I don’t currently have the capacity for a new edition of Mapping Australian higher education 2023 but I am still updating the data behind the tables and charts. The latest spreadsheet is here.
The main changes since the last update are:
2026 Commonwealth Grant Scheme expenditure
2026 HELP lending
2025 staff data
2025 graduate outcomes
2024 research expenditure
Reorganised lists of university lobby groups
Ongoing changes in non-university higher education providers – despite the hostile policy environment new providers are still being registered by TEQSA
I will post again on the over-enrolment parts of the bill – in competition with Job-ready Graduates student contributions as the worst domestic student policy idea of the 2020s – but copy in my submission overview as a summary of its key themes:
The Universities Accord (Opening the Doors of Opportunity) Bill does not do what it says on the cover.
The bill’s sole mechanism for increasing enrolments in universities is more efficient use of existing funding.
The bill does not appropriate any new funding for additional student places. As under the current system, the minister will need to work through the government’s internal budget processes to secure that money.
By contrast, the bill has two new features that will reduce how many student places universities can offer.
The most important of these is caps on over-enrolments, on student contribution-only places delivered by universities above their allocated number of student places. If these laws had been in place in 2025, the maximum over-enrolments allowed would have permitted about half of the over-enrolments actually delivered, at the cost of more than 20,000 places across the system.
A planned default allocation of student places to public universities, while intended to reduce unused places, also threatens cuts. To use an example, a university’s default allocation of places for 2029 will be the lower of their places allocated for 2028 or the places actually delivered in 2027. If the university had received additional places for 2028 and respected their over-enrolment limit for 2027 the default position would wipe out some or all of their new 2028 places.
Due to problems with the bill’s drafting it will not achieve some of its other goals. The explanatory memorandum presents the default allocation described above as preventing a university’s allocation going backwards, but this is not what the bill itself guarantees.
The bill’s explanatory memorandum recognises problems with the current definition of low socioeconomic status, but the bill itself inserts a provision that will reduce how many low SES students attract needs based funding.
Another major issue with the bill is excessively broad ministerial discretion. The bill lets the minister impose conditions on receipt of Commonwealth Grant Scheme funds with no restrictions on how this power can be used. For allocations of international student commencements, the bill suspends an existing limit on the minister directing ATEC in respect of specific education providers.
The 2026 early implementation of enrolment restrictions, without statutory authority, shows that the government cannot just be trusted to do the right thing. Clear legal limits are required.
During the 2020s the government has implemented policy using a broad ministerial power to impose conditions on funding agreements. Universities must sign these agreements to receive Commonwealth Grant Scheme funding. I have criticised this use of funding agreements when the conditions subvert the intent of the Higher Education Support Act 2003 and/or avoid parliamentary scrutiny.
A repeat offence example is allocating Commonwealth supported places to specific courses, such as in the 20,000 equity places policy, when this is not supposed to happen unless the course is first ‘designated’ by the minister.
Another example is starting implementation of the equity plan expenditure of unused CGS grants through funding agreements, when this was actually to be financed under the ‘other grants’ provisions of HESA 2003. (Eventually proper legal processes were followed.)
A third example is the ban on early offers using funding agreements. Admissions-related issues are covered by other sections of HESA 2003 and by the Threshold Standards administered by TEQSA. A substantive policy issue like this should have gone via one of these processes that include parliamentary scrutiny.
The scope of ministerial discretionary power should be constrained. Instead, the funding legislation introduced in late June would lift some existing restrictions. It exposes universities and other higher education providers to worse misuse of power. This post explains the proposed changes and suggests remedies.
Current power to add conditions to funding agreements
Under the current HESA 2003, some conditions of funding are built into the legislation, such as which students are eligible for Commonwealth supported places. These will remain.
On top of the legislated conditions, current section 30-25(2) states that ‘the agreement may specify conditions to which the grants are subject, that are additional to the conditions that apply under Division 36’ [such as CSP eligibility]. This is the legal authority for the examples given above.
Section 30-25(2) has restrictions placed on it.
The minister cannot exclude a course from Commonwealth support using a funding agreement. This must be done under current section 36-15(2), which requires a legislative instrument to be used. This legislative instrument is subject to disallowance by either house of parliament: current section 30-25(2A).
Another restriction is that the conditions cannot relate to industrial relations matters: current section 30-25(2B). This was intended to stop Coalition governments using funding agreements to pursue their IR agendas.
Because funding agreements will no longer exist under the new system current sections 30-25, 30-25(2A) and 30-25(2B) are repealed by the amending bill: item 2, part 1, schedule 1.
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.
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.
This post in an overview of rewards and penalties available to ATEC as it enforces mission based compact terms and student places allocations.
By the standards of recent higher education regulation the ATEC compliance regime seems relatively weak. This may reflect a trade-off between maximising administrative discretion and creating clear laws to which fines could be attached.
