provision preventing the minister giving directions to ATEC on specific providers or classes of providers will come into effect.

The ATEC allocation must specify that an allocation is only for a priority class of courses and the number of places for each priority class: new section 30-35.

The phrase ‘priority class’ implies that the allocation cannot be to a specific course, although there is no equivalent of new section 30-20(3), which prevents ATEC allocating to specific courses at Table A institutions without designation. If so, this differs from current practice in which courses are often specified in funding agreements.

Specifying courses raises the question of whether designation applies to non-Table A providers. In the current legislation designation only applies to Table A providers: current section 30-12. But in the amending bill the designation provision does not directly mention Table A providers: new section 30-30. However the new designation provision is positioned in the bill after two sections that expressly apply exclusively to Table A providers and immediately prior to the non-Table A provision. I think the best reading of the bill is that designation does not apply to non-Table A providers, but if so this should be clarified in an amendment to section 30-30.

Offering CSPs to applicants

If a non-Table A provider receives an allocation to a priority class of courses it must offer places as CSPs unless they have used them all: current section 36-30(3)&(4) as amended by items 19 to 21 in the amending bill.

Non-Table A providers can also enrol full-fee students once they have exhausted their CSP allocation. There is no equivalent of the current section 36-30(1) restriction on Table A institutions offering full-fee places to undergraduates.

If courses are not specified in the ATEC allocation this could cause problems as the provider may only want CSPs in certain courses within a class of courses.

Do non-Table A providers have a floor number of CSPs?

As described in an earlier post, the policy intent is that Table A institutions have a floor number of CSPs, although I raised doubts about whether the amending bill successfully implements that intent.

For non-Table A providers there is no floor number of CSPs.

However ATEC must consider compliance with section 36-25 of HESA 2003, which requires that students admitted as CSPs can continue as CSPs: new section 30-45(1)(b). There is no equivalent requirement on the minister to ensure that the CSP allocation to non-Table A providers can support the teach-out of students. While hopefully common sense would prevail it would be better to make statutory allowance for this situation.

Student contribution caps on non-Table A providers

The CSP over-enrolment caps apply to non-Table A providers. They will all be covered by the ‘default deemed allocation’ [of student contribution eligible places] of 105% of the CSP allocation: new section 33-9(a).

As many providers get only small CSP allocations this leaves them little room for error. For TAFE SA, allocated 19 places in 2026, the 5% buffer = .95 EFTSL. Based on 2026 allocations, six other providers have over-enrolment buffers of less than three places.

During their offers and enrolments period non-Table As are squeezed between section 36-30 provision, which requires CSPs to be offered until none are left, and section 33-9 that will leave them with zero funding if they overshoot by a very small number.

This is more evidence that the 5% over-enrolment cap is impractical and counter-productive.

Needs based funding

Non-Table A providers are eligible for needs based funding if they receive CSPs: new section 39-10. Needs based funding is explained in more detail here.

The problem – generally, but more so for non-Table A providers – is that needs based funding comes with acquittal requirements. For providers with small numbers of CSPs – three with less than 25 allocated in 2026 – with only the subset of low SES or Indigenous students eligible for equity funding, compliance costs may exceed the revenue received.

Non-Table A providers should be able to opt-out of needs based funding if they decide its costs outweigh its benefits.

International student allocation

The minister may specify the ‘kind or kinds of ESOS registered higher education providers to which ATEC may make an allocation’ of commencing international students: new section 46B(3)(a).

ATEC will make the actual allocations of places, as described in this post. While the allocation process is unsatisfactory at every stage the allocations are not binding, and principally affect visa priority processing.

For non-table As with CSPs, ATEC’s discretion on how many to allocate gives them a point of leverage on compliance with international student commencing allocations. However, for 2027 the minister has exempted TAFEs from the planning levels, removing this power from ATEC if the ministerial exemption continues into 2028.

Compacts

Mission based compacts only apply to Table A (public university) and Table B (listed private university universities), so most non-Table A providers are exempt.

For Table B institutions compacts are the biggest difference between the old and the new funding systems. The most detailed description of their contents for 2027 comes from ATEC’s interim statement of strategic priorities, which I described here.

Including Table B providers in ATEC compacts was a mistake. I have not seen any rationale given for doing so. It seems to be a carry-over from the current system, but under it compacts are just summaries of what universities are doing on matters of interest to the government. The government’s interest in the current version of compacts is not great; they did not bother putting the 2025-26 compacts on the Department’s website until December 2025.

Under ATEC, the compacts are tools for broad interference in the running of universities to align them with government priorities. I am unconvinced of that for public universities, but for private universities it is completely inappropriate. They are not funded to deliver on government priorities. They should provide diversity in the system, not more of the same.

Of the current Table B institutions only Avondale University gets recurrent and significant CSP funding, nearly $12 million dollars and 705 places for 2026. In future, the compact process means that these CSPs will depend on Avondale’s performance against its compact.

Table B governing bodies need to consider asking to be removed from HESA 2003.

ENDS