July 29, 2026
Parliamentary Joint Committee on Intelligence and Security
The Go8 consents to the publication of this submission and has no wish for any of it to be treated as confidential.
The Group of Eight (Go8) supports measures that protect and advance Australia’s national interest, including economic prosperity, national security, sovereign capability and international standing. At the same time, Australia’s future competitiveness will depend on its ability to remain deeply engaged in global research, innovation and education networks. Effective policy settings must therefore both mitigate risk and preserve the international collaboration that underpins discovery, talent development, economic growth and strategic advantage.
The Foreign Arrangements Scheme (FAS), established through Australia’s Foreign Relations (State and Territory Arrangements) Act 2020, forms part of a broader policy architecture designed to strike this balance. The FAS provides transparency and oversight of arrangements entered into by State and Territory entities, including public universities, to ensure consistency with Australia’s foreign policy and foreign relations objectives.
In the six years since it came into effect, the geostrategic environment has continued to evolve. ASIO Director-General Mike Burgess has repeatedly warned that Australia faces a dynamic, diverse and degraded threat environment that has emerged far earlier than previously anticipated.[1] As a result, Australia’s policy and regulatory frameworks must continually adapt to remain targeted, sophisticated and responsive to changing risks.
In that context, the Go8 supports the review of the FAS and recognises the need for the scheme to evolve. However, the objective should not simply be to mitigate risk but to do so in a way that preserves the openness and international engagement that underpin Australia’s economic resilience, technological advancement, research capability, and global competitiveness.
Australia must not lose sight of the fact that our position as a trusted and attractive partner for international collaboration is itself an important national asset.
We compete globally for research partnerships, talent, investment and transnational education opportunities. Our regulatory settings should reinforce Australia’s reputation as a trusted, predictable and attractive collaborative partner. International engagement should not be viewed primarily as a source of vulnerability; rather, it should be recognised as a critical source of national strength and strategic advantage in an increasingly contested global environment.
Recommendations
The Go8 recommends that the Committee:
- Support the Bill’s shift from a focus on Australia’s foreign relations to Australia’s broader national interest, while ensuring regulation is proportionate and appropriately calibrated. In doing so, the Committee should recognise that international education, research and innovation partnerships are themselves important contributors to Australia’s national interest.
- Support a more coordinated and consistent whole-of- government approach, including a clear overarching framework outlining Australia’s legislative and regulatory approach to deterring foreign interference and ensuring greater consistency in risk frameworks, terminology and tolerance thresholds.
- Ensure the Foreign Arrangements Scheme remains targeted, risk-based and proportionate, by streamlining notification requirements, simplifying assessments of institutional autonomy and removing the requirement to notify minor variations to previously approved arrangements. Such reforms would reduce unnecessary administrative burden and allow universities to focus resources on research, education and international engagement.
- Implement Recommendation 17 of the Independent Review by providing clear country-based guidance to assist universities in assessing institutional autonomy.
- Recognise and leverage the substantial research security, foreign interference and governance frameworks already established by Australian universities, including those developed through the University Foreign Interference Taskforce (UFIT) and subsequent sector-led initiatives.
- Ensure implementation guidance provides appropriate clarity regarding the collection, use, handling and protection of information disclosed under the legislation, thereby providing confidence to international partners while supporting the effective operation of the legislation.
- Ensure any extension of the FAS to offshore campuses is implemented in a way that is proportionate, practical and predictable, and does not create unintended barriers to international education, research collaboration or transnational partnerships that are clearly in Australia’s national interest.
- Support universities in implementing any changes through the provision of clear guidance, toolkits and practical implementation support.
Emphasis on the National Interest
The Go8 supports the shift in focus from Australia’s foreign relations to Australia’s broader national interest. This reflects the reality that Australia’s economic, security, and strategic priorities are increasingly interconnected and require a more holistic and coordinated policy approach. It is a welcome evolution from more fragmented regulatory settings and provides an opportunity to better align the Scheme with Australia’s contemporary strategic priorities.
Australia’s research-intensive universities share this objective and have worked closely with government over many years to develop one of the world’s most comprehensive research security and foreign interference frameworks. This experience demonstrates that it is possible to protect Australia’s national interests while maintaining the international engagement and collaboration that underpin innovation, economic prosperity, sovereign capability, and strategic advantage.
The Go8 strongly supports the need for effective safeguards against foreign interference and other national security risks. However, regulation must remain proportionate, targeted and focused on clearly identified risks. Policy settings that unnecessarily deter international engagement, collaboration and partnership can themselves create strategic costs for Australia by reducing access to talent, knowledge, investment and global networks that contribute directly to the national interest.
