Go8 submission to the Select Committee on Productivity in Australia

February 20, 2026

Senator Andrew Bragg, Chair of Select Committee on Productivity in Australia, Parliament House, Canberra ACT 2600

Introduction

Productivity growth is the fundamental driver of Australia’s long-term economic growth and prosperity. Since Federation, growth in living standards has overwhelmingly been underpinned by improvements in labour productivity. Around two-thirds of these gains have come from multifactor productivity (MFP) growth, with the remainder driven by capital-deepening (a rise in the capital to labour ratio).^[1]

Without sustained productivity growth, Australia risks a gradual erosion of living standards and global competitiveness. Weak productivity growth constrains the resources available to invest in critical national priorities such as healthcare, climate action, and defence. It also translates into lower real wages and fewer high quality, secure jobs.

Australia’s recent performance is a clear warning sign. Labour productivity growth is now at its lowest in 60 years, averaging just 0.4 per cent per year between 2015 and 2024 – one quarter of the long-term historical average of 1.6 per cent. ^[2] MFP growth has also weakened markedly since the late 1990s, reflecting lower returns from technology adoption and diffusion. In 2024-25 both labour and MFP growth declined.   

Productivity is fundamentally about working smarter – producing more, and higher – quality goods and services with the same or fewer resources. Working smarter depends on the creation, diffusion and application of knowledge, including through research and development (R&D), and on a highly skilled workforce capable of turning ideas into impact.

Australia’s universities  –  and particularly the Group of Eight – are therefore central to the national  productivity challenge. As Australia’s leading research-intensive universities, the Go8 play a unique role in knowledge creation, advanced skills formation, and the translation of research into economic and social benefit.

Each year, Go8 universities collectively invest around $10 billion in research, accounting for approximately 20 per cent of Australia’s total R&D investment. This scale of investment underscores the central roleGo8 universities play in Australia’s innovation system.

Without sustained knowledge creation and dissemination through universities, Australia’s productivity

performance would be significantly weaker, and the nation would fall further behind leading advanced economies in both living standards and competitiveness. As the Strategic Examination of Research and Development (SERD) aptly put it:

“Boosting a focus on R&D will prevent Australia’s slide into mediocrity”.^[3]

The Go8 also underpin the productivity of Australia’s workforce. Each year, Go8 universities educate around half a million students, including more than 32,000 research students, and graduate approximately 135,000 students. The Go8 accounts for over half of all PhD completions nationally. Go8 universities educate 60 per cent of Australia’s doctors, dentists, and vets, more than half of all science graduates and over 40 per cent of engineering graduates.

Despite this contribution, there are clear constraints on the ability of Australian universities to do more. These include the unsustainable funding of university research and the growing regulatory burden on the sector, both of which are addressed in this submission.  

Go8 recommendations ^[4]

The key reasons the Go8 focuses on lifting investment in R&D and addressing the regulatory burden are as follows:

Investment in R&D strengthens the capital base of the economy, which is critical for productivity growth because productivity growth depends on the ratio of capital to labour (‘capital deepening’). Yet Australia’s national R&D investment remains at just 1.7 per cent of GDP, a full percentage point below the OECD average.

• R&D differs fundamentally from physical capital and labour, which are subject to diminishing returns. Many forms of R&D – particularly basic and foundational research – generate knowledge that can be widely reused and built upon, supporting increasing returns to scale and making R&D central to long term productivity growth.
• Regulatory burden inhibits productivity growth by constraining investment, entrepreneurship, and risk appetite. The regulatory burden in Australia is rising. A recent estimate has the cost to Australian businesses of regulatory compliance with Commonwealth regulations at around $160 billion per year, or 5.8 per cent of GDP, up from 4.2 per cent a decade ago.^[5] Australian universities are not immune to this growing burden.
• Addressing regulatory burden is therefore essential to restoring economic dynamism, including through revitalised regulatory reform in services sectors such as higher education, where unnecessary and duplicative regulation diverts resources away from productivity‑enhancing activity.

