The Group of Eight (Go8) recognises antisemitism as a serious, current and ongoing issue requiring sustained institutional action. Our members are committed to providing safe, respectful and inclusive university environments, while upholding academic freedom, freedom of speech, lawful expression, and procedural fairness.
The Go8 supports the amended Higher Education Standards Framework (Threshold Standards) requiring providers to define and respond to antisemitism as part of a whole-of-organisation approach to preventing and responding to racism.
For the Statement of Regulatory Expectations (SRE) to be effective, TEQSA’s guidance must be clear, principles-based and non-prescriptive. It should support providers in demonstrating compliance with the Threshold Standards without creating uncertainty about regulatory expectations or introducing additional obligations beyond those contained in the Standards themselves.
As currently drafted, the SRE risks blurring the distinction between enforceable requirements, examples of evidence and illustrations of good practice. This lack of clarity is significant given TEQSA’s stated intention to monitor compliance against the expectations in the SRE through registration, re-registration and compliance activity.
TEQSA should be clear about how it intends to use this SRE (and future SREs including ones covering Islamophobia and racism towards Aboriginal and Torres Strait Islander peoples) in its regulatory practice and the authority of the SRE with respect to the Threshold Standards.
The final SRE should also recognise the substantial progress already undertaken across the sector. Go8 universities have invested considerable effort in developing evidence-based responses to antisemitism, both individually and collectively.
In particular, the Go8 universities played a critical role in developing a sector-leading working definition of antisemitism (one that has subsequently been adopted by Universities Australia). They also established the Expert Advisory Committee on Combatting Antisemitism (EACCA) chaired by Dr Alan Finkel AC. EACCA delivered 21 recommendations in June 2026, including the adoption and operationalisation of the Universities Australia definition of antisemitism, and members are now actively working towards implementation.
The SRE should acknowledge and build upon these efforts. Universities should not be required to repeat genuine consultation, governance processes or implementation activities simply because they occurred before publication of the SRE or commencement of the amended Standards. Requiring duplication of work would impose unnecessary cost, delay practical action and risk retraumatising affected communities.
Recommendations
The Go8 recommends that:
- TEQSA should recognise the progress made by providers including consultation, governance decisions and implementation activities completed before or after publication of the SRE and commencement of the amended Threshold Standards.
- The SRE should clearly distinguish between enforceable obligations, examples of evidence and good practice guidance and explain how TEQSA intends to use the SRE in monitoring, registration, re-registration and compliance activities. In addition, TEQSA should clarify its approach to assessing proportionate and reasonable compliance given the set timeframes and be clear about the interpretation of “demonstrable progress towards compliance”.
- The SRE should retain an outcomes-focused approach, allowing providers flexibility to allocate responsibilities through their own governance arrangements, provided authority, escalation, accountability and governing body oversight are clear.
- The SRE should be framed in a way that manages potential unintended consequences by confirming its guidance status, and setting out principles for balancing safety, academic freedom, freedom of speech, lawful expression, and procedural fairness.
Further information
1.Recognising progress already made by providers
The draft appropriately acknowledges the importance of meaningful engagement with affected communities when considering and adopting a definition of antisemitism. The emphasis on safe, inclusive, trauma-informed consultation; breadth and diversity of participation; confidentiality and transparency; and protection from reprisal is constructive.
However, the final SRE should make clear that consultation and engagement undertaken before publication of the SRE can be recognised and relied upon where those processes were genuine, relevant and appropriately considered through institutional governance arrangements.
Universities should not be expected to repeat consultation simply because it occurred before publication of final guidance. The critical question is whether the engagement was meaningful and whether the outcomes remain relevant to the institution’s circumstances. Providers should retain responsibility for determining whether additional consultation is necessary in response to implementation requirements, institutional developments or changing circumstances.
The final SRE should also recognise that effective consultation can take many forms. Representative organisations, specialist advisers, academic experts, lived experience and direct engagement all have a role to play. Guidance should not imply that consultation is required on every aspect of a definition or implementation approach, particularly where institutions are responding simultaneously to multiple forms of racism and discrimination.
A principles-based approach that recognises prior work will encourage institutions to focus their efforts on implementation and outcomes rather than repeating processes that have already been undertaken in good faith.
2. Regulatory status and use of the SRE
The draft creates uncertainty about its status and intended use.
On the one hand, the document is presented as guidance intended to assist providers in understanding and meeting the Threshold Standards. On the other hand, TEQSA states that it will monitor compliance with the expectations contained in the SRE and may seek evidence through registration, re-registration and compliance activities.
Taken together, these provisions create uncertainty about whether the SRE is explanatory guidance, a de facto compliance checklist or an additional source of regulatory obligations.
The final SRE should clearly state that the Threshold Standards remain the sole source of enforceable obligations and that the SRE provides non-exhaustive examples of how compliance may be demonstrated.
Where TEQSA considers a particular expectation to be indispensable to compliance, the final SRE should identify the relevant provision in the Threshold Standards and explain the relationship between that requirement and the expectation. Similarly, examples of good practice should be clearly identified as illustrative rather than mandatory.
Providers require regulatory certainty in order to design proportionate compliance frameworks.
