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.

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.

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.

The Australian government announced over the weekend that it will introduce legislation this week to further “support the integrity and sustainability of the international education sector.” explains that the legislative package represents “the next step in delivering on the objectives of the Government’s Migration Strategy.”

The planned legislation will allow Minister for Education Jason Clare to limit the number of new international enrolments that can be offered by Australian providers. The Australian newspaper characterised those new limits as a “soft cap,” which is “better than the alternative of a rigid limit on student numbers.” That softness, or flexibility, in the cap model arises from a provision that allows providers to recruit above a cap limit if they “establish additional, new supply of purpose-built student accommodation to benefit both international and domestic students and free up pressure on the rental market.”

While education stakeholders will need more detail on the implementation of the new cap before drawing any hard conclusions, Australia’s international education sector, which has been campaigning for months against any such limits on foreign enrolment.

In addition to the enrolment cap, the planned legislation will introduce a package of additional measures, some of which have been floated by the government previously. Specifically:

• Education providers will be prevented from holding ownership positions in education agencies;

• Registrations for new international education providers will be paused for up to 12 months; as will approvals of new courses proposed by existing registered providers;

• Institutions or schools seeking to register as international education providers will be required to demonstrate “a track record of quality education delivery to domestic students before they are allowed to recruit international students”;

• Dormant provider registrations will be cancelled;

• Registered providers under regulatory investigation will be banned from recruiting new international students;

• There will be additional data sharing related to education agents; and

• Agent commissions on onshore student transfers will be prohibited.

“Most providers do the right thing and are in education and training for the right reasons,” said Minister for Skills and Training Brendan O’Connor, in introducing the new measures this weekend. “They will benefit from a high quality and sustainable international education sector, and the Government’s efforts to crack down on non-genuine and unscrupulous actors who undermine integrity and trust in the sector.” At the same time, he added, “Because there is no place for dodgy operators who undermine the strong reputation of the sector, we are making it tougher for bottom-feeders to take advantage of international students for a quick buck.”

Early sector response

Responding quickly to the government announcement, Universities Australia Chief Executive Luke Sheehy said, “Decades of careful and strategic work by universities and the Government has seen Australia grow to be a leading provider of international education. We can’t let this work go to waste…We will be working closely with the Government to co-design the policy settings needed to give the international education sector a strong and sustainable footing from which to grow into the future.”

Phil Honeywood, the CEO of the International Education Association of Australia (IEAA), added that, “Under the [pending legislation], the Federal Government is looking to allocate a limit on the number of new overseas student enrolments available to each CRICOS [Commonwealth Register of Institutions and Courses for Overseas Students] registered provider.

While stakeholder consultations are being offered, this latest measure will send all the wrong messages, yet again, of Australia’s reliability as a welcoming study destination country. Coming on top of the recently announced changes to financial capability requirements, visa processing slowdowns and backlogs, prospective students and our education agents will feel incredibly let down. Other measures, such as big increases in student visa fees, are also anticipated.”

“Given that importance, any mix of policy settings must be considered, and nuanced. If the problems are neither simple nor one-dimensional then the solutions won’t be either,” said Group of Eight Chief Executive Vicki Thomson. “Consultation will be crucial to ensure we get the settings right.”

Framework for consultation

In their joint release over the weekend, Minister for Education Jason Clare, Minister for Skills and Training Brendan O’Connor, and Minister for Home Affairs Clare O’Neil also released a draft . The Framework elaborates on each component of the pending legislation as outlined above, and sets the stage for a government-industry consultation on the implementation of these new measures and other longer-term directions in Australia’s international education sector.

“The Government will consult with the sector on all aspects of the Framework over the coming months and release the final Framework later this year,” said the joint release, while Minister O’Neil added that, ““With international student visa grants back to pre-pandemic levels, the focus now shifts to ensuring numbers in the sector are managed more strategically over the long-term.”

The Framework sets out a broad range of consultative questions, including:

• “Are there further reforms governments should consider that will improve the quality and integrity of the sector?”
• “What more can providers do to improve the integrity of the international education sector?”
• “What factors should inform government’s approach to allocating international student enrolments across sectors, providers, and locations in Australia?”

“This Strategic Framework marks a significant shift for Australia’s international education sector,” concludes the draft Framework paper. “Government invites views from the sector and interested parties on the issues raised ahead of finalising the Strategic Framework later in 2024.”