Attachment A to this submission provides further discussion of the rationale for our recommendations.

Attachment B to this submission provides examples of areas of regulatory burden impacting Go8 universities.

Conclusion

The evidence is unequivocal. Australia’s labour productivity growth has fallen to a quarter of its long‑term historical average. National R&D investment remains a full percentage point below the OECD average. The cost of Commonwealth regulatory compliance alone has risen to around 5.8 per cent of GDP.

Reversing Australia’s weak productivity performance requires decisive, coordinated action. Central to this is lifting national investment in R&D to boost innovation and productivity. Building on the Strategic Examination of Research and Development (SERD), Australia needs a clear national R&D and innovation strategy with a goal of lifting total R&D investment from 1.7 per cent of GDP towards 3 per cent of GDP.

This target is not a target for government spending alone. It reflects the scale of total investment required across the economy – particularly revitalising business sector R&D and innovation – to restore productivity growth.

The strategy must also address long‑standing weaknesses in the sustainability of university research funding, including by moving towards coverage of the full economic costs of publicly funded research, and by enabling Australian participation in global research ecosystems such as Horizon Europe.

At the same time, Australia must confront the growing regulatory burden that is constraining investment, entrepreneurship and productivity. For universities, unnecessary and duplicative regulation diverts scarce resources away from research and education – the very activities that underpin long‑term productivity growth.

The Go8 supports the renewed regulatory reform agenda currently underway, but more is required. This should include an economy‑wide regulatory stocktake, encompassing the university sector, with a clear commitment to reducing regulatory costs by 25 per cent by 2030. Similar reforms should be pursued by States and Territories through National Cabinet.

We are not advocating deregulation. We are calling for smart, efficient and risk‑based regulation – regulation that addresses genuine market failures without imposing unnecessary costs on productivity‑enhancing activity.

The Go8 would welcome the opportunity to discuss this submission further with the Select Committee on Productivity in Australia.

Attachment A: Discussion

The problem of weak productivity growth

The OECD has recently observed that Australia’s trend rate of productivity growth is modest, both relative to its  historical performance and compared with many international peers.^[6]  Chart 1 illustrates Australia’s widening  shortfall in labour productivity (GDP per hour worked) relative to the United States – widely regarded as a global productivity leader – after adjusting for exchange rates and relative inflation.

In 2000 Australia’s labour productivity level stood at around 92 per cent of the United States’ level. By 2023 this had fallen to approximately 82 per cent.  

Chart 1: Real GDP per hour worked (US dollars per hour, PPP converted, constant prices)

Source: OECD Productivity Database

As a nation, we must not accept sluggish productivity growth as the norm. Economic growth is driven by the “three Ps”:  productivity, population, and participation. However, labour utilisation in Australia is already high, and both population growth and participation are projected to slow down in coming years – at the same time that productivity growth has stalled.^[7] In short, Australia cannot rely on population and participation gains to offset weak and unsustained productivity growth.

Drivers of the productivity slowdown

The Productivity Commission, Treasury, and Reserve Bank of Australia (RBA) note that the slowdown in labour productivity growth, also seen globally, likely reflects a combination of interrelated factors, including:

• diminishing gains from technology and slower diffusion of new technologies
• weaker investment, resulting in reduced capital deepening (the ratio of capital to labour)
• declining economic dynamism and competition, alongside a slowdown in economic policy reform
• structural shifts in the economy towards non‑market and service sectors, which typically exhibit lower measured productivity
• gaps in human capital accumulation
• potential mismeasurement of productivity, particularly in non‑market sectors

Both of the focus areas recommended by the Go8 directly address the causal factors identified by the Productivity Commission, Treasury and the RBA. Increased investment in R&D, for example, supports capital deepening, technological advancement and diffusion, and economic dynamism. Similarly, reducing regulatory burden is central to lifting economic dynamism and advancing a renewed agenda of regulatory reform.

