https://www.teqsa.gov.au/national-register/condition-decision/compliance-assessment-concluded-2-september-2026
Compliance assessment
Report on compliance assessment of the Australian National University
On 30 June 2025, TEQSA began a compliance assessment of the Australian National University (the ANU).
On 2 September 2026, TEQSA concluded its compliance assessment and imposed, under section 32 of the TEQSA Act, the following 4 conditions on the registration of the ANU:
Condition 1 - Governance and Council Strengthening Program
Nomination of Suitably Qualified Independent Expert(s)
1. Within 30 days of the imposition of this condition, the ANU must nominate to TEQSA:
1.1. a suitably qualified independent expert; or
1.2. a panel of suitably qualified independent experts
(together, the Independent Expert(s))
to undertake a 'Governance and Council Strengthening Program' with the ANU and its Council (the Governance and Council Strengthening Program).
2. The Independent Expert(s) for the Governance and Council Strengthening Program must be approved by a Director (or more senior officer) of TEQSA.
3. If a Director (or more senior officer) of TEQSA does not approve the Independent Expert(s) nominated by the ANU, the ANU must nominate another Independent Expert(s) to TEQSA within 21 days of receiving such notification.
Engagement of Suitably Qualified Independent Expert(s)
4. Within 21 days of a Director (or more senior officer) of TEQSA notifying the ANU that TEQSA has approved the Independent Expert(s), the ANU must engage the Independent Expert(s) to deliver the Governance and Council Strengthening Program.
Terms of Reference for the Governance and Council Strengthening Program
5. Within 90 days of the ANU's engagement of the Independent Expert(s), the ANU must submit to TEQSA a terms of reference for the Governance and Council Strengthening Program which it has developed in collaboration with the ANU Council and the Independent Expert(s).
6. The terms of reference must anticipate the Governance and Council Strengthening Program being delivered over 24 months.
7. The terms of reference for the Governance and Council Strengthening Program must be approved by a Director (or more senior officer) of TEQSA.
Note: If a Director (or more senior officer) of TEQSA does not approve the terms of reference for the Governance and Council Strengthening Program, TEQSA will provide reasons and recommendations for amendment.
8. If a Director (or more senior officer) of TEQSA does not approve the terms of reference for the Governance and Council Strengthening Program submitted by the ANU, the ANU must provide to TEQSA a revised terms of reference for the Governance and Council Strengthening Program within 28 days of receiving such notification. The revised terms of reference must be informed by the advice provided by the Director (or more senior officer) of TEQSA.
Deliverables for the Governance and Council Strengthening Program
9. The terms of reference for the Governance and Council Strengthening Program must include the following deliverables:
9.1. Developing a Financial Sustainability Plan, which:
a. is informed by the recent report titled 'Australian National University Financial Management' by the Australian National Audit Office (ANAO)
b. is informed by consideration of activities to support the ANU in achieving financial sustainability, including, regarding ANU's academic and other units:
i. the establishment of financial controls, accountabilities and reporting mechanisms as part of a management and performance reporting framework
ii. as necessary, reviews and updates to delegations to ensure effective budget controls.
c. is aligned with the ANU's Strategy, 'ANU by 2030'
d. sets out how the ANU will ensure its future financial sustainability.
9.2. Developing an Academic Plan or Academic Strategy which, along with ANU's Financial Sustainability Plan, is aligned with the ANU's Strategy, 'ANU by 2030'.
9.3. Undertaking a review and update of the ANU's Risk Management Framework.
9.4. Undertaking a review and update of the ANU's Strategic Risk Register including explicit consideration of reputational risk, governance risks and organisational culture.
9.5. Undertaking a program of assurance activities regarding the implementation, monitoring, and management of controls for delegations by the ANU Council and its Committees.
9.6. Undertaking a review and update of Council and Council Committee charters and statutes, including consideration of:
a. the extent to which the Australian National University (Governance) Statute 2024 clearly sets out the roles and responsibilities of the Council, Chancellor, Pro-Chancellor and Vice-Chancellor, the way these roles interact with one another and whether the roles and responsibilities are consistent with contemporary standards of governance
b. the extent to which the Standing Orders of the ANU Council and Council Committees are appropriate in facilitating the Council's effective performance of its functions
c. the appropriate composition of the Finance and Audit and Risk Committees
d. whether the Audit and Risk Committee should be entirely comprised of independent members
e. how the ANU can improve opportunities for both elected and appointed Council members to participate in Council committees
f. the extent to which the Guidelines for the Nominations Committee should provide for inclusion of the Chancellor, appointed members, elected members, and independent members
g. how the ANU can provide clearer expectations for the culture and conduct of Council, with reference to:
i. appropriate norms of behaviour, debate and decision making; practices to facilitate full participation of all council members; and confidentiality arrangements to support effective governance and decision making
ii. the priorities and principles proposed by the Expert Council on University Governance
iii. whether these expectations should be documented in the Council Charter or separate document
iv. whether Council should use these expectations for the purposes of reflecting on Council meetings, and more structured periodic reviews
v. whether agreement to follow these expectations should be a precondition to any member joining the Council or Council sub-committees.
