UA members remain committed to supporting good-practice governance including adherence to the Higher Education Threshold Standards as self-accrediting organisations, and continuing self-assurance for the effectiveness and suitability of mechanisms and processes concerning grievances and complaints. Despite this, UA cannot support the proposed Statement as currently drafted. The Statement does not complement existing measures and is seemingly based on a misunderstanding of the reality of the grievance and complaint context in the sector.

UA recommends that TEQSA

• not proceed with the Interim Statement of Regulatory Expectations and,
• consider alternate approaches more aligned with TEQSA’s functions and powers and risk-based approaches, such as the provision of Guidance Principles.