Ϲ Monitor Articles about Regulation and Quality Assurance /category/agents/regulation-quality-assurance/ Ϲ Monitor is a business development and market intelligence resource providing international education industry news and research. Thu, 10 Sep 2026 19:23:05 +0000 en-GB hourly 1 https://wordpress.org/?v=6.5.3 /wp-content/uploads/2022/07/cropped-LOGO_2022_FLAVICON-2-32x32.png Ϲ Monitor Articles about Regulation and Quality Assurance /category/agents/regulation-quality-assurance/ 32 32 For the first time, the Australian government has exercised its powers to cancel an entire course /2026/09/for-the-first-time-the-australian-government-has-exercised-its-powers-to-cancel-an-entire-course/ Thu, 10 Sep 2026 19:23:01 +0000 /?p=48874 In late 2025, the Australian Parliament passed a package of legislative amendments extending new oversight and regulatory powers to government ministries and agencies, and setting the stage for additional regulation of the country’s international education sector via the National Code of Practice for Providers of Education and Training to Overseas Students. Among other measures, those…

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In late 2025, the Australian Parliament passed a package of legislative amendments extending new oversight and regulatory powers to government ministries and agencies, and setting the stage for additional regulation of the country’s international education sector via the National Code of Practice for Providers of Education and Training to Overseas Students.

Among other measures, those legislative amendments granted the government the power to cancel entire courses due to concerns around quality or relevance to Australia’s skills needs.

On 4 September 2026, and for the first time, the Australian government did just that when it issues an order preventing new enrolments in the Graduate Diploma of Management Learning, or GDML, identified as course number BSB80120.

The government order stipulates that, “Providers that deliver the course (BSB80120) will have their Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) registration for the GDML course automatically suspended or cancelled.”

This is significant in at least two ways. First, a college of university can only enroll student visa-holding students in a course that is registered on CRICOS. In effect, if a course’s CRICOS registration is suspended or cancelled, the provider loses its legal basis to recruit and enroll foreign students in that course.

Second, pay close attention to the word “automatically” in that statement. Normally, a sector regulator – ASQA for VET providers, TEQSA for universities – has to investigate a specific provider and make a decision before it can suspend or cancel a registration. The new legislation allows the government to step around that provider-by-provider process. Rather, it specifies the GDML, and every provider’s CRICOS registration for that course is suspended or cancelled straight away via the powers vested in the legislation.

The scale of the decision

While we are using the term “course” here, this should not be understood to refer to a single programme offering at a given institution. Rather, the GDML is widely taught within Australia’s VET sector.

A statement from Assistant Minister for International Education Julian Hill indicates that 452 VET providers are registered to deliver the GDML to international students, with 41,033 active Confirmations of Enrolment (CoEs) at time of cancellation, including 15,772 students currently enrolled.

The government order stipulates that – while new students cannot be enrolled in THE GDML at any provider – students who have already begun their studies will be able to complete their course with their current institution.

But why?

“The government will continue to act decisively to ensure Australia remains a trusted global education destination, to protect international students and to prevent misuse of the student visa system,” said Mr Hill.

A from the Assistant Minister’s office explains, “The decision is the first use of new course cancellation powers and follows significant evidence that the course has been used to facilitate onshore transfers by non-genuine students and is associated with high rates of visa refusals and course non-completion…The targeted action will strengthen the quality and integrity of Australia’s international education sector and protect the interests of international students and follows the package of integrity reforms the Government passed in November 2025.”

A related report from highlights that, “Transfers jumped from 510 people in 2020 to 4,000 in 2025, with 77% of the students switching to the diploma coming from elsewhere in higher education. [This] meant students could switch into the course without necessarily needing a new student visa application…[Further,] almost most half of the people approved to enroll in the diploma did not commence in 2025, and completion rates were significantly below those of other VET courses.”

Commenting on the decision in , industry expert Tracy Harris said, “This course is exactly what the cancellation powers in the legislation were built for and I’ve been waiting for this decision. There are well-known concerns in the sector about rapid growth and non-genuine students in this particular course, and it’s entirely unsurprising to me that this would be the first course the government would act on.”

In a related post on , Mirza Rahil Baig, country manager for the agency Global Scholar said of the GDML cancellation, “Course selection is becoming a compliance issue. The industry can no longer afford to ask only: ‘Is this course available?’ We need to ask: Does this course genuinely fit the student’s academic background? Is the progression logical? Is there a credible career outcome?

And most importantly, are we building a genuine education pathway?…For education agents, counsellors and recruitment partners, this should change the way we advise students.”