Lifting investment in R&D to boost innovation and productivity

The benefits of sustained productivity growth can be realised by increasing Australia’s R&D intensity and innovation performance (Chart 2). In practical terms, R&D investment strengthens innovation and productivity capacity through several channels:

• enabling businesses to leverage external knowledge to improve efficiency and competitiveness
• amplifying knowledge spillovers, thereby increasing the likelihood of breakthrough innovations
• fostering cross‑sector collaboration and creating new pathways for shared problem‑solving and innovation

The transformative impact of research is evident in technologies now taken for granted, such as magnetic resonance imaging (MRI), the internet and smartphones. Each emerged from decades of foundational research in disciplines including physics, mathematics and computer science. From this accumulated stock of knowledge flow practical solutions, innovative products and the creation of new and growing industries

Chart 2: Research and development as an enabler of productivity and its benefits

Source: Go8. 2025. Go8 Dialogue Report: Leveraging Research and Innovation to Turbocharge Productivity, October.

Empirical evidence for Australia reinforces the case for increased R&D investment:

• Research by Elnasri & Fox shows that a 1 per cent increase in public funding for higher education R&D boosts multifactor productivity by 0.175 per cent.^[8]
• A study by London Economics for the Go8 found that every $1 billion invested in Go8 university research generates $9.2 billion in additional economic output across the broader economy.^[9]
• The CSIRO estimates that $1 of R&D investment yields $3.50 in economy-wide benefits, with an average annual return of 10 per cent.^[10]
• Sector-specific studies reveal that public investment in agricultural R&D has delivered internal rates of return as high as 28 per cent, rivalling the impact of foreign R&D on Australia’s agricultural productivity.^[11]

However, the most recent SERD highlights that Australia is falling behind comparable OECD economies in R&D investment. National R&D expenditure stands at around 1.7 per cent of GDP, well below the OECD average of approximately 2.7 per cent of GDP.

The SERD also notes that while Australia’s performance in ‘foundational’ or basic research—an area of particular strength for Australian universities—is world‑class, too little of this knowledge is translated domestically into new products and services by emerging, innovation‑based businesses.

In our view, both knowledge creation and its translation into commercial products and services are equally critical to innovation and productivity growth. Accordingly, our recommendations are designed to strengthen not only R&D investment itself, but also the pathways that support its effective translation into economic and societal outcomes.

The need for a national R&D and innovation strategy

Australia requires a clear national strategy to realise the full economic benefits of research and innovation. Developing a comprehensive national R&D and innovation strategy is therefore critical. A central objective should be to lift national investment in R&D from its current level of around 1.7 per cent of GDP towards 3 per cent of GDP over time.

The bulk of this additional investment will need to come from the business sector. While businesses account for more than 50 per cent of national R&D investment (with Go8 universities contributing around 20 per cent), business R&D intensity has declined markedly – from 1.37 per cent of GDP in 2009 to around 0.90 per cent of GDP more recently.

To support a coherent, whole‑of‑government approach, Australia should establish a single National Agency for Research and Innovation to oversee research and innovation policy and funding. The agency would operate as a ‘one‑stop shop’ for research funding, consolidating smaller programs rather than adding new layers of bureaucracy. It would oversee major funding bodies, including the ARC, NHMRC and MRFF, and have responsibility for implementing the national R&D and innovation investment strategy.

Targeted incentives are also needed to lift business investment in R&D, particularly among small and medium‑sized enterprises. This should include a coordinated mix of measures drawing on the R&D Tax Incentive, the National Reconstruction Fund, and government procurement budgets. These mechanisms can be deployed through new and existing programs, such as a Small Business Technology Transfer Program and the Trailblazers University Program.

We should incentivise growth in business investment in R&D, especially by SMEs, using a mix of incentives leveraging the R&DTI, the National Reconstruction Fund, and government agency procurement budgets. The latter can be done through new and continuing existing programs, such as a Small Business Technology Transfer Program and the Trailblazers University Program.