“The Government is committed to the careful management of Australia’s international education sector, and to strengthening its quality, integrity and reputation. We seek to shape a sector which is sustainable in the long-term and which plays a leading role in delivering on Australia’s national objectives. Enhancing the quality and integrity of the sector, strongly aligning education outcomes with areas of skills needs, and continuing to build our innovative delivery models are just some of the key measures that will help advance Australia’s position as a world leader in education.”

There is little to argue with in those statements. But even so, sector stakeholders will reasonably enough wonder about the nature of the upcoming consultation. That this week’s announcement of an enrolment cap (and related measures) came unexpectedly over a weekend – and with a framework already in place – will leave many to question if the government has set the stage for a real collaborative consultation or has simply laid down a roadmap for further reforms.

For additional background, please see:

• “Australia increases minimum funds requirements again amid rumoured hike in student visa fees“
• “New research debunks link between Australia’s rental housing crisis and international students“
• “US gains greater share of international student interest amid policy changes in competitor destinations“
• “Australia: New Migration Strategy ushers in tougher requirements for international students“

The post Australian government to set international student cap appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

The move follows a high-profile “exposé” published in on 27 January. The piece has since been widely criticised by sectors leaders as having conflated international foundation programmes (sometimes referred to as International Year One or IYO) with full degrees.

Speaking immediately after the item’s publication, Universities UK Chief Executive Vivienne Stern said: “The Sunday Times story fails to distinguish between entry requirements for International Foundation Years and full degrees. International Foundation Years are designed to prepare students to apply for full degree programmes. They do not guarantee entry to them. They are designed for students who come from different education systems where, in many cases, students might have completed 12 rather than 13 years of education…It must be understood that entry routes for international students will reflect the diverse countries and education backgrounds that these students come from, and that some will need bridging courses to enable them to progress to UK degrees.”

Even so, a further statement from Universities UK on makes clear the level of concern around the story, and that the sector feels the need to respond further to a narrative that has caught the public imagination, as well as the attention of policy makers.

“There has been a significant focus on recruitment practices relating to international students in recent weeks. While many aspects of the reporting misrepresented the admissions process and criteria, we recognise the concern this has caused for students, their parents, and the public and it is vital that they all, along with government, have confidence that the system is fair, transparent, and robust,” said Universities UK. “Where there is practice that falls below the standards expected of our universities and their representatives, we will take action.”

The peak body has therefore determined that it will:

• Review the (AQF) and make recommendations to strengthen it further, particularly with respect to recommendations toward “how the AQF and wider UK data infrastructure can be enhanced to identify and address bad practice and improve resilience.”

• Commission the Quality Assurance Agency (QAA) to “undertake a rapid review of [International Foundation Programmes].” That review will essentially compare requirements of International and Home Foundation Programmes, with a particular focus on admissions requirements.

• Strengthen the sector’s Admissions Code of Practice with respect to international admissions by reviewing “the Admissions Code of Practice to signpost where the Code is expected to apply to international recruitment and update the Code if appropriate.”

Those moves come amidst growing calls within the UK sector for increased regulation, especially with respect to education agents. Writing in on 2 February, Jim Dickinson argued that the AQF review should be accompanied by a requirement that its provisions be compulsory for all institutions. “That will feel like burden to some – but it’s hard to find anything in the framework as currently described that you wouldn’t argue is pretty essential when recruiting people from another country to spend a lot of money to come study in the UK,” he said.

Mr Dickinson is calling in part for expanded efforts re: due diligence in vetting agents, strengthened (and consistently applied and enforced) agent contracts, a greater onus on education providers to ensure that agents undertake required training, and greater transparency and monitoring across agent networks.

Responding via LinkedIn, higher education consultant Vincenzo Raimo added, “My view is that trying to regulate agents across national borders is the wrong place to start. We should be regulating those who appoint the agents. We are too quick to blame agents when things go wrong. It’s the universities which appoint the agents in the first place who need to take responsibility for the actions their agents carry out on their behalf. I approve of the Code of Ethics for agents but where’s the code of ethics for the universities and their staff?”

Even that sample of opinion reveals some persistent challenges in approaching the question of increased regulation of agents, including at least:

• The capacity and effectiveness of institutions and schools to vet new agent contacts and to monitor agent performance
• The practical limitations of attempting to regulate agents across national borders

Some of those points were echoed in a lively LinkedIn discussion, which included comments from industry veteran Nick Golding, who added, “Can consistency of [agent] vetting be assured when it will be undertaken by hundreds, if not thousands, of different individuals working across 140+ institutions?…Then, how will ongoing standards of practice be monitored with, for example, annual audits? Are universities resourced for that, and could it that mean that agencies are audited by every single institution they work with?”

