The existing structure for student visas in the UK provides an important backdrop for these changes. In brief, to sponsor a student visa, a UK university or school must be a registered student sponsor. This entitles the institution to issue a Confirmation of Acceptance for Studies (CAS) which is in turn required for the student’s visa application.

The updated published on 7 April 2026 (“Document 2: Sponsorship Duties”) includes a new section that outlines the responsibilities of sponsor-institutions pertaining to education agents.

The updated rules carry two main implications for sponsor-institutions in their work with agents.

First, agency details must now be included on the Confirmation of Acceptance for Studies (CAS): “Sponsors must record agent details on the CAS where the sponsor has used an agent in the recruitment of the sponsored student.”

Second, sponsors must not only commit to the Agent Quality Framework (AQF), but be able to demonstrate that compliance: “All student sponsors using recruitment agents must retain evidence of how they are managing agents in line with the AQF and The National Code of Ethical Practice for UK Education Agents, as applicable to the school, further education, pathway and higher education sectors.”

Agency details on the CAS

Related guidance from outlines the agency details that must now be included in the CAS.

This amounts to:

• Agent company name (the formal legal name as used in the agency contract)
• Agent contact name (indicating the primary agent contract contact)
• Agent address (which refers to the specific office or branch from which the student was recruited)

The Home Office indicates otherwise that this provision applies to all cases in which the sponsoring institution was engaged with an agent on the student file, “even if this is a one-off recruitment and/or the recruitment was done without a formal ongoing contract with the agent or third party.”

In the event that a sub agent was involved with the file, the CAS must provide details of the primary agent (as opposed to the sub agent).

If an agent or advisor was engaged directly by the student for application support or other advisory, and where “that third party was not used by the sponsor as part of the recruitment process,” the agency details need not be included in the CAS.

Moving beyond voluntary compliance

The 7 April guidance effectively enshrines the Agent Quality Framework (AQF) for sponsor-institutions in the UK, a distinct progression from what has essentially been a voluntary compliance regime to this point.

The Home Office sets out that, “All student sponsors using recruitment agents must have committed to adhering to the key principles of the (AQF).”

Further, sponsors are now required to document how they are managing agents in line with the provisions of the AQF and .

What this will mean in practice is not yet clear, but it does set up a requirement for more structured and systemic reporting as to how a sponsor is in compliance with the AQF and The National Code. In broad terms, the provisions of The National Code extend additional reporting and documentation requirements to agents, along with specific training requirements, including completion of the .

Commenting on the updated guidance on , Avinav Sharma, Executive Director, Global Partnerships at MSM Unify, said:

“For agents and counsellors, the message is equally direct. If you have not completed your UK knowledge training and signed the national code of ethical practice, you are operating without the credentials this framework now demands. Your digital badge and certificate are no longer nice-to-haves. They are proof points that your sponsor partners will need to show UKVI…This is the UK government signalling that the recruitment channel will be held to the same compliance standard as the institutions themselves…Is your agency ready for this level of scrutiny?”

For additional background, please see:

• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “UK’s stiffening compliance regime already having an impact on international student recruitment“
• “How the UK’s Agent Quality Framework will shape the future of agent training“
• “Who decides about quality? Education agents and the question of increased regulation“

The post UK Home Office publishes updated visa sponsor guidance for “agents and third parties” appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

But agent use is rare in the ascending study abroad destination of Japan. The number of international students in the country increased by to 435,200 in 2025, up +8.2% over 2024. The jump was driven by a record number of student commencements, and it means that Japan has already surpassed its target of 400,000 international enrolments by 2033.

This growth inspired ���Ϲ��� to participate in a study on Global Agency Perspectives on Japan. ���Ϲ���’s Martijn van de Veen and Megumi Kawai co-authored the study with Shigetoshi Akamatsu, International Officer at Waseda University, and with Dr Hiroshi Ota, Professor at Hitotsubashi University as a senior advisor. The team gathered survey responses from more than 300 agencies from 68 countries through the first quarter of 2026 and found that 79% of responding agencies have never formally partnered with a Japanese university.

Unlike in the Big Four, there is a murkier understanding in Japan of what agents are and what they can do. Agents are often seen as “brokers” responsible for transactions rather than services – an understanding that would apply to a mere fraction of agents worldwide.

Dr Hiroshi Ota offers an important correction on this point:

“There is a persistent misconception in Japan that agencies are merely ‘brokers.’ In reality, professional, accredited agencies act as highly experienced education consultants that are essential for sustainable growth.”

An “indispensable” asset

A found that 92% of more than 500 colleges and universities surveyed across North America, Australia, and the UK consider agents “indispensable for recruiting international students.”

The Global Agency Perspectives on Japan survey illuminates why this is the case. Of the agents surveyed:

• 97% manage application and admission support;
• 95% provide students with initial counseling and career guidance;
• 92% handle visa and pre-departure briefings (one of the most complex hurdles for students entering Japan);
• 90% actively promote their partner schools and institutions on social media;
• 70% represent their universities at international student fairs.

These are all crucial components of moving prospective international students from awareness to enrolment.