A Small Business Technology Transfer Program, modelled on the successful US scheme, would enable the Australian Government to provide grants allowing small businesses to partner with universities to translate early‑stage concepts into commercially viable products or services. Funding would be drawn from government agencies’ procurement and R&D budgets, with procurement‑based funding supporting the development of solutions to clearly defined government needs.

Finally, Australia should strengthen industry-university commercialisation pathways, including by facilitating greater investment in early‑stage ventures by superannuation funds and venture capital. Australia has ample capital; what is now required are the mechanisms, incentives and confidence to deploy it effectively—into the ideas, ventures and technologies that will shape future productivity and economic growth.

Recent analysis, including the Strategic Examination of Research and Development (SERD), identifies a number of barriers to greater investment in innovation-driven ventures:

• Regulatory constraints, such as the superannuation performance test and fee disclosure rules, discourage long-term, high-impact investment.
• Liquidity and risk management requirements make it harder for funds to invest in early-stage ventures.
• Challenges around valuation, transparency, and market timing further limit participation.

Addressing these constraints will require modernising superannuation regulation to better support innovation. In particular, the superannuation performance test administered by the Australian Prudential Regulation Authority should be updated to better accommodate long‑term, high‑impact investment in Australian research,

development and innovation, including university‑led ventures.

In addition, the Australian Securities & Investments Commission’s Regulatory Guide 97 on fee and cost disclosure should be reformed to remove disincentives for venture capital and private equity investment.^[12]

As outlined in previous Go8 submissions, including to the SERD, Australia cannot go it alone. Integration with globally leading research and industrial partnerships is essential. In this context, Australia should seek associate membership of the European Union’s $170 billion research and innovation program, Horizon Europe.

Australia’s current limited access to Horizon Europe has resulted in missed opportunities, stalled collaborations, and unrealised impact – issues demonstrated in multiple Go8 case studies. Associate membership would remove these barriers and ensure Australian researchers and businesses can operate at full capacity within one of the world’s most substantial research ecosystems.

For Australian university research we also need sustainability of funding rather than overly rely on cross subsidies, including from international student revenue. This must involve commencing the process of government funders covering the full economic costs (FEC) of research by:

• Establishing a robust and transparent costing model for university research.
• Transitioning toward FEC coverage for publicly funded university research grants to reduce the reliance on discretionary income, particularly international student revenue.

Addressing growing regulatory burden

Compliance with federal regulation now imposes a significant and growing cost on the Australian economy. In 2024, the cost of compliance with Commonwealth regulation was estimated at $160 billion, or around 5.8 per cent of GDP – up from $65 billion, or 4.2 per cent of GDP, in 2013 .^[13] These estimates do not capture the additional costs associated with state and local government legislation, nor the substantial compliance burden arising from contractual research funding obligations faced by research‑intensive universities.

Australian universities are among the most highly regulated sectors of the economy. Regulatory requirements span multiple levels of government and a wide range of regulatory bodies, covering areas including education quality and student experience; research; national security and foreign interference; financial sustainability; health, wellbeing and safety; governance; operations; culture and conduct; and consumer protection.

The regulatory burden facing universities is driven primarily by government approaches to regulation and compliance reporting. It has been compounded over time by regulatory duplication, as new requirements are introduced incrementally to address specific issues without sufficient consideration of the existing regulatory framework or the broader regulatory landscape. As a result, regulatory burden has continued to grow despite repeated commitments by successive governments to reduce it.

For universities such as the Go8, this burden diverts resources away from their most productive uses—teaching, delivering a high‑quality student experience, and undertaking world‑leading research and development.

As the Assistant Minister for Productivity, Competition, Charities and Treasury, the Hon Dr Andrew Leigh, recently noted:

“Many academics now report spending more time managing approvals than pursuing the work that attracted them to research in the first place. More time on grant administration than on experiments. More time on paperwork than on partnerships. Processes intended to ensure integrity and accountability can, in practice, frustrate innovation and collaboration.”^[14]

The scale and complexity of the regulatory framework governing universities is substantial.

