Benchmarking is a formalised evaluation process by which a university can measure the standard of their policies, processes, programmes or strategies through comparison with other universities. Currently, there is a paucity of research that focuses on the documentation associated with external benchmarking undertaken by Australian universities. Given that Australia's higher education regulatory body requires universities to reflect the purposes of external benchmarking within policy frameworks and for external referencing to be overseen by peak academic governance bodies such limited research is of significance. This paper contributes to the literature by investigating whether documented structures, policies and guidelines are in place to inform learning and teaching external referencing processes. Using a qualitative documentary thematic analysis, policies, procedures and guidelines found on university governance websites were investigated and analysed. The findings indicate that many Australian universities are at risk of not meeting mandatory regulatory requirements.