The colleges are the least examined body in this chain and the only one that is not a government agency. They are private membership organisations performing a function with the force of law: without a favourable college assessment, specialist registration is not available, and the Medical Board does not substitute its own view.

Three structural features follow, and none of them is an accusation against any college.

1. They are not subject to the accountability that applies to a regulator. Assessment timeframes are not published as regulatory performance data, are not audited by an auditor-general, and are not governed by a statutory clock. This database therefore cannot state a sourced duration for the step. That absence is itself the finding, and it is recorded on the companion project as the kind of gap that has to be closed before the step can be argued about honestly.
2. They charge a cost-recovery fee before the outcome is known. The RACP assessment of comparability fee was published at $6,184 for 2026.
3. They have an interest in the supply of practitioners in their specialty. That is the standard objection, it is structurally real, and it is not by itself evidence of anything -- the colleges are also the only bodies holding the clinical expertise to make the assessment at all.

The Expedited Specialist pathway matters mainly because it is the first route to specialist registration that does not pass through this step. It is, in effect, a controlled experiment in whether the step is load-bearing, and it will produce an answer within a few years. That answer should be collected.