There is a wide range of activity taking place under the banner of 'co-created curriculum' within higher education. Some of this variety is due to the different ways people think about 'co-creation', but significant variation is also due to the ways in which higher education curriculum is conceptualised, and how these conceptualisations position the student in relation to the curriculum. In addition, little attention is paid to the differences between co-creation "of" the curriculum and co-creation "in" the curriculum. This paper addresses this gap by examining four theoretical frameworks used to inform higher education curriculum design. We examine how each framework considers the position of the learner and how this might influence the kinds of curricular co-creation likely to be enacted. We conclude by calling for more discussion of curriculum and curriculum theories in higher education--and for these discussions to include students. We argue that more clarity is needed from scholars and practitioners as to how they are defining curriculum, and whether they are focused on co-creation "of" the curriculum or co-creation "in" the curriculum. Finally, we suggest that paying greater attention to curriculum theories and their assumptions about the learner, offers enhanced understanding of curricular intentions and the extent to which collaboration is possible within any particular context.