Submission To Consultation – Statement of Regulatory Expectations:
Adopting a Definition of Antisemitism
A response to the Tertiary Education Quality and Standards Agency’s (TEQSA)
September 2026 consultation paper.
The Australia Palestine Advocacy Network (APAN) welcomes the opportunity to respond to this consultation. We focus our comments on the “Definition of antisemitism” and “Governance and accountability” sections of TEQSA’s draft Statement of Regulatory Expectations (SRE).
TEQSA’s draft Statement of Regulatory Expectations asks providers to assess candidate definitions of antisemitism against specific quality criteria: whether a definition is conduct-focused, directed to equal participation and safety, legally compatible, operationally usable, and accompanied by safeguards for academic freedom, lawful expression, procedural fairness and viewpoint neutrality.
We submit that the definitions most tertiary educational institutions are being pushed toward Universities Australia (UA) and International Holocaust Remembrance Alliance (IHRA) definitions of antisemitism – are divisive, destructive to academic and intellectual freedom, promote anti-Palestinian racism against Palestinians and our allies, and likely to worsen antisemitism. These definitions also fail several of the specific quality criteria noted above, as evidenced before Australian courts, formal legal opinions, and assessments of the United Nations and major human rights organisations.
We propose an alternative and more reliable approach to addressing anti-racism, built on the Australian Human Rights Commissions’ National Anti-Racism Framework, that would satisfy TEQSA’s own criteria. The National Anti-Racism Framework provides a roadmap for governments, business and community organisations to address all forms of racism in Australia, with 63 recommendations for a whole of society approach to address racism, proposing reforms across seven sectors, including the education sector.
To read the submission in full, please download the PDF.