“While I believe that all institutions everywhere should conduct some form of due diligence on agents and other suppliers of students, I don’t believe that is the ultimate answer to the problem. The international education sector as a whole needs a global standard of agency good practice and training that is independently accredited and monitored on an ongoing basis, which is at arm’s length to the agencies themselves, and institutional or national interests.

In other words, there needs to be a supranational body that can embed and police global standards effectively.”

There are of course well-established models for accreditation, regulation, and agent training, but the most commonly cited examples of those are tied to specific study destinations, such as the United States, Australia, or New Zealand. We don’t normally cite ���Ϲ��� programmes or services in ongoing coverage, but in this case it’s appropriate to point out one highly relevant and global initiative –  – that has already emerged as the industry’s largest agency accreditation scheme with 1,500+ agents vetted, the status of each is regularly reviewed via annual audit. That accreditation is in turn tied to, and reinforced by, compulsory compliance with a Code of Conduct for education agencies.

The industry is clearly on a path towards increased oversight and quality assurance in this area, both in the UK and elsewhere, but the key ingredients to an effective model will include a balancing of educator and agent responsibilities, monitoring and enforcement mechanisms that transcend national boundaries, and a solid grounding in the best practices and standards in the field.

For additional background, please see:

• “International enrolment drop at York sounds alarm for UK higher education“
• “���Ϲ��� announces new agent code of conduct“
• “New analysis highlights UK universities’ reliance on international enrolments“
• “Signs point to cooling demand for UK higher education in non-EU markets“

The post Universities UK announces admissions and agent probe appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

The article also departs somewhat from our normal coverage on ���Ϲ��� Monitor, in that it is explicitly concerned with a new initiative from ���Ϲ���. We don’t normally highlight ���Ϲ���’s programmes and services in our ongoing coverage but we’re making an exception in this case as we believe the subject is especially relevant and important for our readers.

The international education marketplace is more complex than ever. A greater number
of destinations – and education institutions – are competing for students’ attention. The range of available study programmes has expanded and now includes online and hybrid modalities. Students consider not only course content, but also scholarships, internships, and post-study work and permanent residency opportunities.

As a result, both students and educators are increasingly turning to agents for support. Students rely on agents to help them to plan study abroad, compare options, and apply to institutions. Institutions appreciate the local expertise and connections of agents when diversifying their markets, promoting a wider variety of programmes, and communicating across languages, religions, and cultures.

Greater use of agents has underscored the need for improved quality standards for institution-agency collaborations. Several best practice guidelines now exist, some developed by governments and peak bodies and some created by other stakeholders.

Despite having been developed at different times and in different contexts, the resources listed below all aim to codify best practices for educators and agents alike. Persistent themes include honesty, accountability, and transparency in agency-educator partnerships and in communications and transactions with students.

• The London Statement framework (formally, The Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants)
• The Guide to International Student Recruitment Agencies from the National Association for College Admission Counseling (NACAC)
• The National Code of Ethical Practice for UK Education Agents from British
• Universities’ International Liaison Association (BUILA)
• The Australian Agent Code of Ethics (ACE)
• Best Practice Guidelines for Institutional Members from the Association of International Enrollment Management (AIRC)
• Best Practice Guidelines for Education Providers and Agents from The Association of Language Travel Organisations (ALTO)

A new code of conduct governing ���Ϲ���-approved agencies

For the past year, ���Ϲ��� has been engaged in a process of deep reflection on these important themes, leading to the development of our own Code of Conduct. This is a code of practice that agencies are now required to endorse and comply with in order to establish or maintain their ���Ϲ��� Agency Status and their eligibility to attend ���Ϲ��� events.

“The increasing use of education agents in international recruitment also underscores the need for improved quality standards,” says ���Ϲ��� CEO Markus Badde. “The number of active agents continues to grow quickly yet the sector still remains largely unregulated. For decades we have consistently worked to advance professional standards in international student recruitment by screening, training and accrediting education agencies. Given current circumstances we feel there is now a need to do more. Over a year ago, we introduced block chain technology enabling students, parents, and educators to easily and instantly verify an agency’s IAS accreditation. Now we have gone even further with the implementation of a more in-depth vetting process for participating agencies, with increased agent monitoring and quality assurance measures carried out by ���Ϲ���’s globally distributed Agents Relations team.”