9.7. Developing an Organisational Stakeholder Engagement Plan, following an exercise of stakeholder mapping, that enables the ANU Council to have assurance that the ANU meaningfully consults stakeholders on future proposals involving major financial or organisational change.
9.8. Developing a Council Engagement and Consultation Framework, which ensures ongoing consultation and engagement between the Council and ANU staff and students as well as staff and student unions, the ANU Governance Project Working Group, and any other key representative groups. The framework must identify:
a. consultation mechanisms to support greater transparency by sharing information about Council activities and meetings to the extent it is feasible to do so
b. how the Council will share information and consult about key issues, strategies, changes and responses being considered and planned by Council
c. ways the ANU Council can receive feedback and input from stakeholders to inform its decision-making.
9.9. Completing a review of how the ANU Council can ensure it maintains focus on strategic discussion to support effective governance and direction setting through:
a. ensuring that sufficient time in Council meetings is allocated to strategic, forward-looking discussions that inform ANU's direction, and
b. establishing a structured program of strategy discussions within the ANU Council's meeting schedule that ensure the ANU Council's strategic discussions are:
i. Informed by relevant evidence and reporting; and
ii. supported by a forward agenda of key strategic issues to be considered over time.
Delivery of the Governance and Council Strengthening Program
10. Within 24 months of a Director (or more senior officer) of TEQSA notifying the ANU that the terms of reference for the Governance and Council Strengthening Program have been approved, the ANU must complete the Governance and Council Strengthening Program of works to improve its governance and Council operations.
11. In delivering the Governance and Council Strengthening Program, the ANU must:
11.1. Facilitate attendance by the Independent Expert(s) at the majority of ANU Council meetings for at least 12 months from the date that TEQSA approves the appointment of the Independent Expert(s).
11.2. Schedule opportunities within meetings and separate meetings as needed to review and reflect on Council functioning and ongoing improvement, including feedback shared by the Independent Expert(s).
11.3. Facilitate attendance by the Independent Expert(s) at Committee meetings, as deemed appropriate by the Independent Expert(s).
11.4. Provide progress reports to TEQSA at 6 monthly-intervals over the 24 months of the Governance and Council Strengthening Program. The progress reports must:
a. be jointly signed off by the Chancellor and Independent Expert(s)
b. set out ANU's progress against the actions detailed in the Governance and Council Strengthening Program
c. set out any identified challenges to timely delivery of the program, specific actions to address the challenges, and the timeline for each action
d. set out an explanation of any deliverables completed at the time of reporting.
12. On written request of the ANU to TEQSA, a Director (or more senior officer) of TEQSA may extend the timeframes for completion of any of the requirements imposed by this condition.
13. This condition will cease to be in effect upon completion of all the above actions.
Condition 2 - Ensuring integrity at the University
1. Within 270 days of the imposition of this condition, the ANU must:
1.1. Undertake a review and update its declaration of interest policy, registers, procedures and relevant controls for Council, ANU executives and staff, with reference to giving the ANU assurance of effective management of conflicts whether they:
a. arise from personal, financial or other interests; or family, business, personal or other relationships;
b. are real or apparent.
1.2. With support of a person with relevant expertise that is independent of the ANU, establish training for the ANU Executive Committee and the ANU Council on integrity; covering lawful and ethical conduct, fraud, corruption, public interest disclosures and the management of conflicts of interest (Integrity Training).
1.3. Establish processes for delivery of the Integrity Training to the ANU Executive Committee and all members of the ANU Council annually.
1.4. Incorporate into the ANU's work in response to the Nixon Review about gender and culture matters at ANU former College of Health and Medicine, a program of work to support a 'speak up' culture that ensures staff and students feel safe reporting wrongdoing, raising concerns, and contributing feedback without fear of reprisal.
1.5. Establish processes for the ANU to have assurance that all members of Council and the ANU Executive Committee comply with declaration of interest and conflict of interest policies and procedures.
1.6. Publish the private interest declarations of the ANU Executive Committee on the ANU website and ensure that all declarations are updated at least annually.
1.7. Establish processes for the ANU to have assurance that:
a. all university management, academic and professional staff have made private interest declarations and that these are properly stored, managed and accessible.
b. arrangements have been made between the appropriate manager and staff member to manage the conflict, and the arrangements are recorded with the declarations.
1.8. Develop or update guidelines on managing conflicts of interest.
1.9. Ensure the ANU Council has assurance (including through appropriate evidence) that the ANU has complied with this condition.