Importantly, Australia’s national interest is advanced not only through the management of risk, but also through the pursuit of opportunity. International research collaboration, transnational education, strategic research partnerships and the attraction of global talent strengthen Australia’s research capability, economic resilience, diplomatic influence and sovereign capacity. They also enhance Australia’s reputation as a trusted, reliable and attractive partner in an increasingly competitive global environment.
For this reason, the administration of the Scheme should recognise that international engagement is not merely a potential source of vulnerability to be managed, but a strategic national asset to be leveraged. Australia’s regulatory settings should support both objectives: protecting national interests while preserving the openness and international connectivity that are essential to Australia’s future prosperity, competitiveness and security.
A More Integrated and Coordinated Approach
The Go8 supports a more coordinated and consistent whole-of-government approach to addressing foreign interference and related national security risks. As Australia’s regulatory architecture has expanded over recent years, universities and other stakeholders are increasingly required to navigate multiple frameworks with overlapping objectives, differing terminology and varying risk methodologies.
A more integrated approach would improve both effectiveness and efficiency. It would provide greater clarity regarding how individual measures collectively contribute to protecting Australia’s national interest, while reducing duplication and unnecessary compliance burden. Importantly, it would enable government and institutions to focus resources on managing genuine risks rather than navigating fragmented regulatory processes.
Key elements of such an approach should include:
- A comprehensive framework outlining how existing measures collectively address foreign interference risks, allowing for the identification of overlaps and gaps;
- Greater consistency in risk frameworks, terminology and tolerance thresholds, including closer alignment with the Australian Research Council’s (ARC) approach and broader UFIT framework;
- A coordinated approach across government agencies to support more consistent decision making and improve efficiency for government and the sector.
The Go8 supports the Bill’s shift from assessing foreign arrangements primarily through the lens of Australia’s foreign relations to a broader consideration of Australia’s national interest. However, this broader focus should be accompanied by a regulatory approach that remains proportionate, targeted and appropriately calibrated to risk. In doing so, government should recognise that international education, research and innovation partnerships are themselves important contributors to Australia’s national interest, strengthening Australia’s research capability, economic resilience, sovereign capacity and global influence.
Recommendation: Support the Bill’s shift from Australia’s foreign relations to Australia’s broader national interest, while ensuring regulation remains proportionate, targeted and appropriately calibrated to risk, and recognising that international education, research and innovation partnerships are themselves significant contributors to Australia’s national interest.
Recommendation: Support a more coordinated and consistent whole-of-government approach, including the development of a clear framework outlining Australia’s overall legislative and regulatory response to foreign interference, with greater consistency in risk frameworks, terminology and tolerance thresholds.
Streamlined Measures
The Go8 supports the proposed measures to streamline notification requirements, simplify assessments of institutional autonomy and remove approval requirements for minor variations to previously approved arrangements. These changes better align the Scheme with a risk-based regulatory model and will assist in ensuring compliance effort is directed towards matters of genuine strategic significance.
The Go8 and its member institutions engaged with the Independent Review of the Scheme led by Rosemary Huxtable AO PSM and were pleased to see our feedback on how to better target genuine risk reflected in many of its recommendations. We also appreciated DFAT’s constructive engagement through targeted consultation on exposure drafts and its willingness to work collaboratively with the sector to improve the practical operation of the Scheme.
Key changes that will assist public universities include shifting to one step notification for non-core arrangements (Part 11); increasing the transparency, accuracy and usability of the Public Register (Part 12, Division 3); and ensuring the Act is reviewed regularly (Part 10).
Notwithstanding these reforms, challenges remain in determining institutional autonomy. While removing the need to review governing documents will reduce administrative complexity, universities must still assess a range of legislative and regulatory settings that may affect governance, education and research activities, including issues relating to censorship, academic freedom and other government-imposed constraints. Additional guidance would support more consistent assessments across the sector.
The Go8 therefore strongly supports implementation of Recommendation 17 of the Independent Review, which would provide institutions with country-based guidance and identify foreign universities previously assessed as not possessing institutional autonomy. This would improve consistency, reduce duplication and significantly lessen the compliance burden on universities while strengthening the overall effectiveness of the Scheme.
The Go8 also welcomes the Government’s commitment to continue engaging regularly with universities through UFIT and other forums to provide coordinated information in foreign policy settings, current and emerging risks and intelligence insights. This engagement, along with a strengthening of DFAT’s capacity to undertake or coordinate technical assessments, especially in regard to complex research matters, will assist in the effectiveness and efficiency of the Scheme.
Recommendation: Ensure the Foreign Arrangements Scheme remains targeted, risk-based and proportionate, including by streamlining notifications, simplifying assessments of institutional autonomy and removing approval requirements for minor variations to existing arrangements. These changes will enable universities to focus resources on research, education and international engagement while maintaining appropriate safeguards for Australia’s national interest.