Agents want to work with Japanese partners

The Global Agency Perspectives on Japan survey found great interest among agents to work with Japanese universities (a score of 4.4 out of a possible 5 for “very high” interest).

For Japanese higher education institutions, this strong demand on the part of agents provides potential access to an immediate global footprint that would otherwise take years to build.

When asked what they thought were main barriers that could prevent students from considering study in Japan, the consensus was lack of awareness about what Japan offers. Three-quarters (75%) cited “lack of awareness/brand recognition of Japanese universities,” and the same proportion cited a “perception that programmes are not taught in English.” More than half (52%) pointed to “lack of information and marketing materials from universities.” These three reasons were much more frequently mentioned than other concerns that are less solvable, such as competitiveness from other destinations (38%), limited post-study work opportunities (31%), and difficult visa procedures (29%).

Said one respondent, “The main reason [for not working with Japanese partners] is that we didn’t have enough information about Japanese universities, particularly the selection process for African students.”

“Our focus has previously been on other destination markets, and we are now preparing to expand into Japan,” said another.

Responding agents were also quick to point out Japan’s strengths as a study destination, noting especially Japan’s reputation for technology innovation, the quality of Japanese education, career opportunities for foreign graduates, and the relative affordability of study in Japan.

As one respondent said, “Japan’s biggest advantage isn’t just culture or technology – it’s that Japanese education is directly linked to real job opportunities in high-growth industries.” Another agent added that, “Japan’s single greatest selling point is its unmatched combination of world-class technology and engineering education and extremely affordable study and living costs compared to other top destinations.”

Why Japan is expanding and diversifying its international enrolment

While Japan’s aging population is a significant concern, the crisis facing higher education is even more acute: the number of 18-year-olds has already halved from its 1991 peak of 2.07 million to just 1.06 million in 2024.

With this demographic projected to fall to 0.88 million by 2040, Japan must attract international talent at an unprecedented scale – not just to fill classrooms, but to create a pipeline of skilled graduates who can join the local workforce and support the government’s broader economic goals.

Currently, Japanese universities are heavily reliant on China, Nepal, Vietnam, South Korea, and Myanmar. These five countries contribute nearly 80% of Japan’s international student body. To diversify beyond these markets and to attract top researchers from advanced economies, Japan needs prospective students to understand that there are:

• Many English-taught programmes offered by leading Japanese universities;
• Newly improved Japanese-language supports for foreign students and workers to better integrate them into society and the economy.

This is especially urgent given the increasingly competitive marketplace for international student recruitment and as Japan is now working hard to attract the world’s best students, alongside other top Asian competitors such as China, Malaysia, and South Korea.

For additional background, please see:

• “Japan surpassed its foreign enrolment target of 400,000 in 2025”
• “From the Big Four to the Big Fourteen“
• “Canada and the US are losing international student enrolments to Europe and Asia“
• “Asia ‘consolidating as the leading destination region’ for international students“

The post Study finds strong agent interest in partnering with Japanese universities appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

The guidance includes details of a new red-amber-green (RAG) banding scheme that sets up what could be, as Jim Dickinson wrote on , “a system more punitive than many in the sector were expecting.”

The regulatory background

In order to apply for a student visa for the UK, an international student must first obtain a Confirmation of Acceptance for Studies (CAS) document. Only a sponsor – that is, an educational institution licensed by the Home Office to sponsor international students for visas – may issue a CAS. In effect, the sponsor is vouching for the student-applicant and his/her eligibility to study in the UK.

That sponsor status places a number of obligations on the institution, and particularly that a sponsor must apply for a (BCA) every 12 months.

When UK Visas and Immigration (UKVI) carries out the BCA, it currently assesses the sponsor based on the following thresholds for three “core requirements”:

• a visa refusal rate of less than 10%;
• an enrolment rate of at least 90%; and
• a course completion rate of at least 85%.

The linkage between the three is quite explicit: the institution is expected to carefully evaluate each applicant to determine that they are eligible for admission but also, once admitted, will have a high likelihood of following through to take up their spot in their intended programme of study and then go on to successfully complete that programme. In other words, the university or college’s ability to continue to admit international students rests on its ability to recruit qualified, bona fide students that are committed to their intended programme of study.

Sponsor institutions that fall outside of those benchmarks are subject to a variety of sanctions, the most extreme of which could lead to the revocation of the sponsor license – meaning in effect that the institution could no longer admit foreign students.

The new BCA thresholds

A May 2025 UK government immigration white paper set out a number of new requirements for UK institutions, including more stringent compliance thresholds. Specifically, sponsoring institutions must now maintain:

• a visa refusal rate of less than 5%;
• an enrolment rate of at least 95%; and
• a course completion rate of at least 90%.

The draft guidance from the Home Office indicates that the first two of those new compliance benchmarks will come into effect on 1 June 2026. The course completion threshold will remain at 85% until June 2027, at which point it will rise to 90%.

RAG time

The Home Office guidance sets out that, “A sponsor’s performance against the three metrics composing the BCA will be rated in a Red-Amber-Green (RAG) banding system.”