There are currently over 1,500 education agencies in 115 countries who have been
accredited and have ���Ϲ��� Agency Status – a designation that is valid for one year and for which the vetting and review process is refreshed annually. This fast-growing base of IAS agencies already represents the largest network of accredited agencies in the industry, and, as such, represents a new global standard for agency recognition and quality assurance.

“Having a trusted source of accredited agencies around the world is imperative, particularly at a time when lower barriers to entry have created a proliferation of new agency players” says ���Ϲ���’s Executive Director for Agent Relations Tiffany Egler. “With the ���Ϲ��� Code of Conduct in place, and with the steps we have taken to expand the IAS programme, schools, colleges, and universities can now be better assured that they are working with professional organisations to ensure the best possible outcomes for their international students.”

The complete code appears below, and we hope it will be helpful both for educators
working with agents and for agents who aim to distinguish themselves in an increasingly competitive marketplace.

���Ϲ��� Code of Conduct for the Ethical Recruitment of International Students

Agency owners and executives are straightforward, transparent, and accountable at all times and in all dealings with staff, institutions, students, parents, and other stakeholders. This includes ensuring that they and their staff are:

1. Acting fairly and in the best interests of both students and institutional partners.
2. Providing current, accurate, and honest information.
3. Providing realistic and appropriate information that is tailored to the individual student, particularly in relation to language ability, financial capacity, and intended study programme.
4. Ensuring that visa and admissions applications are free of any fraudulent or misleading documents or representations.
5. Being transparent in all business dealings and advisory services, including avoiding any conflicts of interest or misrepresentation.
6. Prioritising the use of signed agreements or contracts between the agency and the institution and being transparent with both students and receiving institutions in cases where a student may be referred outside of any such formal agreement.
7. Disclosing to partner institutions whether any contracted subagents may play a role in recruitment and ensuring appropriate oversight or quality assurance measures to monitor subagent compliance with this code of conduct.
8. Preserving the confidentiality of all personal and business information.
9. Ensuring that minor students have adequate representation and support from a parent, guardian, and/or legal counsel.
10. Representing accurately the rights and responsibilities of the student in their intended destination country.
11. Complying with all relevant laws and regulations in both the agent’s home country and the student’s intended destination.
12. Promoting a government or industry endorsement – including the use of any official brand marks – only with the approval of the endorsing body.
13. Using an institution’s officially approved material, including branding or any official marks, only in cases where a written agreement with that institution provides for such use.
14. Ensuring that all advertising and marketing materials are free of misrepresentation and comply with both local advertising standards and the brand guidelines of partner institutions.
15. Ensuring the quality of the student experience through effective mechanisms to gather feedback and otherwise monitor a student’s progress in their study abroad destination.
16. Establishing clear processes for handling complaints and resolving disputes.
17. Participating in appropriate industry training programmes where possible and appropriate, as well as training and site visits specific to individual institutions.
18. Maintaining membership in appropriate professional associations and other standards-based bodies, where possible and appropriate.
19. Working with stakeholders and colleagues to advance industry standards and best practices.
20. Maintaining all required business licences and/or registrations.

For additional background on the ���Ϲ��� Agency Status programme, please see .

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Across its many recommendations, the report proposes a more integrated approach to marketing Australia as a study destination and “diversification into new and emerging geographic markets.”

The report also makes several recommendations concerning expanded regulation of education agents, and argues that, “The Government accept that regulation of education agents is essential and long overdue, and that a model must be determined and implemented…Any model will need to ensure compliance with a single Code of Ethical Practice for Education Agents setting expected standards for all education agents who work with Australian education providers.”

Adopt a “Team Australia” approach

The report asserts that key to boosting the Australian international sector’s competitiveness is that “Government lead a ‘Team Australia’ programme to build a stronger national international education brand and platform and agree on a five-year prioritised Market Diversification Plan.” This includes (1) better coordination among government agencies tasked with education employment and relatedly, (2) an end to fragmented and/or divisive marketing in international markets by various stakeholders in the industry.

Invest in new markets

“Team Australia should prioritise the development of a five-year Market Diversification Plan into new and emerging geographic markets,” says the report. Recommended new regions for student recruitment are “sub-Saharan Africa, Southeast Asia and South and Central America (considering for example Nigeria, Kenya, Botswana, Zimbabwe, Indonesia, Vietnam, the Philippines, Brazil, Colombia and Chile).”