The only automatic penalty universities face under the new system is for enrolling more students than the bureaucrats think they should have.
Rewards – the strange absence of mission funding
Despite the word ‘mission’ in the compact title and reference to university missions in the ATEC Act 2026 nothing in the original ATEC legislation, or the Universities Accord (Opening the Doors of Opportunity) Bill 2026 introduced late last month, gives ATEC any power to support universities in achieving their mission other than by allocating additional Commonwealth supported places.
A mission fund could have provided a balance to homogenising compact targets. But no such fund is planned and no legal provision under which it could be paid is in the current or amending legislation. With no mission funding the compacts are just another compliance exercise.
The Centre for the Study of Higher Education at the University of Melbourne has today published The fall and rise of postgraduate Commonwealth supported places, which I co-authored with Ren-Hao Xu. It is part of our research project on university decision-making under Job-ready Graduates, with other papers here and here.
As the title suggests, the paper shows how domestic postgraduate coursework places became increasingly full-fee before a reversal, so that now, for the first time since the 1990s, most places in public universities are Commonwealth supported. Additional flexibility in the use of CSPs introduced by Job-ready Graduates facilitated this growth.
This change saved postgraduate students significant amounts of money, but the scale of CSP provision looks fragile. We argue that it was partly a byproduct of excess capacity created by weak undergraduate demand in the post-lockdown years. As that demand returns pressure to move CSPs back to undergraduate courses will grow, compounded by tighter controls on CSP numbers in the ATEC era.
Financing domestic postgraduate coursework
With a few niche exceptions, all public university domestic undergraduates are in Commonwealth supported places (CSPs). But domestic postgraduate coursework – graduate certificate through to masters by coursework – has long been a mixed economy, with both Commonwealth supported and full-fee places on offer, sometimes in the same course. Full-fee students can use FEE-HELP to finance their studies.
Until Job-ready Graduates took effect in 2021, postgraduate CSPs were a ‘designated’ category, along with sub-bachelor places. Postgraduate CSPs were allocated to universities by funding cluster (groups of disciplines with the same Commonwealth contribution) in university-government funding agreements.
The spread of designated CSPs across postgraduate courses reflected historical allocations and ad hoc decisions on new places. These ad hoc allocations were not principle free – recurrent justifications included providing places for postgraduate initial professional entry courses and addressing skills shortages – but the cumulative consequences were untidy. University allocations of postgraduate CSPs ranged from dozens to thousands. This created messy local markets. Universities struggled to fill full-fee places when their competitors had CSPs.
Job-ready Graduates abolished specific allocations of postgraduate places, except in medicine. It put postgraduate coursework into a single fund with sub-bachelor and bachelor degree places. The Commonwealth contribution funding each university could receive for these places is their ‘maximum basic grant amount’ (MBGA).
From 2021, universities decided whether to use their CSPs in postgraduate courses. These decisions were not straightforward. A fixed maximum basic grant amount created a potential trade-off with undergraduate places. A second trade-off existed with full-fee postgraduate places, which usually generate significantly more revenue per place than a CSP.
Trends in postgraduate full-fee and Commonwealth supported places
Across the entire sector, including private higher education providers, domestic full-fee postgraduate places are just a majority, at 50.2% of all places.
But looking at public universities only, CSPs became a similarly narrow majority in 2021, the first year of Job-ready Graduates. The CSP share stood at 58% in 2024. The relative shares are back to where they were in the late 1990s, but with CSPs trending up rather than down.
In his second reading speech for the Universities Accord (Opening the Doors of Opportunity) Bill 2026 education minister Jason Clare said that it will ‘help more people from poor families and the regions and the bush to get into university. In simple terms, if you get the marks, and you’ve got what it takes you will get a place.’ Later in the speech, he described the new policy as ‘effectively uncapping the system for these students’.
This is the latest iteration of a concept first announced as ‘effectively demand driven’ funding in the Accord final report and then described by the Department of Education as ‘managed demand driven funding’.
Whatever its name, how this policy would be implemented remained unclear. The policy implies eligibility criteria – ‘if you get the marks’ – that do not exist at the system level. It raised questions about the coherence of the government’s position. Does it make sense to impose tougher caps on enrolments generally while claiming to ‘effectively uncap’ a sub-section of students? Isn’t this just a part-solution to an avoidable problem caused by hard caps?
The silence of the bill
Anyone hoping that the funding bill would provide clarity will be disappointed. There is no uncapping of places for any category of student that isn’t already demand driven. But another feature of the system gives ATEC some flexibility to allocate additional places late in the enrolment period.
A recap on the new system
First a recap on how the new system will work. The first step is for the minister to set a total allocation pool of places, which will cover all coursework places other than medicine and the demand driven programs for Indigenous students.
The second step is for ATEC to allocate those places to universities. This will be a combination of ‘core student load’, a historical figure, and an ‘additional growth allocation’. Together these are the ‘domestic student profile’ of each university.