Essentially, sponsors with a red rating are operating at or below one or more of the BCA requirements. An amber rating indicates that the sponsor is in danger of non-compliance with respect to one or more of the key benchmarks, whereas a green rating means that the institution is more comfortably within the compliance threshold.

The margin for error, however, is notably slim across the key BCA metrics. The following table summarises the band ranges for each requirement.

“Look at the width of the amber band – or rather, the near-total absence of it,” says Wonkhe’s Dickinson. “On refusals it’s a single percentage point. On enrolment it’s a single percentage point. On completion it’s two. The amber band is extremely narrow.” In other words, the distance to travel between green and red is very narrow indeed.

The significance of those very tight thresholds is driven home by another key aspect of the RAG system: there is no overall scoring across metrics; rather, the sponsoring institution’s rating will be based on their lowest-rated BCA requirement.

The Home Office guidance sets out that: “The RAG rating system is not an aggregate. A sponsor’s rating shall be determined by their lowest rated metric, which will take precedence over any other metric’s score. For example, if the sponsor falls into the red category for their refusal rate, yet falls into the green category for both their enrolment and completion rates, they will receive a red RAG rating.”

Against the advice of sector stakeholders, including Universities UK, the Home Office also intends to make sponsor ratings public, indicating that “a sponsor’s RAG rating will be published on the student sponsor register.” This provision will apply to the first BCA assessment cycle after 1 June 2026, meaning that public ratings won’t likely be available for a critical mass of UK higher education institutions until spring or summer 2027.

Recruitment impacts

“We welcome stronger compliance in principle, but the cumulative impact on UK recruitment should not be underestimated,” says Peter Skillen, the Director of Governance, Risk, Assurance, and Compliance at Study Group. “What may appear to be a technical tightening on paper could have a real chilling effect in practice. The government’s white paper proposed raising each BCA metric by five percentage points and introducing a new RAG banding system, but the draft guidance appears to go further in the way that framework is operationalised. With narrow amber bands, a lowest-metric-wins approach, and final warnings that can remain active for five future Basic Compliance Assessments, institutions may become increasingly selective in their recruitment behaviour, particularly in emerging markets. The risk is that the system becomes more draconian and overbearing for institutions, compelling them to carry out ever more stringent compliance checks and absorb growing administrative burdens. The unintended consequence may be a UK system that is less accessible to genuine international students, with some institutions deciding that recruitment from certain countries is no longer viable.”

The new BCA compliance thresholds were first announced almost a year ago in the government white paper in May 2025. In the months since, there have been a number of signals that institutions are both anticipating and responding to a more stringent compliance regime.

There is after all a significant exercise of risk management at the heart of the CAS-sponsor-compliance model as the three key BCA metrics rest a great deal of responsibility for student performance and student outcomes with the institution itself.

“The rationale behind the new RAG scheme is hard to argue with: stronger compliance should help ensure universities issue CAS only to genuine, well‑prepared students, protecting educational standards and the UK’s international reputation,” says Diana Beech, the Assistant Vice-President (Policy & Government Affairs) at City St. George’s, University of London.

However, the scheme’s razor‑thin thresholds and ‘lowest‑metric‑wins’ approach are not without risk. With so little margin for normal variation, even responsible institutions could be pushed into the red – and publishing these ratings will only intensify that pressure. The result may be overly cautious recruitment, fewer opportunities for legitimate students, and a narrowing of global engagement.

Enhanced compliance matters. But it needs a framework that is proportionate, supportive, and avoids penalising compliant institutions for factors they cannot fully control.”

Indeed, some institutions are already responding reducing or suspending recruiting activities in countries that are seen to be associated with higher risk. “Higher risk” in this sense being defined as markets where students are more likely to not follow through on their study plans or to complete their programmes of study – often for reasons relating to academic background, language skills, or financial difficulty.

In July 2025, for example, London Metropolitan University said that it would suspend admissions for Bangladeshi students. Deputy Vice-Chancellor Gary Davies has attributed the decision to high rates of visa refusals for Bangladeshi students in particular, which were putting the university’s compliance at risk.

Earlier this month, the University of Derby said that it too would suspend student recruitment from Pakistan and Bangladesh over concerns that visa refusal rates for applicants from the two countries were simply too high.

Other UK institutions have reportedly – although less publicly – made similar decisions to limit or suspend admissions from specific markets and/or for particular fields of study where there is seen to be undue compliance risk.

On their face, any such moves are extreme measures and regrettable in that they limit opportunities for bona fide students from markets that are seen to have high risk levels attached. But they also perfectly illustrate the dilemma that UK universities now face under the new BCA benchmarks. With such narrow RAG bands – a green rating requires, for example, that universities maintain a visa refusal rate under 4% – an individual university must either take additional steps to more fully qualify prospective students before issuing a CAS or they have to limit (or even suspend) recruitment in markets or channels that are judged to have greater compliance risk.