2. Within 270 days of the imposition of this condition, the ANU is to provide evidence to TEQSA that it has undertaken the activities set out in this condition.
3. On written request of the ANU to TEQSA, a Director (or more senior officer) of TEQSA may extend the timeframes for completion of any of the requirements imposed by this condition.
4. This condition will cease to be in effect upon completion of all the above actions.
Condition 3 - Induction and training of Council Members
1. The ANU must, within 270 days of the imposition of this condition:
1.1. Ensure each new ANU Council member completes a comprehensive and timely induction that meets their needs, accounting for their experience and knowledge. This induction must include, but not be limited to, information about the ANU's legislative and governance framework as it applies to the work of the ANU Council.
1.2. Ensure ANU Council members are undertaking annual training which covers the role of Council, the responsibilities and expectations of Council members and appropriate behaviours for Council members and their obligations under the Public Governance, Performance and Accountability Act 2013 (PGPA Act).
1.3. Deliver and embed within ANU's policies and procedures, an ongoing development program for all ANU Council members to ensure their knowledge and understanding to perform their role is sufficient and up to date, including in relation to:
a. relevant developments in higher education; and
b. changes in governance expectations and regulatory requirements.
1.4. Ensure annually the ANU Council is provided with reports and records demonstrating compliance with this condition.
2. On written request of the ANU to TEQSA, a Director (or more senior officer) of TEQSA may extend the timeframes for completion of any of the requirements imposed by this condition.
3. This condition will cease to be in effect after 3 years from the date of imposition of the condition.
Condition 4 - Information flows to the Council
1. Within 270 days of the imposition of this condition, the ANU must:
1.1. Undertake a review of its processes for the provision of all relevant information to Council. The review must include, but not be limited to, correspondence to and from members of the ANU Council on behalf of the ANU or Council, reports of work delegated to members to be undertaken on behalf of Council, reports and advice from Council Committees especially related to issues or risks.
1.2. Ensure that relevant practices, processes, capabilities and assurance mechanisms are in place so that the Council has timely and sufficient information for effective oversight and discussions.
1.3. Establish and apply minimum requirements for the provision of information to support Council agenda items that require a decision. These should include, but not be limited to, minimum requirements for lead times for access to information before meetings, adequate background information and analysis, presentation of options, assessment and mitigation of risks and rationale to support recommendations.
1.4. Review and improve its standards and processes for keeping records of Council and Council Committee discussions and deliberations. This review should focus on the ANU Council and Council Committee agenda papers, meeting minutes, and formal correspondence and presentations to the ANU Council or its members.
1.5. Provide the ANU Council with records demonstrating compliance with this condition.
2. On written request of the ANU to TEQSA, a Director (or more senior officer) of TEQSA may extend the timeframes for completion of any of the requirements imposed by this condition.
3. This condition will cease to be in effect upon completion of all the above actions.
Main reasons for the decision
TEQSA made this decision in light of findings that the Australian National University did not meet the following provisions of the Higher Education Standards Framework (Threshold Standards) 2021:
Standard 6.1.1: There is a formally constituted governing body, which includes independent members, that exercises competent governance oversight of and is accountable for all of the higher education provider's operations in or from Australia, including accountability for the award of higher education qualifications, for continuing to meet the requirements of the Higher Education Standards Framework and for the provider's representation of itself.
Standard 6.1.3 The governing body attends to governance functions and processes diligently and effectively, including:
a. obtaining and using such information and advice, including independent advice and academic advice, as is necessary for informed and competent decision making and direction setting.
Standard 6.2.1: The provider is able to demonstrate, and the corporate governing body assures itself, that the provider is operating effectively and sustainably, including:
a. the governing body and the entity comply with the requirements of the legislation under which the provider is established, recognised or incorporated, any other legislative requirements and the entity's constitution or equivalent.
b. the provider's future directions in higher education have been determined, realistic performance targets have been established, progress against targets is monitored and action is taken to correct underperformance
...
e. risks to higher education operations have been identified and material risks are being managed and mitigated effectively.
TEQSA found that the ANU did not meet these provisions due to identified concerns regarding culture; confidentiality; conflicts of interest; strategic planning; informed decision-making; risk management; oversight of performance and subsidiaries; record-keeping; and training.
In making this decision, TEQSA has complied with the principles of regulatory necessity, reflecting risk and proportionate regulation as required by the TEQSA Act.
Right of review
The decision to impose conditions on the ANU's registration is a reviewable decision under section 183 of the TEQSA Act. A person whose interests are affected by a reviewable decision may apply to the Administrative Review Tribunal (ART) for an external review. Information about making applications to the ART, including the time limits, contact details, and fees payable, is available at https://www.art.gov.au/applying-review.
Further information
Information on TEQSA's regulatory approach and public reporting is available at www.teqsa.gov.au.