The final SRE should therefore describe categories of evidence that may assist TEQSA’s assessment without prescribing a fixed evidence model.
Relevant evidence may include governing body and management records, consultation outcomes, approved policies, implementation plans, training materials, institutional communications, complaints frameworks, monitoring reports and evidence of review and improvement.
The focus should remain on whether providers have implemented effective systems and controls that satisfy the Threshold Standards in their particular institutional context. TEQSA should expressly confirm that alternative approaches will be assessed on their merits and that departure from an example contained in the SRE will not, by itself, indicate non-compliance.
An outcomes-based regulatory approach will support innovation, proportionality and institutional accountability while preserving regulatory clarity.
3. Implementation timeframe and demonstrable progress
The proposed implementation timeline presents significant practical challenges.
TEQSA proposes to publish the final SRE in October 2026, with the amended racism standards commencing on 1 January 2027.
This period coincides with examinations, student assessment, graduations and the summer teaching break. It provides only a limited window for meaningful consultation, consideration through governance processes, policy development, systems changes, training and institutional communication.
The concept of “demonstrable progress towards compliance” also requires clarification.
The final SRE should distinguish between the commencement date of the amended Standards and the practical reality of implementing substantial institutional changes.
It should set out what TEQSA means by demonstrable progress and provide assurance that assessments will take account of:
- work undertaken before publication of the final SRE;
- institutional governance cycles;
- the timing of final guidance;
- resource and operational constraints; and
- evidence of genuine and good-faith implementation.
A proportionate approach is particularly important where providers have already undertaken significant preparatory work in anticipation of the amended Standards.
The final SRE should recognise that cultural and organisational change takes time and that providers should be assessed on the effectiveness and credibility of their implementation efforts rather than adherence to an arbitrary process timetable.
4. Allocation of responsibilities throughout the whole-of-organisation
The Go8 strongly supports a whole-of-organisation approach to addressing antisemitism.
A definition of antisemitism will only be effective if it is integrated into existing institutional frameworks covering governance, policy, student conduct, staff conduct, complaints management, risk, safety, teaching, learning and research activities.
Implementation should therefore be embedded within existing institutional systems rather than treated as a separate compliance exercise.
That said, the final SRE should avoid prescribing a single organisational structure or accountability model. Large and complex universities often distribute responsibilities across a range of functions, including senior executive leadership, governance and legal teams, student and staff wellbeing services, equity and diversity portfolios, academic governance bodies, human resources functions, complaints teams and security operations.
What matters is not where responsibility sits, but whether responsibilities are clear, appropriate escalation mechanisms exist, accountability is understood and governing bodies have sufficient visibility to exercise effective oversight.
The draft SRE assigns governing bodies a detailed role in planning, consultation, resourcing, implementation and record keeping. These should be presented as examples rather than regulatory requirements.
As a matter of principle, governing bodies should set strategic direction, oversee material risks and hold management accountable. Management, in turn, should be responsible for developing and implementing operational systems, policies, training, complaints processes and monitoring arrangements.
The final SRE should preserve flexibility in governance arrangements while ensuring clear accountability and effective oversight.
5. Addressing unintended consequences
The draft SRE risks creating several unintended consequences that should be addressed in the final version.
First, a lack of clarity about the status of the SRE risks transforming guidance into a de facto compliance checklist. If institutions come to believe that every action described in the document is mandatory, effort may shift away from achieving the outcomes required by the Threshold Standards and towards documenting adherence to process.
Such an approach would discourage innovation, undermine proportionality and reduce the ability of institutions to tailor responses to their own communities and circumstances.
Second, the draft provides limited guidance on how universities should balance efforts to prevent and respond to antisemitism with their obligations relating to academic freedom, freedom of speech, lawful expression and procedural fairness. These tensions arise regularly in teaching, research, public debate, complaints handling and disciplinary processes.
While the SRE should not attempt to determine individual cases, it should articulate the principles TEQSA will consider when assessing whether institutions have managed these obligations fairly, lawfully and effectively.
Third, requiring repeated consultation may retraumatise individuals who have already contributed their lived experience to institutional and sector-wide processes. It may also undermine confidence in earlier engagement by creating the perception that previous consultation was not meaningful.
This risk may be particularly acute where individuals belong to communities affected by multiple forms of racism and discrimination and are repeatedly asked to participate in overlapping consultation exercises. The final SRE should recognise these risks and encourage providers to build on prior work wherever possible.
Conclusion
The Go8 supports TEQSA’s objective of strengthening institutional responses to antisemitism and helping providers meet the amended Threshold Standards.
The final SRE will be most effective if it provides clear, principles-based guidance that focuses on outcomes rather than the prescribed processes, recognises substantial work already undertaken across the sector, and respects institutional autonomy in how compliance is achieved.
Universities should be encouraged to build on existing progress rather than duplicate work that has already been undertaken in good faith. A regulatory framework that recognises prior action, supports proportionate implementation and provides certainty about expectations will better achieve the shared objective of addressing antisemitism and strengthening campus safety.
The Go8 looks forward to continuing to work constructively with TEQSA as the guidance is finalised and implemented.