Needless to say, each of those broad courses of action carries significant additional costs – in terms of real expenses, risk, or foregone opportunities – for institutions, partners, and students alike. In the meantime, the Home Office has indicated that it is actively engaged in discussions across the sector around the draft guidance and that final guidance and details for implementation of the more stringent BCA requirements will be published shortly.

For additional background, please see:

• “UK’s stiffening compliance regime already having an impact on international student recruitment“
• “UK sets out new immigration strategy, will reduce Graduate Route work term to 18 months“
• “UK: International student numbers fall for second year, especially in postgraduate programmes“
• “How the UK’s Agent Quality Framework will shape the future of agent training“
• “Who decides about quality? Education agents and the question of increased regulation“

The post Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Those legislative amendments were explicitly aimed at strengthening integrity and transparency measures across the Australian sector, with the expectation that they would lead to new regulations via updates to Australia’s National Code of Practice for Providers of Education and Training to Overseas Students.

The first of those revisions to the National Code was introduced on 20 January 2026 when new rules were published to effectively ban education providers from offering commissions to education agents when an onshore student transfers to another course/institution that is not mentioned on the student’s visa.

Most recently, a 24 February update from the Australian Skills Quality Authority (ASQA) further expands on the new transparency thresholds for education agents. ASQA is the national regulator for Australia’s vocational education and training (VET) sector, and contains some important updates with respect to provider reporting on the use of education agents as well as the responsibility to disclose conflicts of interest.

The AQSA guidance also reveals that providers will soon be able to access more agent data via Australia’s system (Provider Registration and International Student Management System).

Specifically, AQSA refers to the ESOS Act’s empowerment of the Department of Education to gather data on agent performance, including:

• The number of students admitted to AQSA-accredited providers referred by education agents
• The number of student visa applications made by students supported by an agent, and the number granted or refused for each agency
• Course completion statistics for agent-referred students

AQSA adds that:

“More information about education agents will be made available to providers through PRISMS, in addition to the existing education agent data that is available. Providers will be able to access information about all agents used by all providers, not just the education agents they currently work with.”

That additional detail is understood to include reporting on:

• The number of onshore transfers associated with a given agent
• Information about agent commissions

Ownership disclosures

ASQA requires that regulated providers maintain a list of education agents they are working with, and that those agent relationships must be disclosed in PRISMS and also published on the provider’s website.

The regulator now also explicitly requires that providers notify it of any conflicts of interest arising from agency control or ownership. This amounts to a duty for registered providers to inform ASQA if their institution (or some associate of the provider) assumes a position of ownership or control with respect to an education agency. Similarly, providers must also disclose if an education agent begins to own or control the provider.

Non-compliance, cautions ASQA, is “a strict liability offence,” meaning that the offence is committed even in the absence of fault or criminal intent. Providers are referred to ASQA’s for ownership and control reporting for additional detail.

For additional background, please see:

• “Australia introduces new rules restricting agent commissions for onshore student transfers“
• “Australia passes integrity legislation; sharpens definition of agents and agent commissions“

The post Australia moving to wider sharing of education agent data appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Up to this point, institutions or schools have been able to compensate an education agent at any point during the student’s time in Australia.

Background

The new rule appears in revisions to the National Code of Practice – formally, the – and is part of a package of amendments to the Education Services for Overseas Students Act (ESOS). Those amendments passed in November 2025 and are aimed at closing loopholes in the international sector that had allowed:

• Unethical providers or agents to profit from shady transactions commonly referred to as “course hopping.” This is where a student obtains a visa for one programme and institution, usually a higher-level course, then progresses to an often lower-level programme and institution, sometimes with the intention of working more and studying less.

• Improving the integrity of the international education sector and protecting the interests of genuine students and quality institutions by removing the ability of unscrupulous businesses to continue poor practices.

A briefing from the Department of Education underscores the point:

“This change removes the incentive for unscrupulous education agents to facilitate unnecessary or non-genuine transfers. This change will support sector integrity and ensure that agents and providers are working in the best interests of their students.”

Unpacking the new rules

There are important points to surface about the new onshore agent commission rules:

• As per the November 2025 ESOS amendments, commissions are defined as any monetary or other benefit given on behalf of an institution to an agent in connection with international recruitment. This includes bonuses, service fees, gifts, etc.

• Included in the understanding of agent are “individuals or entities on casual or fixed-term contracts that are engaging in education agent activities would be education agents.”

• The ruling only applies to agents advising students who have not completed courses. It applies to any student who has begun a course/course package for which they have a visa, and it covers withdrawals, government-mandated cancellations of a course, and switching to another course or level without completing the first one. Providers cannot offer or give commissions to agents in these cases.

• However, agents can still receive commissions from providers for above-the-board transfers when students have completed their first course (the one for which they received a visa) and then progress to another qualification (which requires a new visa).

• Onshore students are still permitted to use agents to help them in their study planning and course progression, and agents are still allowed to receive compensation from students. The ruling only applies to provider-to-agent compensation.

• Onshore students are still able to transfer between providers if they wish, if they have completed the first six months of their principal course (or the first six months of their first school course if they are a school student). But providers are not permitted to pay an agent in this circumstance.