For additional background, please see:

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Korean government introduces new quality controls for universities and agents /2026/09/korean-government-introduces-new-quality-controls-for-universities-and-agents/ Thu, 10 Sep 2026 18:08:39 +0000 /?p=48866 South Korea met its goal of hosting 300,000 international students by 2027 in mid-2025, two years early, and by February 2026, foreign enrolments stood at 314,000. That kind of volume tends to usher in a next phase of internationalisation in major destinations, one where the focus moves from quantity to quality, and where governmental regulation…

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South Korea met its goal of hosting 300,000 international students by 2027 in mid-2025, two years early, and by February 2026, foreign enrolments stood at 314,000. That kind of volume tends to usher in a next phase of internationalisation in major destinations, one where the focus moves from quantity to quality, and where governmental regulation of the sector becomes  more intense. This is exactly what is happening in South Korea.

On 8 September 2026, the Ministry of Education announced a suite of measures that will (1) affect the way universities and agents recruit students and (2) set a higher bar for the experience international students have while in South Korea, both in their studies and in terms of post-graduation outcomes.

In another sign that the South Korean sector is maturing, the ministry plans to increase its support – including scholarships – for the attraction of top students, especially those in STEM and/or choosing programmes linked to regional economic needs and skills gaps.

In an official press release, Education Minister Choi Kyo-jin said: “Surpassing 300,000 international students means Korea is being recognised as a competitive country for global talent. We will focus on attracting and nurturing talented students and support them so they can contribute to our society and communities around the world based on their studies and experiences in Korea.”

Agent and university obligations

In October, universities and recruitment agencies will receive ministerial direction about acceptable codes of conduct in recruiting and hosting students. This will come in the form of a contract both parties need to sign and abide by. Later in the year, the ministry will amend its Higher Education Act to make key provisions in the agreement mandatory and to allow the ministry to issue corrective orders for non-compliance.

Many of the stipulations are basic best practices, as outlined in and comparable practice codes, such as:

  • Providing accurate information to students about academic programmes, in-study work rights, and post-study opportunities;
  • Avoiding misleading or exaggerated advertising;
  • Informing students about tuition refund processes and amounts;
  • Refunding the tuition paid by students whose visa is denied.

Agents will also be compelled to provide any information that universities request from them, and universities will need to step up their monitoring of agents’ recruitment practices.

A stricter accreditation process

IEQAS is South Korea’s quality assurance programme that evaluates how well local universities recruit and manage international students. As of March 2026, universities have been required to operate according to new EQAS standards around illegal stay rates, Korean language proficiency, and dropout rates. These new benchmarks are included in what is known as the 4th cycle of IEQAS. If a university makes it into the “Excellent Certified Universities” tier, they are rewarded with streamlined visa processing, top visibility on the official Study in Korea portal, and a government press release profiling the institution as a success story. In addition, “excellent” universities receive priority and preferential quota allocations when selecting recipients for the government’s Global Korea Scholarship (GKS).

The next tier is “General Certified Universities,” which comes with somewhat simplified visa process. If a university fails to be certified, it faces visa restrictions and limits on the recruitment of international students.

The 4th IEQAS cycle will end in 2028 and be replaced with the 5th cycle in 2029, which will come with stricter standards. At present, universities only have to meet one mandatory indicator of proper conduct concerning recruiting and student experience, and then select six other indicators. But in the 5th cycle (2029–2032), key indicators will become mandatory and not up to the universities to choose. Korean and English language proficiency thresholds will move from 40% to 60% by 2030. Institutions that are in financial hardship or performing poorly on mandatory indicators will lose visa issuance rights. This would effectively bar them from recruiting more international students.

Market correction

The background for the government’s tightening of compliance requirements is growing evidence that international students are not always receiving the experience, support, and opportunities they deserve in South Korea. For example:

  • Korean media that in the past year, some junior colleges have delayed tuition refunds of up to 1 billion won or (US $745,000) due to financial hardship. One college admitted that it had used around half of the money owed to students for operating expenses amid financial difficulties.
  • Insufficient Korean language proficiency has been determined to be an obstacle to international student success, retention, and graduate outcomes. Rezia Usman, regional director of the office of international affairs at Woosong University, said to Korea JoongAng Daily: “Korea has already proven that it is good at attracting international students. The challenge now is making sure those students feel they are truly learning the [local] language and culture while universities also help them build their careers in Korea.”
  • Some universities have been admitting students with poor chances of success. “The issue is structural,” explained a report in Korea JoongAng Daily. “Admission decisions are largely left to institutional discretion, and universities face no direct penalties for enrolling students who do not meet the ministry’s guidelines.”
  • Agent use is quite common, with 18% of 8,300 surveyed international students agreeing that agency recommendations were a major factor in their choice of university. Regulations and better scrutiny of agents will improve the quality of advice and support that students receive for them, and increase the chances that students are screened properly so only those with a high chance of success are admitted.