On top of the domestic student profile universities will have an over-enrolment buffer, of 750 places or 5% of the domestic student profile, whichever is lower. As part of transition measures some universities can have total places exceeding these levels but caps on commencing students.
The idea behind needs based funding is that universities should be paid according to student characteristics, not just the disciplines of the subjects students take. While agreeing with the broad concept behind needs based funding, I have criticised the government’s approach for its limited use of direct measures of need.
Needs based funding as implemented modifies existing programs rather than making a major conceptual change to the funding system. It converts equity group funding and a regional campus loading to a per student basis, rather than the previous formula-driven shares of a fixed maximum fund.
I won’t re-prosecute my criticisms of the government’s policies in detail here. My focus will be on the how these policies have been translated into legislation through the Universities Accord (Opening the Doors of Opportunity) Bill 2026, introduced into Parliament in late June.
I have two main concerns about the bill compared to expectations. Low SES status will be defined by the time of enrolment in a unit of study, rather than the first address on enrolment with the provider, and so numbers will be under-stated. Also the minister can easily vary down the loadings for various student characteristics and regional campus payments for continuing students.
As with my previous explainer posts on this bill, I am happy to receive feedback via comments or direct communication.
Interim needs based funding
Needs based funding exists this year under interim legal measures. This post describes 2026 funding rules for low SES and Indigenous students. This post explains 2026 funding rules for regional campus students.
In those posts I was critical of their poor-practice legal basis, which allowed the minister to pay needs-based funding grants (or not) entirely at his discretion, with the substantive rules for allocation in a Department of Education document with no legal standing.
The bill will give the needs based funding programs a much stronger legal basis while still leaving significant ministerial discretion.
All legislative references in the following text are to the Higher Education Support Act 2003 unless otherwise specified, ‘current’ signalling the legislation now in force, ‘new’ signalling the amending bill.
Which higher education providers are eligible?
A provider is eligible if it has been allocated Commonwealth supported places for the year: new section 39-10. This applies to both the equity and regional parts of needs-based funding.
In presentations earlier this year I told audiences that the government will try again to impose provider-level caps on international students. Its 2024 attempt failed due to a surprise Coalition-Green alliance in the Senate. The basis of my statement was ATEC ‘s legislation, which said that it would ‘allocate a maximum number of international student commencements to ESOS registered providers’ (emphasis added).
But for unexplained reasons the government is backing away from tough provider-level international student enrolment limits. The Universities Accord (Opening the Doors of Opportunity) Bill 2026 gives ATEC a role in allocating commencements to higher education providers, but it is something closer to current national planning level allocations for new overseas student commencement (NOSC) than a hard capped system.
The basic process will be that the minister sets a total allocation pool of international student commencements, and ATEC then decides on the distribution between universities and other higher education providers.
As described in detail below, this process has very high levels of ministerial and ATEC discretion, to the point of both being able to reduce allocations after the students have started their courses.
While there should be much better processes than those set in the bill, at least for non-public university providers it is not obviously significantly worse than what we have now.
As for domestic students in Commonwealth supported places, the minister for education will start by setting a total pool of ‘overseas students that may commence a course of education with ESOS registered higher education providers during a specified period’: new section 46B(1).
What does the minister take into account when setting the international student allocation pool?
Although the minister’s promotional material focuses on new Commonwealth supported places expected over coming years he could have funded those under the current system – albeit imprecisely, as the current system largely allocates in dollars rather than places. The most we can say in favour of the bill and new places is that it will be more obvious whether or not they have been funded.
Where the bill differs most from the current funding system is in reducing places at the university level. In the previous post I explained how a year of under-enrolment could result in a lower allocation of places two years later. In today’s post I describe proposed new restrictions on over-enrolments, students taken above the allocated level.
All legislative references in the following text are to the Higher Education Support Act 2003 unless otherwise specified, ‘current’ signalling the legislation now in force, ‘new’ signalling the amending bill.
As with the earlier posts, this is one is dealing with complex legislation so I am happy to receive feedback through comments or direct communication.
The current system
Under the current ‘higher education courses’ grant – all CSP categories other than medicine or Indigenous students in demand driven places – there is a maximum basic grant amount. The value of CSPs delivered in this category is calculated as the Commonwealth contribution rate * the number of student places delivered. If the value of these places exceeds the MBGA the university gets the MBGA but no more: current section 33-5(2). In 2024 nine universities delivered student places worth at least 5% more than their MBGA.
For student contributions, however, there is no cap. The provisions on upfront student contributions and HECS-HELP loans give the Commonwealth no power to intervene on these payments: current sections 93-15 and 96-1 respectively.
The proposed system – capped student contributions
There will be a transitional scheme for currently over-enrolled universities, which I cover below. First I will focus on the long-run system under which universities will get an over-enrolment buffer, for which student contributions are paid, but then be penalised student contribution revenue for places in excess of the buffer.
Andrew Norton 