Adjustment period for providers

Providers have some time to adjust. A Department of Education Fact Sheet sets out that:

“To give providers time to adjust to the change, the ban will not apply where the relevant overseas student has been accepted for enrolment by a provider on or before 31 March 2026. The student does not need to have commenced study on or before 31 March 2026 for this exception to apply – only acceptance for enrolment is required, i.e. the student becomes an ‘accepted student’ as defined in the ESOS Act. This allows time for providers to adjust their business practices and honour existing contracts with education agents that involve future instalments of commission payments for previously recruited students.”

Illustrative examples

The Fact Sheet also provides a helpful example of student transfers that are not bound by the new rule on agent commissions:

“A student enrols in ELICOS at Provider A and a Bachelor of Laws at Provider B and is granted a student visa for this package of courses. In the final year of the Bachelor of Laws, the student decides to pursue further study, and seeks the help of an education agent to enrol in a Master of Laws course at Provider C after completion of the Bachelor of Laws. Provider C is permitted to pay a commission to the agent, because the course will start after completion of the student’s principal course.”

And the summary also includes an example of when a provider cannot compensate an agent in the case of a packaged course:

“A student is issued a student visa on the basis of two [Confirmations of Enrolment, or CoEs], an ELICOS course at Provider A followed by a Bachelor of Laws at Provider B. Six months into the student’s Bachelor of Laws at Provider B, the student transfers to the same course, a Bachelor of Laws, at Provider C. Provider C cannot pay the student’s agent a commission or this recruitment, as this is not the specified course at the specified provider in the student’s package of courses for which their visa was granted.”

For additional background, please see:

• “Australia passes integrity legislation; sharpens definition of agents and agent commissions”

The post Australia introduces new rules restricting agent commissions for onshore student transfers appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

The bulk of the proposed amendments apply to the Education Services for Overseas Students Act 2000 (ESOS Act). They closely reflect, with the exception of the then-controversial legislated mechanism for a foreign enrolment cap, the ESOS amendments proposed (and subsequently withdrawn) in 2024.

The ESOS amendments put forward by the Minister today provide for the following:

• Greater scrutiny of “cross-ownership arrangements” between providers and agents;

• Empowering the Department of Education to collect and share data from providers on their education agents, particularly with respect to the amount of commissions received and the number of students referred by each.

“Some collusive business practices between providers and agents are driven by agents seeking commissions through facilitating onshore transfers of students between providers, especially from the higher education sector to the VET sector,” notes the accompanying memo. Speaking in Parliament today, Minister Clare said his proposed amendments provide for a definition of “education agent commission.” This in turn, he said, “will allow for complementary amendments to be made to the National Code of Practice for Providers of Education and Training to Overseas Students 2018 to ban commissions from being paid to education agents for onshore student transfers.”

The proposed ESOS amendments otherwise provide government with additional powers around the registration (or de-registration) of education providers.

“International education is an important national asset,” said Minister Clare. He continued:

“In September 2022 we announced the Parkinson Review of the Migration System. And in January 2023 the Nixon Rapid Review into the Exploitation of Australia’s Visa System. These reviews identified integrity issues in international education, and we moved quickly on a number of recommendations of those reviews. This Bill is the next step.”

That being the case, the next step after this – presuming that the legislative amendments are passed into law – will be the revisions they trigger in government regulation otherwise, perhaps especially with respect to the National Code. The amendments themselves are very much concerned with expanding government authority in specific ways. There will be more clarity about how those new oversight powers will be employed in the regulations that eventually arise from the amendments.

For additional background, please see:

• “Australia’s enrolment cap legislation is stalled. What happens next?“
• “Who decides about quality? Education agents and the question of increased regulation“

The post Australia introduces new integrity measures through proposed amendments to the ESOS Act appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

International student numbers have more than tripled since the year 2000, with the most rapid growth having occurred in the last two decades. While this growth has unlocked new opportunities for institutions around the world, it has also highlighted the need for reliable oversight of the student recruitment process, especially when it involves third-party partners such as agents and counsellors. 

In response to the growing concerns around quality assurance, ethical practice, and accountability in recruitment, a number of destination countries are introducing formal frameworks and codes of conduct to govern the activities of education agents, protect students, and uphold the reputation of both the nation and institutions. 

Among these initiatives is the UK Agent Quality Framework (AQF), a selection of eight tools – including stakeholder guides, training, and an agent database –  designed to improve governance, professional competence, and partnership standards between agents and institutions. 

This article will explain what the AQF covers, outline its implications for UK providers, and offer practical guidance as to the training steps institutions can take to meet its requirements.

Understanding the Agent Quality Framework

Developed by the British Council following a lengthy consultation period with key stakeholders and created in close partnership with a number of sector bodies, including BUILA, UKCISA, and Universities UK International (UUKi), the AQF is a voluntary, sector-led approach to recruitment that supports agents and institutions in working more effectively together. 

