CRICOS registration is the second regulatory process a higher education provider must complete before it can enrol international students on student visas, and it cannot begin until TEQSA registration is granted. It is assessed by TEQSA against a different law, the Education Services for Overseas Students Act 2000 and the National Code 2018, rather than the Threshold Standards. A high-quality application is usually decided in three to six months, with a further two to four weeks before the CRICOS code is issued and recruitment can begin.
For most private providers the international market is the commercial reason for entering higher education at all, which makes it surprising how often CRICOS is treated as an afterthought. This article sets out the sequence, what the application involves, and where, in fifteen years of TEQSA registration work, I have seen providers lose time.
Why CRICOS registration comes after TEQSA registration
Under the ESOS Act, a provider can only be registered on the Commonwealth Register of Institutions and Courses for Overseas Students if it is already registered to deliver the course domestically. For higher education that means registration under the TEQSA Act, and TEQSA's own guidance on how to apply for CRICOS registration is explicit that higher education registration is the prerequisite. The only exceptions are providers delivering solely ELICOS or Foundation Programs, which follow their own route.
The practical consequence is a sequence that cannot be compressed. TEQSA registration comes first, taking nine months of substantive assessment after a preparation period of six to twelve months. CRICOS registration follows, and TEQSA's indicative timeframes note that providers typically lodge their CRICOS application about three months after initial registration is approved. That gap is the time it takes to assemble the ESOS evidence, and it can be shortened by preparing in parallel, but the application itself cannot be lodged early. The full timeline from first engagement to international delivery is, on TEQSA's own estimate, around thirty-five months.
What law does CRICOS registration assess against?
This is the point providers most often miss. The Threshold Standards are about the quality of higher education. The ESOS framework is about the protection of overseas students as consumers and as visa holders, and it is administered as an immigration-adjacent regime as much as an education one.
The ESOS Act establishes the registration requirement, the Tuition Protection Service, and the obligations to report to the Department through PRISMS. The National Code of Practice 2018 sets eleven standards covering marketing and recruitment, education agents, written agreements with students, formalising enrolment, younger students, student support services, course progress and attendance monitoring, overseas student transfers, deferral, suspension and cancellation, complaints and appeals, and additional registration requirements. A provider that has just completed a TEQSA application will recognise some of this and be unfamiliar with the rest.
The application must demonstrate compliance with both, and TEQSA continues to use a Confirmed Evidence Table for CRICOS assessment, so this is an evidence-against-every-requirement exercise of the kind TEQSA has retired for higher education registration.
What does the CRICOS application involve?
Beyond the fee, currently $24,500 for initial CRICOS registration, the application must show the provider can meet the National Code from the first day an international student enrols. The elements that take longest to prepare are consistent.
Written agreements with students must comply with Standard 3 of the National Code, setting out the course, fees, refund conditions and the provider's obligations in prescribed terms; the domestic enrolment contract will not do. Refund policies must meet the ESOS Act's default and refund provisions and interact correctly with the Tuition Protection Service. Education agent arrangements must be documented, with written agreements, monitoring and the capacity to terminate agents who act improperly, and a provider that intends to recruit through agents needs those agreements in place before it applies.
Course progress and attendance monitoring must be built into the student management system and the academic policies, with the intervention strategy the Code requires, because these are the mechanisms by which the provider meets its visa-related reporting obligations. Student support must extend to the specific needs of overseas students, including orientation to Australian law and conditions, and the provider must be able to demonstrate capacity to report through PRISMS. Financial viability is assessed again, with attention to the provider's capacity to meet its obligations to students if a course cannot be delivered.
TEQSA also assesses the provider's premises and facilities against the intended international enrolment, and applies a distinct fit and proper assessment under the ESOS Act to the people who will run the provider.
How long does CRICOS registration take?
TEQSA's published guidance says a decision on a high-quality application is usually made within three to six months, and that the provider is given the opportunity to respond within twenty-eight days if TEQSA identifies concerns during assessment. Once registration is granted, a further two to four weeks pass before the CRICOS code is issued and the provider is listed, and recruitment cannot begin until then.
From there, TEQSA recommends recruiting at least five months before delivery commences, allowing for offers, acceptances, confirmation of enrolment, and the student visa process, and it advises students to apply for their visa at least eight weeks before the course starts. Putting the pieces together, a provider registered by TEQSA in, say, March can realistically expect a CRICOS decision late in the year and a first international intake the following mid-year. Business plans that assume international revenue in the first year after TEQSA registration are wrong.
What is different once registered?
CRICOS registration brings a second set of ongoing obligations, and they are more procedural and more time-sensitive than TEQSA's. The provider must record every overseas student enrolment, variation and cancellation in PRISMS, report unsatisfactory course progress and attendance within prescribed times, notify TEQSA of changes to courses, locations, ownership and key personnel, and maintain the written agreements, refund arrangements and agent monitoring the Code requires. The material changes that must be notified under the TEQSA Act overlap with, but are not the same as, those required under the ESOS Act.
CRICOS registration is granted for a period of up to seven years, may be shorter, and may carry conditions. Its renewal is a separate application from the renewal of higher education registration, and the two are best sequenced together.
Preparing in parallel
The most useful advice is to prepare the CRICOS application during the TEQSA substantive assessment rather than after it. The National Code policies, the student agreement, the refund policy, the agent agreements and the PRISMS-ready student management system can all be built while TEQSA is assessing the higher education application, so that the CRICOS application is lodged within weeks of registration rather than months. That single decision shortens the path to international revenue by a quarter of a year or more, at no cost beyond doing the work earlier.
What cannot be done in parallel is recruitment. Marketing to overseas students, engaging agents to recruit, and issuing offers before the CRICOS code is issued are breaches of the ESOS Act, and TEQSA treats them seriously. Build everything; sell nothing until the code arrives.
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Frequently asked questions
Can a provider apply for CRICOS registration at the same time as TEQSA registration?
No. Higher education registration under the TEQSA Act is a prerequisite for CRICOS registration. The CRICOS application can be prepared in parallel but lodged only after TEQSA registration is granted.
How long does CRICOS registration take for a higher education provider?
TEQSA indicates that a decision on a high-quality application is usually made within three to six months, with a further two to four weeks before the CRICOS code is issued and recruitment can begin.
What does TEQSA assess a CRICOS application against?
The Education Services for Overseas Students Act 2000 and the National Code of Practice for Providers of Education and Training to Overseas Students 2018, not the Threshold Standards. TEQSA uses a Confirmed Evidence Table for CRICOS assessment.
Can a provider recruit international students before its CRICOS code is issued?
No. Marketing to, recruiting or enrolling overseas students before CRICOS registration is granted and the code issued is a breach of the ESOS Act.
Dr Brendan Moloney is CEO of Darlo Higher Education, Australia's largest specialist TEQSA consultancy. He holds a PhD from the University of Melbourne, is a Cambridge University Press author on governance in higher education, and has advised private providers on registration and course accreditation for more than fifteen years.