Key elements include:

• The Tertiary Education Quality and Standards Agency Act 2011 (TEQSA Act), which establishes TEQSA as the national regulator for higher education providers. TEQSA is responsible for provider registration, course accreditation, re‑registration, and monitoring compliance with the Higher Education Standards Framework 2021 (Cth) and the Australian Qualifications Framework (AQF).
• The Higher Education Standards Framework 2021 (Cth) (HESF), which sets threshold standards across seven domains and with which ongoing compliance is a mandatory condition of registration.
• The Australian Qualifications Framework (AQF), the national policy for regulated qualifications, jointly developed by Commonwealth, state and territory governments and administered by the Commonwealth Department of Education.
• The Higher Education Support Act 2003 (Cth) (HESA), which governs higher education funding and student support arrangements, including Commonwealth Supported Places, student loans, accountability requirements, and extensive data reporting, audit and certification obligations.
• The Education Services for Overseas Students Act 2000 (ESOS Act), which establishes the framework for education provided to international students, including CRICOS registration and consumer protection requirements. For universities, TEQSA also acts as the ESOS regulator and oversees CRICOS registration and renewal.
• The National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code), established under the ESOS Act, which sets mandatory and highly prescriptive standards covering all aspects of service delivery to international students.

Each of these frameworks carries distinct reporting and compliance obligations, many of which overlap. Notably, the ESOS Act and National Code pre‑date the introduction of the current risk‑based national regulatory framework for universities in 2011. As a result, there is significant duplication across the National Code, the HESF and HESA guidelines in areas such as student recruitment and admissions, academic progress monitoring, student support, complaints and grievances, and consumer protection.

Consistent with recommendations first made in the Bradley Review, renewed consideration should be given to integrating the ESOS Act and National Code with the HESF and TEQSA framework. Such reform would reduce regulatory duplication while ensuring a consistent, high‑quality student experience for both domestic and international students, underpinned by common threshold standards for course delivery, student safety and support services.

More recently, universities have also been required to submit additional standalone annual reports to the Department of Education on matters such as student support policies and gender‑based violence. Multiple reporting requirements across different authorities and student cohorts further compound the compliance burden.

By way of illustration, the University of Sydney’s legislative compliance register identifies 331 legislative instruments and associated documents, with 157 imposing significant compliance obligations – representing a 10 per cent increase over the past two years. Owing to the breadth and complexity of its research activities, the University of Sydney engages with more than 95 regulatory bodies and estimates that time spent on regulatory compliance has increased by between 20 and 25 per cent over the past decade.

Australian Tertiary Education Commission (ATEC)

The higher education sector is also facing heightened regulatory uncertainty in relation to the proposed Australian Tertiary Education Commission (ATEC). While legislative development is ongoing and final arrangements remain unresolved, it is clear that ATEC will have the authority to establish enforceable compacts with universities covering both domestic and international student enrolments.

However, significant uncertainty remains regarding the scope of these compacts, their implications for university operations, enforcement mechanisms, and their potential interaction with the existing regulatory role of TEQSA.

The Government is also considering incorporating recommendations from the Expert Council on university governance and the Senate inquiry into higher education governance into the Threshold Standards used by regulators. Such changes would materially alter the accountability framework against which universities are assessed.

Any revision to the Threshold Standards necessarily requires the involvement of the Higher Education Standards Panel. However, the ATEC legislation currently before Parliament proposes to disband this panel, without providing clear assurances regarding transparency, governance or stakeholder engagement within the proposed new framework.

Compression of the lead‑time period between passage of legislation and its operative effect

A further challenge facing universities is the shortening of lead times between the passage of legislation and its commencement. Compressed implementation timeframes concentrate administrative effort into short periods and undermine sustainable planning, budget forecasting and the orderly implementation of systems and processes required to meet new obligations.