The AQF is built around four key principles:

• Student choice: Agents must provide impartial, up-to-date information on programmes, fees, support services, and outcomes so that each student can weigh their choices objectively.
• Governance: From handling enquiries and tracking applications to managing complaints, agents must follow documented processes that are regularly reviewed through audits.
• Ethics: Agents must act with integrity by prioritising student needs, disclosing any conflicts of interest, and avoiding misleading claims. They must be able to demonstrate up-to-date knowledge of UK education and visa policies.
• Transparency: Agents must clearly communicate information about their services, fees, and institutional relationships while maintaining accurate records of all interactions and transactions.

By adhering to these principles, your institution can demonstrate compliance with sector expectations, maintain consistent oversight of agent activities, and build a more reliable, transparent recruitment process that prioritises student welfare.

The role of agent training

To meet the expectations laid out in the AQF, your agent partners must represent your institution professionally, stay informed about UK education and visa policies, and act in the best interests of students. Effective training plays a key role in achieving this, with well-trained agents contributing directly to a positive student experience and protecting your institution’s reputation.

The is an integral part of the AQF. This free, online programme covers areas such as the UK education system, visa and immigration rules, student support, and ethics, providing agents with a clear foundation upon which to build their professional development. 

Agents who complete the UK Agent and Counsellor Training Course receive a certification which is valid for two years, and they also have the option to appear on a public register, making it easier to verify their credentials. With the current push to drive up standards, this certification is increasingly being seen as a baseline for partnering with agents, instead of an optional extra.

Under the AQF, institutions have a clear duty to ensure their agent partners are properly trained and compliant. In practice, this may involve:

• Verifying each agent partner’s certification via the .
• Providing formal onboarding training for all new agents as well as supporting ongoing training by offering or signposting refresher and specialist skills courses to help agents stay up to date.
• Ensuring agents understand an institution’s unique selling points, compliance obligations, and specific partnership requirements through workshops, knowledge checks, and other resources. 
• Reviewing agent performance through data such as application volumes, conversion rates and training engagement to pinpoint knowledge gaps, evaluate the impact of existing training, and tailor future learning modules accordingly.

Taking these steps helps foster consistency, transparency, and quality in your recruitment partnerships.

Challenges of agent training 

The AQF is driving an evolution in agent training standards across the UK, shifting from informal, institution-specific practices to a more structured and accountable approach. However, delivering consistent, high-quality training across a global network of agents can be a significant challenge. 

Moreover, as your agent network expands to meet growing student mobility and competitive recruitment demands, you will need a scalable training model to avoid repeatedly running time and resource-intensive induction cycles.

At the same time, differences in time zones, language barriers, and limited access to the internet make live sessions impractical for many partners. Additionally, developing bespoke training materials in-house can quickly exceed your institution’s budget and internal capacity, leaving gaps in agent knowledge and reducing the likelihood of effective compliance.

The need for transparency and accountability adds a further layer of complexity. You must not only deliver training but also be able to track completion, assess knowledge retention, and act on student feedback. Integrating these monitoring processes into existing systems often involves technical work and data privacy considerations. Without a clear strategy and structure, it’s easy to lose track of agent progress, potentially undermining both AQF best practices and the student experience.

Practical approaches to meeting AQF training requirements

Meeting the AQF’s expectations for agent training doesn’t require a one-size-fits-all approach, but it does call for structure and consistency. As an education provider, you can take practical steps to embed good training practice into your institution’s agent partnerships by focusing on the following:

• Structured onboarding: Ensure all new agents receive a consistent induction covering your institution’s unique value proposition and ethical recruitment standards. Embed short quizzes with minimum pass scores to confirm understanding and reduce the need for manual follow-ups.
• Continuous professional development: Include upkeep of certification as a contractual requirement.
• Flexible training: Offer on-demand online modules to make training accessible across time zones and adaptable to different learning styles. 

Include case studies in your courses to test decision-making and reinforce the real-world application of AQF standards. If resources are available, complement online training with in-person meetings to strengthen your agent partnerships.

• AQF alignment mapping: Assign one or more of the AQF pillars to each of your training modules and run periodic checks to ensure every pillar is fully covered in your training and identify any gaps.
• Introduce micro-credentials:  Depending on your available resources, break your core topics into bite-sized badges or certifications that agents earn one by one. You can also gamify this by introducing leaderboards or point systems to boost engagement and reward top performers.
• Real-time monitoring: Host your content on a scalable digital platform such as or your Learning Management System (LMS) to automate assignments, track completions, and maintain audit-ready records of training activity.
• Regular content refreshes: Schedule updates according to your resources, to reflect policy changes, institutional developments and sector best practices, ensuring all agents remain current.

The AQF’s focus on professionalism, ethics, and transparency offers a clear roadmap for elevating your agent partnerships. By combining structured onboarding, flexible delivery methods, and targeted module-to-pillar mapping, you will be able to build a compliant training programme that drives more effective, student-centred recruitment.

Furthermore, by integrating real-time monitoring tools and committing to regular content reviews, you will ensure your agents remain current and aligned with your institution’s strategic goals. In so doing, you’ll safeguard student outcomes and reinforce your institution’s reputation.

