The implications of ASQA being moving to a full cost recovery agency

September 30, 2019

ASQA and TEQSA are required by the Australian Government to transition from partial cost recovery to full cost recovery by 2020-21 making charging activities more consistent with the  other areas of Government and Australian Government Charging Framework. 


Currently, neither regulator recovers the full cost of their regulatory operation or the full cost of legislative activities. The regulators recover only the costs of regulatory activity for outputs that are initiated/requested by the providers and not costs associated with compliance, monitoring, enforcement, and investigations. Under these updated provisions that will change.




In December 2009, the Council of Australian Governments (COAG) agreed to ASQA’s establishment as a cost recovery agency, and announced that ASQA would over a period of years move from partial to full cost recovery. On 1 July 2011 ASQA was established by the enactment of the NVR Act and supplementary legislation. In the 2014–15 Portfolio Additional Estimates Statements, the Australian Government confirmed ASQA’s continued operation as a partial cost recovery entity.


The Australian Government Budget 2018–19 announced that ASQA will transition from partial cost recovery to full cost recovery by 2020–21.


During the transition to full cost recovery by 2020–21, ASQA will engage in public consultation with all VET sector stakeholders before any changes are made to ASQA’S fees and charges. ASQA will detail any proposed changes, the rationale and anticipated cost-recovery outcomes of the proposal, and provide all stakeholders with the opportunity to provide input and feedback. ASQA will allow adequate time not only for this consultation to take place, but also for reconsideration and revision of the proposal based on stakeholder input received during the consultation.


Public consultation on ASQA’s fees and charges for 2018–19 took place from 1 August to 3 September 2017. For more information on this consultation process, see section 5—Stakeholder engagement.


ASQA recovers costs by imposing fees and charges on providers for various tasks ASQA performs as part of regulating the VET sector. ASQA receives budget appropriations from the Australian Government, and cost recovery revenue is returned to the Australian Government’s Consolidated Revenue Fund to offset budget funding


ASQA’s collection of fees and charges 



ASQA’s authority to impose fees is provided in section 232 of the NVR Act.



ASQA’s authority to impose charges is provided in sections 7–12 of the National Vocational Education and Training Regulator (Charges) Act 2012 (the Charges Act).


ASQA mainly imposes and collects fees and charges on three key groups:


  • Registered Training Organisations (RTOs)

  • Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) providers—including those that deliver English Language Intensive Courses for Overseas Students (ELICOS)

  • VET accredited course owners.


ASQA’s business activities 


ASQA is required to support all its business activities and operations under the full recovery model. The business activities and operations include: 



ASQA’s partial cost recovery model 


ASQA currently receives an annual budget appropriation for operating and capital activities from the Australian Government and returns cost recovery revenue to the Consolidated Revenue Fund to offset their budget funding. The cost of some of ASQA’s regulatory activity is partially recovered through fees and charges. Some of ASQA’s regulatory activity is funded by ASQA’s annual budget appropriation.  




Let's now look into how the proposed changes are going to affect your training organisation or its operations. 


A revised fees and charges model came into effect from 6 July 2018: 


  • reduce many fees and charges from the current rates, reflecting efficiencies realised through ASQA’s upgraded business systems and improved processes

  • provide cost reductions for providers that demonstrate high levels of compliance with their regulatory obligations , including the requirements of the VET Quality Framework

  • only impose assessment fees in certain cases (for example, when a registered training organisation seeks to renew its registration, charges for the additional cost of assessment will only be imposed on those providers that require an audit)

  • align with ASQA’s risk-based approach to regulation, so that providers that require a greater level of regulatory attention and oversight are more likely to pay higher costs for their regulation.


Changes to fees and charges for RTOs include:


  • decreases in initial, renewal and change-of-scope application lodgement fees

  • a shift from assessments of all applications (with costs shared across all providers) to an approach where costs are charged at the point of audit (meaning that for renewal and change- of-scope applications, charges for the additional cost of assessment will only be imposed on those providers that require an audit).


CRICOS changes include:


  • decreases in initial and renewal application lodgement fees

  • a decrease in the change-of-scope application fee. Course accreditation changes include:

  • replacing the single application fee with a lodgement fee and an assessment fee (so that ASQA’s initial costs are recovered, and applicants whose applications are of insufficient quality to proceed to the assessment stage are only charged for the cost of lodgement)

  • replacing the single amendment fee with different fees for ‘minor’ and ‘major’ amendments, which results in a lower cost to providers who make minor amendments.


Annual registration changes include:


  • replacing the annual fee with an annual registration charge to ensure consistency with the Australian Government Charging Framework (noting the amount and structure is unchanged, and that there will be no financial impact on providers, course owners or ASQA due to this change).


Averaging the application lodgement fee for initial, assessment, renewal and change-of-scope provides simplicity, consistency and efficiency.


Does this mean all providers will pay more?