Recent examples of this include:

• The Higher Education Support Amendment (Response to the Australian Universities Accord Interim Report) Act 2023 (Cth) was assented to on 6 November 2023. It amended HESA to require universities to have a prescriptive student support policy implemented by 1 January 2024. It also introduced reporting requirements direct to the Department of Education. This is despite the HESF and National Code overseen by TEQSA both containing prescriptive thresholds for student support.
• The Universities Accord (Student Support and Other Measures) Act 2024 (Cth) amended HESA and four other Acts. It required changes to finance and student systems as well as amendments to student facing information collateral. It was assented to on December 5, 2024, with many provisions commencing on 1 January 2025.
• The Universities Accord (National Student Ombudsman) Act 2024 (Cth) amended the Ombudsman Act 1976 (Cth) to establish the National Student Ombudsman as a new statutory function of the Commonwealth Ombudsman as an escalated complaints-handling mechanism for students who have already complained to their university about a range of issues and are unsatisfied with the response. It required system-generated correspondence templates to be updated, staff training and student facing information collateral to be updated. The Act was assented to on 10 December 2024 and commenced on 1 February 2025. 

Even where adequate lead time is provided and the policy rationale is sound, the cost of implementation is often substantial and insufficiently considered during regulatory design.

By way of example, Deloitte Access Economics was commissioned by the Department of Education to undertake a cost–benefit and regulatory burden analysis for the National Higher Education Code to Prevent and Respond to Gender‑Based Violence, overseen by a dedicated regulator within the Department of Education. Deloitte estimated total implementation costs of $1.2 billion over ten years, with approximately 90 per cent of costs borne by providers. For large providers, ongoing annual implementation costs from 2026 were estimated at $8.1 million. While the analysis identified total benefits of $3.5 billion over the same period – yielding a net benefit of $2.3 billion – the scale of the costs imposed on providers underscores the need for these impacts to be explicitly recognised and factored into policy and regulatory design.^[15]

In summary, the Go8 has consistently urged successive governments to address the cumulative and growing regulatory burden facing the university sector. Our 2022 report, Essential decisions for national success reducing the regulatory overload on our universities, remains highly relevant and provides a comprehensive assessment of the deadweight costs imposed by regulatory overload on Australia’s leading research‑intensive universities. Further examples of regulatory burden affecting Go8 universities are outlined in Attachment B to this submission.

Attachment B: Examples of regulatory compliance burden on Go8 universities

The following provides examples of areas of regulatory compliance and burden on Go8 universities. We reiterate that we are not proposing complete deregulation – we need ‘smart’ regulatory systems: efficient regulations and associated regulators that address clear market failures without imposing unnecessary costs by taking a risk-based approach. We need regulatory systems which can “talk’ to one another facilitate the use of data reported to be used across regulatory frameworks.

1. Health and Medical Research funding

Consider the regulatory burden on researchers in Health and Medical Research. The National Health and Medical Research Council lists 18 categories of laws, approval requirements and obligations that must be complied with or that universities must “be aware of” (see list below).

These cut across complex areas of law as broad as national security, clinical trials, privacy, child safety, intellectual property, therapeutic goods, gene technology, human embryonic research, and safety as well as international law– to name just a few.

The list does not include the National Code for the responsible conduct of research – on a list of 13 approved standards and guidelines as well as requirements by the Department of Education, Department of Health, Disability and Ageing, Tertiary Education Quality and Standards Agency and potentially the Australian Tertiary Education Commission in its substantive form. Researchers also have to go through internal institutional processes such as ethics approval.

All of this before researchers actually submit the grant application and go through the rigorous peer review assessment process.