For additional background, please see:

• Of special note to agency-based counsellors: the . Join this online course, produced by the British Council, for a comprehensive understanding of the United Kingdom’s education system and study options, and to develop specialist skills for advising students who wish to study in the UK.
• “���Ϲ��� Podcast: Together for transparency – Building global standards for ethical international student recruitment“
• “Who decides about quality? Education agents and the question of increased regulation“
• “UK sets out new immigration strategy, will reduce Graduate Route work term to 18 months“

The post How the UK’s Agent Quality Framework will shape the future of agent training appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Viewing all of that through a student lens, we have to acknowledge as a sector that in tandem with the recent surge in international student mobility, there has been an increase in reports of students having had a negative experience of study abroad. Those reports are grounded in a variety of issues, including shortages of affordable student housing, mental health concerns, poor integration into local communities, difficulty accessing support services, poor programme delivery, and sub-par graduation and career outcomes for some students.

Those reports have led to growing calls for better regulation of the sector, and they have prompted a wave of new policy settings brought forth by several national governments. New settings include enrolment caps in a number of countries – notably the Netherlands, Canada, and Australia – and a variety of new restrictions and requirements for visiting students.

Parallel to that pattern of tightened rules around international students has been a call for increased regulation of education agents. It is well established that agents play a critical role in student recruitment, and in providing invaluable support for students, parents, and institutional partners. But the education agent space is largely unregulated, operates at a considerable scale (with an estimated 22,000+ agencies worldwide), and offers few barriers for new entrants, especially in an era of aggregated agent networks and remote work.

Partly because the agent space is so large, varied, and lacking serious barriers to entry or to the expansion of agent networks, it has also been highly resistant to regulation. In practical terms, a given national government has little influence over an agency abroad that can quickly rebrand or restructure, or just as quickly shift its recruiting activity from one sector to another or from one country to another.

For all those reasons, there is a broad consensus that self-regulation – that is, measures that come from the industry itself – represents the best path forward for creating and implementing effective quality assurance measures for education agents.

The building blocks

Resistant to regulation as the agent space may be, there has, in fact, been a lot of great work done to strengthen standards of practice for education agents, and to advance the professional qualifications of agency-based student counsellors.

This work has largely occurred in three key areas: codes of conduct, agent training, and agency accreditation. There are a swirl of terms in this space, including “certification,” “accreditation,” and more. Codes of conduct, agent training, and agency training are sometimes conflated with one another, but it’s important to specify exactly what is being referred to. Each of these three components is quite distinct from – but highly complementary to – the others, and an effective self-regulation regime will combine all three.

Standards of practice

A number of codes of conduct and best practice guidelines are in place today, both pertaining to agent conduct and to the professional practices of institutions engaged with agents. Examples include the London Statement (formally, The Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants); the National Association for College Admission Counselling’s (NACAC) Guide to International Student Recruitment Agencies; the British Universities’ International Liaison Association’s (BUILA) National Code of Ethical Practice for UK Education Agents; the Australian Agent Code of Ethics (ACE); the Association of International Enrollment Management’s (AIRC) Best Practice Guidelines for Institutional Members; the Association of Language Travel Organisations’ (ALTO) Best Practice Guidelines for Education Providers and Agents; and the ���Ϲ��� Code of Conduct for the Ethical Recruitment of International Students.

Some codes of conduct are more oriented to one or more education sectors or to a given destination. If we were to put them side by side, however, we would find that they almost universally advance a common set of core principles, including transparency, accountability, integrity, fair dealing, and a commitment to high standards of student service on the part of education agents and also their institutional partners.

Any effort to strengthen quality standards for education agents – that is, any serious effort of self-regulation – rests in part on a clearly framed code of conduct, the standard of practice that it reflects, and a global mechanism for enforcing those standards.

An expanding field of training options

Put yourself in the shoes of a student counsellor working in an education agency. She may have studied abroad herself, or, through fam tours or other visits, have gained a firsthand experience of one or more destination countries. Alongside her knowledge of a study destination, its student visa programmes, and other relevant regulations, she also has to be an expert in any number of institutions and schools, their respective policies, and the many programmes and services they provide.

By any reckoning, that is a tremendous base of knowledge for any counsellor to establish and maintain, especially given that those programme offerings, policies, and other key points of information are changing all the time.

That explains the high demand for training among agency-based counsellors, both on best practices in recruitment and student services as well as training on advising students to study in one country or another, and of course ongoing training on individual institutions or schools.

It explains as well why many institutions invest heavily in counsellor training in support of their agent-partners, and why there is an expanding emphasis on agent training across the international education sector.

Agent training, for example, is embedded in the UK’s (AQF), a package of measures that includes specialised training courses for agency-based counsellors advising on study in the United Kingdom. And there are other specialised platforms, including , which provides a hosted solution that institutions and schools can use to deliver training for agent counsellors, and , which provides a growing portfolio of destination-focused courses along with other professional development options and qualifications for counsellors.