Recommendation: Provide clear country-based guidance to support assessments of institutional autonomy, consistent with Recommendation 17 of the Independent Review, to improve regulatory consistency, reduce administrative burden and strengthen compliance outcomes.
Existing Research Security and Foreign Interference Frameworks
Australia has invested significantly over recent years in developing one of the world’s most comprehensive research security and foreign interference frameworks. This framework reflects a sustained partnership between government, national security agencies and universities to protect Australia’s national interests while preserving the international engagement that underpins research excellence, innovation, economic prosperity and sovereign capability.
Through this collaboration, Australia has established a mature and increasingly sophisticated security architecture that includes the University Foreign Interference Taskforce (UFIT), the Guidelines to Counter Foreign Interference in the Australian University Sector, the Australian Research Council’s Research Security Framework, strengthened visa and export control arrangements, foreign interference legislation, and the inclusion of higher education institutions within Australia’s broader critical infrastructure and national security frameworks.
These measures are complemented by significant institutional investment by universities themselves. As Australia’s leading research-intensive universities and custodians of much of the nation’s advanced research capability, Go8 members have implemented extensive governance, due diligence, risk management and security oversight arrangements. Universities routinely assess international partnerships, undertake detailed partner due diligence, manage export control obligations, engage with national security agencies and apply research security considerations across decision-making processes.
Collectively, these arrangements have fundamentally reshaped how international research and education partnerships are assessed and managed. Australian universities do not operate in the absence of security oversight. Rather, they operate within a highly developed and increasingly integrated security ecosystem that has evolved in response to the changing strategic environment.
Importantly, Australia’s approach is increasingly recognised internationally as a leading model for balancing security and openness. The risk-based frameworks developed through UFIT and related initiatives have informed similar approaches in jurisdictions including Canada, New Zealand and the United Kingdom. This demonstrates that it is possible to protect national interests while maintaining the trusted international collaborations that are essential to scientific advancement, technological innovation and economic competitiveness.
The Go8 acknowledges that the threat environment will continue to evolve and that regulatory frameworks must adapt accordingly. However, future reforms should build upon and leverage the substantial safeguards already established across the sector. New measures should complement existing arrangements, avoid unnecessary duplication and ensure that regulatory effort is focused on areas of genuine risk.
The objective should be to strengthen Australia’s national interest through a regulatory framework that remains targeted, proportionate and risk-based, while recognising that trusted international engagement is itself a strategic national asset. Effective regulation should enhance both Australia’s security and its position as a reliable and attractive partner for international research, innovation and education collaboration.
Recommendation: Recognise and leverage the substantial research security, foreign interference and governance frameworks already established within Australian universities, including those developed through the University Foreign Interference Taskforce (UFIT) and subsequent sector-led initiatives.
Information Sharing and Commercial Sensitivities
The Go8 notes the expanded information-sharing provisions contained in the Bill. Confidence in the handling of information disclosed under the Scheme will be critical to its effective operation. Universities routinely manage international collaborations involving commercially sensitive information, intellectual property, strategic technologies and industry partnerships. Maintaining the trust of research, industry and international partners is therefore essential.
The Go8 supports information-sharing arrangements that enable the Scheme to operate effectively. However, implementation guidance should provide clear assurances regarding the collection, use, handling, disclosure and protection of information provided under the legislation. Greater clarity will support compliance, provide confidence to partners and ensure the Scheme continues to facilitate rather than inadvertently discourage trusted international collaboration.
The Go8 also recognises that decisions under the Scheme may at times rely on classified intelligence or national security advice. While recognising the need to protect sensitive information, institutions should, where possible and consistent with Australia’s security interests, be provided with sufficient information to understand regulatory expectations and respond appropriately to identified concerns. Greater transparency and clarity regarding decision-making factors can strengthen both compliance outcomes and confidence in the Scheme’s operation.
Recommendation: Ensure implementation guidance provides appropriate clarity regarding the use, handling and protection of information disclosed under the legislation, providing confidence to research, industry and international partners while supporting the effective operation of the Scheme.
International Engagement as a Strategic National Asset
Australia’s policy and regulatory settings must support, rather than impede, Australia’s national interest.
Strong and effective international engagement strengthens alliances and partnerships that contribute to regional stability and deterrence; supports collective security in our region; enhances cooperation on transnational challenges such as cyber threats and terrorism; and boosts our economy by opening up trade opportunities and facilitating mobility of skilled workers.