The 18 categories of laws, approval requirements, and obligations that must be complied with include:

• Foreign interference in Australian research.
• The National Principles for Child Safe Organisations.
• National Redress Scheme Grant Connected Policy.
• Registration of clinical trials.
• Research involving humans.
• Use of personal information in research without consent.
• Research involving human embryos.
• Research involving animals.
• Research involving genetically modified organisms.
• Use of carcinogenic or highly toxic chemicals.
• Use of datasets for research purposes.
• Therapeutic Goods Act 1989 (Cth).
• Nagoya Protocol on access and benefits-sharing(a legally binding framework to access to genetic resources located outside Australia).
• Defence Trade Controls Act 2012 (Cth).
• Intellectual Property.
• Foreign Arrangements Scheme.
• Commonwealth Grants Rules and Principles 2024.
• Commonwealth Fraud and Corruption Control Framework 2024.

2. Foreign interference

Australian universities are subject to multiple laws and regulations addressing foreign interference, including: the Foreign Influence Transparency Scheme (FITS, 2018) and the Foreign Arrangements Scheme (FAS, 2020). FITS aimed to counter foreign influence, while FAS ensures foreign arrangements align with Australia’s foreign policy.

Both were expected to capture Confucius Institutes, yet:

• Legal advice across the sector found they were not covered by FITS, so none were registered.
• No Confucius Institute has been cancelled under FAS.

FAS compliance has required substantial university resources. As of 18 August 2025:

• 11,320 arrangements are on the FAS Public Register.
• 82 per cent (9,373) involve universities.
• Only four determinations have been made, all involving universities as secondary partners to state departments.

A 2024 Parliamentary Joint Committee on Intelligence and Security (PJCIS) review of the FITS Act found that it had significant flaws and recommended substantial reform was required; and that (Recommendation 10):

“The Committee recommends that, within three months of any legislative amendments to the Foreign Influence Transparency Scheme Act 2018 resulting from this report coming into effect, the Australian Government establish a working group including the Attorney-General’s Department, the Department of Foreign Affairs and Trade and nominated university and higher education stakeholders to review the application of both the Foreign Influence Transparency Scheme and the Foreign Arrangements Scheme, and identify good practice and options to ease the regulatory burden on the sector in complying with both schemes.”^[16]

Research‑intensive universities have required additional resources to manage the administrative burden associated with the Foreign Arrangements Scheme.

At the University of Sydney, a dedicated team has been established to ensure that arrangements are appropriately reported and that the university remains compliant with the scheme’s requirements. Since its introduction, thousands of proposals have required review. These include arrangements relating to procurement, scholarships, research grants and contracts, gifts, student placements, student exchange and mobility, strategic partnerships, clinical trials, and memoranda of understanding. Despite the careful assessment undertaken to determine whether arrangements required notification, more than 15 per cent of the arrangements submitted were subsequently assessed by the Department of Foreign Affairs and Trade as out of scope. Furthermore, only slightly more than 30 per cent of the arrangements notified are currently listed on the Public Register, and no arrangement has been cancelled.

The Government’s response to the Report of the Review of the Australia’s Foreign Relations (State and Territory Arrangements) Act 2020 (the Review) was tabled in Parliament on 1 September 2025. The response accepts several of the Review’s more practical recommendations, which, if implemented, will reduce the number of arrangements requiring notification. However, a substantial volume of work remains in reviewing arrangements to determine notification requirements, and the regulatory burden imposed by the scheme continues to be significant.

3. Broader research and innovation programs

More generally, research intensive universities such as the Go8 have to navigate a multitude of programs and funding sources for research – research block grants from the Department of Education, competitive grants through the Australian Research Council, the National Health and Medical Research Council, and the Medical Research Future Fund, programs in other Commonwealth departments (such as the Department of Industry, Science and Resources and the Department of Health, Disability and Ageing).

We have pointed out that the Australian Government has over 150 distinct research and innovation programs across 12 portfolios, many of which are open to university researchers, sometimes in collaboration with business and other partners.

These fragmented government programs come with their own regulatory processes – which may include application, compliance reporting, and certification requirements. The sheer number of and potential overlap of programs and associated regulatory requirements need to be addressed.

Our proposal for the establishment of a single National Agency for Research & Innovation will assist by enabling a whole of government approach to managing policy and funding for research and innovation.