The report also considers it important to build stronger ties with the islands of Blue Pacific region (e.g., Fiji, Kiribati, Tonga, Palau) by creating compelling educational offerings relevant to the islands’ geography and developmental priorities.

Make it easier for Australian employers to hire international students

Recognising that post-graduate work rights are so vital to international students and that Australia needs international talent to plug skills gaps in the economy, the report says it is crucial that employers be educated on the benefits of hiring international students. It advocates for the creation of “campaigns [that] combat employer confusion and misinformation about graduate work rights, visa conditions, and pathways to permanent residency (where available).”

Integrate more work placements and structures around them

Most international students choose to study abroad believing that their decision will provide them with better skills and opportunities for a successful career than they could expect if they stayed at home for education. The report emphasises the need for the establishment of a national work-integrated learning framework, and it notes that competitor countries are leveraging in-study work opportunities in their marketing abroad:

“Further sandwich courses, higher education apprenticeships and other paid work and learn integrated models of study are increasingly common in jurisdictions with whom Australia competes for international students. These models offer better integration between industry and educational entities and should be given immediate consideration by a taskforce established by the Government.”

Address accommodation shortages

As in so many other destinations, many international students are having trouble finding suitable and affordable housing in Australia. The report urges state governments and universities to develop the homestay model and make it more attractive to Australian homeowners, and to “urgently work to foster the expansion of the Purpose-Built Student Accommodation (PBSA) sector.” Specifically, it recommends:

• “Examining mechanisms to boost domestic and superannuation fund investment into PBSA (as the majority of capital invested at present is foreign) including support for a new asset class of PBSA, recognising that it is now a mature and specialist housing product.
• Engaging with state, territory and local governments to remove planning and development impediments to PBSA developments.
• Working with regional universities and considering incentives to support PBSA developments in regional Australia.”

Strengthening integrity

Information sharing across international education sectors is crucial to identifying bad actors undermining the integrity of the industry, says the report.

“The Committee recommends the Government use whatever means at its disposal to compel education providers to … share credible information and concerns regarding education agents, entities and student movements … and to disrupt non-genuine students and other entities seeking to exploit the international education sector, the student visa system, and international students.”

The VET sector is singled out for “persistent and deep-seated integrity issues” and the report recommends a series of potential, dramatic actions that could be considered to address these, including the suspension of providers’ ability to recruit and host international students.

Protecting international students

The committee determined the need for a targeted communication strategy to educate:

• “International students of their rights and obligations when studying in Australia;
• Providers and education agents of their obligations to international students studying in Australia;
• Employers and industries that are high employers of international students.”

The government is urged to mandate the inclusion of certain passages in agreements between educators and students, including language around refund conditions as well as the disclosure of any commissions paid to agents.

Tighten up practices with agents

Several recommendations focus on agents, including:

• “An expansion of the current Education Agents Dashboard on Provider Registration and International Student Management System (PRISMS) to allow provider access to all education agents’ information. Such an expansion should enable providers to consider an agent’s performance before entering contractual arrangements and to be able to compare agent performance or integrity concerns about individual agents across the sector.”
• And, as noted earlier, “compliance with a single Code of Ethical Practice for Education Agents setting expected standards for all education agents who work with Australian education providers.”

An underfunded part of Australian tourism

An article in laments the lack of much comment on the key intersection between international education and tourism in Australia. It points out as well that Australia’s education marketing efforts are considerably underfunded relative to international competitors. The article explains that:

“Study Australia’s budget [under AUS$6 million] is extremely modest given the direct revenue and soft power influences potential of international education for Australia. International education revenue (including students here under 12 months and over 12 months) generates sixty-eight per cent of international tourism spend in Australia.”

While Tourism Australia spent close to AUS$60 million in advertising and research in 2021/22, The Koala News notes that “Austrade’s marketing spend for international education for the same year (2021/22) was $6,883,923.”

The report compared the marketing spend for international education in Australia to competitor countries. For example:

“In FY 21/22 the British Council spent £175 million (approx. AUD $335 million) on encouraging educational cooperation and promotion the advancement of education.

In 2019, the Canadian Government announced a new international education strategy backed by government investment of CDN$147.9 million (approx. AUD$165 million) over five years, starting in 2019–20, with a further CDN$8.0 million (approx. AUD$9 million) per year, ongoing.”

For additional background, please see:

• “Australia expands regulatory oversight of education agents and announces new integrity measures for VET”
• “Pandemic Event Visa scrapped as Australia continues overhaul of student visa policies”
• “Australia takes action on fraud in student visa system”

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