Universities, particularly research-intensive universities, play a vital role in this strategic effort. Through research, education and innovation partnerships, they strengthen Australia’s national resilience, advance economic prosperity, contribute to sovereign capability and enhance Australia’s global influence.
Australia’s recent association negotiations with Horizon Europe illustrate this point. The successful conclusion of negotiations with the European Union demonstrates the strategic value both Australia and its partners place on trusted international collaboration. Participation in Horizon Europe will strengthen Australia’s ability to work with like-minded partners on shared priorities including advanced technologies, clean energy, health, space, critical minerals and supply chain resilience. Such partnerships contribute directly to Australia’s national interest by enhancing capability, accelerating innovation and expanding opportunities for Australian researchers and businesses.
As noted by the European Commissioner for Startups, Research and Innovation, Ekaterina Zaharieva:
With the EU-Australia agreements last week, we are moving quickly to bring our innovation ecosystems closer together. This will add to the growing list of likeminded countries that have chosen to join Horizon Europe, the world’s largest and most prestigious research programme. [2]
Australia should view trusted international engagement not solely as a source of potential risk requiring regulation, but as a strategic national asset that underpins research excellence, technological advancement, sovereign capability, economic prosperity and global influence. In an increasingly contested and competitive environment, Australia’s attractiveness as a trusted international partner is itself a significant national advantage.
Offshore Campuses and Transnational Education
The Go8 notes the proposal to extend the FAS to offshore campuses. This represents a significant expansion of the Scheme and should be implemented carefully, recognising both the strategic importance of transnational education and the mature governance frameworks already operating across the university sector.
Successive Australian governments have encouraged universities to expand transnational education as part of Australia’s international education, trade and diplomatic strategy. Offshore campuses and transnational education partnerships support Australia’s economic prosperity, strengthen people-to-people links, deepen strategic relationships and expand Australia’s influence across key regions.
The Australian Strategy for International Education 2021-2030 identifies offshore delivery as part of the sector’s diversification agenda, while the Minister for Education, Jason Clare MP, has emphasised that international education is not a “one-way street” and is “increasingly about Australian universities going to the world”.[3]
Consistent with this policy direction, TEQSA has developed a dedicated Transnational Education Toolkit to support institutions in the delivery of offshore education.[4]
Transnational education delivers substantial benefits in the national interest. It supports Australia’s economic prosperity, enhances our international reputation and influence, strengthens people-to-people links, and contributes to long term diplomatic, trade, research and innovation partnerships. Through offshore campuses and educational partnerships, Go8 universities help extend the reach and impact of Australia’s world-class education system, while deepening engagement with key regional and international partners.
The Go8 supports appropriate oversight of these activities. However, any extension of the FAS to offshore campuses must be proportionate, practical and predictable. It should be targeted to genuine national risks and should avoid duplicating existing regulatory, governance and due diligence processes already operating across Australian universities.
Given the significance and complexity of this change, universities will require clear guidance and practical implementation support to ensure compliance can be achieved efficiently and consistently.
The objective should be to strengthen Australia’s national interest while ensuring that regulatory settings continue to support the forms of international engagement that government policy has actively encouraged and that deliver substantial strategic, economic and diplomatic benefits to Australia.
Recommendation: Ensure any extension of the Foreign Arrangements Scheme to offshore campuses is implemented in a proportionate, practical and predictable manner that avoids unintended barriers to international education, research collaboration and transnational partnerships that are demonstrably in Australia’s national interest.
Recommendation: Support implementation through the provision of clear guidance, practical toolkits and other assistance to ensure consistent and efficient compliance across the sector.
Conclusion
The Go8 supports reforms that strengthen Australia’s national interest and enhance confidence in Australia’s foreign engagement framework.
The central challenge is not whether Australia should protect its national interests – we must and we do.
The challenge is ensuring Australia remains an attractive and trusted partner for international collaboration in research, innovation and education.
The test for the Committee is whether the amended Scheme sharpens Australia’s focus on genuine risk while preserving the international engagement that underpins research excellence, sovereign capability, economic resilience and global influence.
Australia’s ability to remain both secure and globally connected will be a defining source of national strength in the decades ahead. The Foreign Arrangements Scheme should support both objectives.
[1] https://www.asio.gov.au/resources/speeches-and-statements/director-generals-annual-threat-assessment-2026
[2] https://research-and-innovation.ec.europa.eu/news/all-research-and-innovation-news/eu-and-australia-formally-open-negotiations-association-horizon-europe-2026-03-31_en
[3] https://jasonclare.com.au/media/portfolio-media-releases/australia-india-education-and-skills-council-meeting-and-release-of-australia-india-education-strategy/
[4] https://www.teqsa.gov.au/sites/default/files/2023-07/TNE-toolkit.pdf