4. Teaching related administrative burden – Commonwealth Prac Payment (CPP)

The recent Commonwealth Prac Payment provides financial support to students undertaking mandatory placements in teaching, nursing, midwifery or social work courses. However, it has been criticised as having overly complex implementation.^[17] Universities are bearing the administrative burden associated with aspects of its administration, including in relation to:

• Eligibility assessment and verification.
• Placement data collection, certification and financial and auditing information.
• Some coordination with external providers.
• Student enquiries, information and support.

The Go8 has raised these concerns with the Australian Government – including why a government agency such as Centrelink (part of Services Australia), or the Department of Employment and Workplace Relations – similar to the arrangement for VET students – cannot administer CPP for university students.^[18]

[1] Productivity Commission. 2020. PC Productivity Insights: Australia’s long term productivity experience, Canberra, November.

[2] Productivity Commission. 2025. Growth mindset: how to boost Australia’s productivity, 5 productivity inquiries, Canberra, July.

[3] Strategic Examination of R&D independent expert panel. 2025. Strategic Examination of R&D discussion paper, February.

[4] The recommendations in this submission are central to lifting productivity growth but are not exhaustive of all the pro-productivity related Go8 recommendations recently made to government. Further details of broader productivity related recommendations are discussed in the Go8 submissions to: the Strategic Examination of Research and Development (SERD); Economic Reform Roundtable; Productivity Commission 5-pillars of productivity inquiry; and Parliamentary Joint Standing Committee on Migration inquiry into the value of skilled migration to Australia. In addition, prior to the SERD, the Go8 published a detailed report and roadmap of policy reforms towards national R&D investment reaching 3 per cent of GDP which also calls for revitalised competition policy, trade openness, and measures to improve human capital accumulation.

[5] Mandala. 2025. $160 billion and counting: the cost of Commonwealth regulatory complexity, Report prepared for the Australian Institute of Company Directors, November.

[6] OECD. 2026. Economic Surveys: Australia 2026, volume 2026/04, January.

[7] Commonwealth of Australia. 2023. Intergenerational Report 2023: Australia’s future to 2063, p. 29.

[8] Elnasri, A., & Fox, K.J. 2017. ‘The contribution of research and innovation to productivity’. Journal of Productivity Analysis, 47, 291–308.

[9] London Economics. 2022. The economic impact of research and innovation: Group of Eight universities. Unpublished.

[10] CSIRO Futures. 2021. Quantifying Australia’s returns to innovation. CSIRO, Canberra.

[11] Sheng, Y., Gray, E.M., & Mullen, J.D. 2010. ‘Public investment in R&D and extension and productivity in Australian broadacre agriculture’, ABARES Conference Paper 10.16a, November.

[12] Australian Investment Council. 2025. Submission to Productivity Commission – Creating a more dynamic and resilient economy inquiry, questionnaire response 77, June.

[13] Mandala. 2025. op. cit.

[14] The Hon Dr Andrew Leigh MP, Assistant Minister for Productivity, Competition, Charities and Treasury. 2025. ‘The abundance agenda for Australia’, Address to the Chifley Research Centre, Melbourne, June.

[15] Deloitte Access Economics. 2025: Cost benefit analysis of the proposed National Higher Education Code to Prevent and Respond to Gender-based Violence. Report prepared for the Commonwealth Department of Education, August.

[16] Parliamentary Joint Committee on Intelligence and Security. 2024. Review of the Foreign Influence Transparency Scheme Act 2018 Report. March.

[17] Andrew Norton. 2025. ‘The Prac Payment that will go to Services Australia and the ATO, as well as students’, June 23. https://andrewnorton.id.au/2025/06/23/the-prac-payment-that-will-go-to-services-australia-and-the-ato-as-well-as students/

[18] Group of Eight Universities. 2024. Submission Universities Accord (Student Support and Other Measures) Bill 2024 Re: Schedule 4 – Commonwealth Practicum Payments (CPP), September.