Within the AQF, the was developed and is administered by the British Council, and it is also delivered in partnership with ���Ϲ��� Academy. To date, 23,000 counsellors have registered for the course and nearly 10,000 have completed it and also endorsed the AQF’s code of conduct. “Until recently, the AQF was a voluntary framework where UK universities pledged to meet the standards set to evidence their good conduct,” says Jacqui Jenkins, the Global Lead for International Student Mobility at the British Council. “To the best of my knowledge almost all UK providers pledged to the AQF by the time the government made it mandatory [in spring 2024]. Independently, agents have also made public statements about their support of the AQF. Since the pledge was launched the number of agents registered for the [UK course] has increased from 8,000 in December 2023 to more than 26,000 in June 2024.”

Agent training is similarly embedded in the quality assurance standards in Australia, where agent-counsellors referring students to Australian institutions can complete the (EATC) in order to earn a Qualified Education Agent Counsellor (QEAC) designation. The EATC is a long-established course, now delivered by ���Ϲ��� Academy, with more than 13,000 graduates. “The EATC is a perfect example of how training can become part of an industry standard,” says ���Ϲ��� Academy Director Stacey Crosskill. “It provides counsellors with a strong foundation for effective student advising, and it allows individual institutions and schools to concentrate their own training efforts on their respective programmes and services.”

Alongside the British Council course for the UK and the EATC for Australia, ���Ϲ��� Academy provides specialised courses for counsellors advising students on study in Canada, the United States, France, Ireland, and, as of this week, New Zealand. All told, those courses have registered more than 127,000 learners and conferred professional qualifications to more than 19,000 agents in 130 countries who have successfully completed the course requirements.

Aside from the huge demand for training on the part of agency-based counsellors, perhaps the biggest takeaway from this review is that training courses can form an important part of a larger quality assurance mechanism, especially where they are explicitly incorporated into national or international models for quality assurance.

Validating and vetting the agency

If codes of conduct set a threshold of professional standards for both agencies and individual counsellors, and training advances the qualifications and professional development of agency-based counsellors, the last piece of the self-regulatory puzzle would appear to be verifying the bona fides, good practices, and compliance of the agency itself. This is where agency accreditation comes in.

There are lots of different mechanisms in the marketplace to screen or check agency qualifications. These especially include the requirements of the 14 national agency associations that comprise the supranational agent body (Federation of Education and Language Consultant Associations). They also include the vetting that occurs within the agent networks maintained by pathway providers, such as or . Similarly, event organisers, such as or , pre-screen agents that join their networking events. And of course many institutions or schools will conduct their own vetting of agent partners.

Against that varied backdrop, there are only two fully articulated agency accreditation programmes globally. One is administered by the (AIRC), and the other is the (IAS) programme. (Please note that in the United States, where AIRC is based, the term “certification” is more commonly used than is “accreditation.”)

AIRC has been certifying agencies since 2009. Its process is extensive, encompassing five broad areas of agency operation and a combined that agent-applicants must satisfy in order to earn the AIRC Certification seal. To date, 163 agencies have been certified and 107 are active-certified members. The process typically takes nine months, sometimes more or less. Agencies are initially accredited for a five-year term and, pending a successful reassessment in year five, may be renewed for subsequent ten-year terms.

Reflecting on the role of such accreditations, AIRC’s Director of Operations and Certification Jennifer Wright says, “They are designed to provide a full vetting of the agency company and recruiting operations and can be wholly accepted as a qualification for institutions to partner with an agency, or they may complement an individual institution’s agency vetting efforts. I’ve had institutions send staff to our reviewer training at AIRC with no intention of working on agency reviews for us. But they are going to use those skills in their own due diligence work in evaluating new agencies or agency performance, and the AIRC certification gives them a running start on their own engagement with the agency.”

Meanwhile, the IAS, says Tony Lee, ���Ϲ���’s Chief Vision Officer, has become the de facto global standard for agency quality assurance and represents the “the highest common denominator of good agency practice in all of the major study destinations.”

The programme reached an important milestone earlier this year with the accreditation of its 2,200th agency across 127 countries. Another 1,000 agencies are currently in the midst of a comprehensive vetting process that includes reference checks, operational audits, and extensive document verification.

Agencies are reassessed annually, and agent compliance with accreditation requirements, including the ���Ϲ��� Code of Conduct, is overseen by ���Ϲ���’s global agent team, which currently numbers more than 30 staff across 16 countries.

“In order to be a true standard for the industry, any accreditation scheme needs to be credible, accessible by a wide variety of agencies, and administered by a market-neutral organisation with global reach and expertise,” adds Tony Lee. “These are the core ingredients of IAS, and it’s why we are seeing such rapid adoption of this accreditation model by agents and industry stakeholders alike.”

For additional background, please see:

• Join the (12 September 2025, London). A landmark one-day summit bringing together the industry’s senior leaders, policy makers, and experts, all focused on shaping the future of the international education sector.
• “���Ϲ��� announces new agent code of conduct“
• “Australia expands regulatory oversight of education agents and announces new integrity measures for VET“
• “Global agent survey finds a strong growth outlook for 2024; provides new insights on agency operations“

The post Who decides about quality? Education agents and the question of increased regulation appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.