For additional background, please see:

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Why sharper English-language guidance is becoming an agent’s sharpest tool for student success /2026/07/why-sharper-english-language-guidance-is-becoming-an-agents-sharpest-tool-for-student-success/ Tue, 21 Jul 2026 16:47:08 +0000 /?p=48445 Most agents ELSAA speaks with are deeply committed to their students’ success – that isn’t in question. What is changing, and fast, is how much specialist knowledge agents now need on English-language evidence specifically, and how much rides on getting it right. As UK admissions and visa processes tighten, agents who can offer sharper, more…

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Most agents ELSAA speaks with are deeply committed to their students’ success – that isn’t in question. What is changing, and fast, is how much specialist knowledge agents now need on English-language evidence specifically, and how much rides on getting it right. As UK admissions and visa processes tighten, agents who can offer sharper, more confident guidance on English-language testing are giving their students and their own business a genuine edge.

The scrutiny is coming from more than one direction. Admissions offices are tightening their own checks on the authenticity and consistency of English-language evidence, in response to well-documented fraud vulnerabilities and inconsistent evidence standards across the sector.

At the same time, UK Visas and Immigration (UKVI) now runs an annual Basic Compliance Assessment (BCA) for every institution holding a student sponsor licence, scoring them on visa refusal rates, enrolment rates, and course completion rates. Falling short on any one of those metrics can strip an institution of the right to self-assess a student’s English ability altogether, forcing a shift to mandatory secure testing across the board. Further, a new Agent Quality Framework is being extended so institutions can no longer treat agent-sourced evidence as somebody else’s responsibility. In short: the English-language evidence an agent helps assemble now feeds directly into a compliance metric that determines whether an institution can keep recruiting internationally at all.

That’s the backdrop and it’s also the opportunity. Agents who understand this chain of evidence, and can speak to it confidently, become more valuable partners to the institutions they work with, and better advisers to the students who trust them.

Academic readiness is the cornerstone of student success

Academic readiness is the strongest predictor of first-year performance, progression, retention, and completion. When students arrive without sufficient English proficiency, the impact is immediate: difficulty engaging in seminars and group work, falling behind in reading-intensive modules, rising stress, and a higher likelihood of assessment failure or withdrawal.

Meeting a minimum entry requirement isn’t the same as being ready to perform at it. A student who scrapes the headline overall score with a weak reading or writing subscore is often the one who struggles most in postgraduate, research-intensive programmes, where extended reading and academic writing carry most of the assessment weight.

In practice, that means: looking with the student beyond the single overall band to the subscore breakdown; recommending a margin above the minimum particularly in speaking and writing wherever a programme is writing- or seminar-heavy; and encouraging an early retake where subscores are borderline, rather than waiting until an offer is at risk. Agents who steer students toward the cheapest or fastest route to a passing score to obtain a visa rather than genuine readiness, aren’t doing anyone any favours: those are the students most likely to need extra support, delay progression, or withdraw outcomes now visible to institutions through the BCA’s own completion-rate metric.

The growing scrutiny of MOI

Medium of Instruction (MOI) evidence is under sustained scrutiny, and institutions increasingly treat it as a case-by-case judgement rather than a standard alternative to testing. Practice varies widely: some institutions require MOI letters to be corroborated by transcripts, curriculum details, or interview; others have withdrawn MOI acceptance for certain markets or programmes altogether, following BCA findings that linked MOI-based admissions to weaker completion or higher visa refusal rates.

For agents, that means treating an MOI recommendation as a considered call each time, not a default and being able to talk a student through the reasoning.

Three questions are worth working through together: First, does the receiving institution’s current policy actually support MOI for this student’s country, subject, and level of study? Policies here shift often, so this is worth checking fresh for each application rather than assumed from a previous case. Second, was the student’s prior study substantively delivered and assessed in English not just described as such on paper in a way that plausibly matches the demands of postgraduate or research-intensive study in the UK? Third, is an MOI-based application more likely to trigger additional verification, delay an offer, or be queried at visa stage for this particular market?

Where any of these three is uncertain, recommending secure testing alongside or instead of MOI is the safer, more defensible choice for the student’s academic readiness, and for the agent’s credibility with the institutions they work with.

Secure testing as a strategic enabler

Secure English language testing is worth repositioning, in conversations with students, as more than an entry hurdle. It supports identity validation, demonstrates genuine academic readiness, reduces institutional exposure, and gives students greater confidence going into study. Viewing testing as an unnecessary cost is short-sighted: the real cost is poor preparation academic, financial, and emotional. Framing testing as an investment in a student’s own success, rather than a bureaucratic step, tends to land better with students and parents alike and it happens to be true.

BCA reviews are raising the bar

The Basic Compliance Assessment is an annual Home Office review of how well a sponsoring institution is managing its international student population against three metrics: visa refusal rates, enrolment rates, and course completion rates. Institutions rated amber or red face restrictions including, in some cases, losing the right to self-assess English-language ability, which pushes their entire cohort toward mandatory secure testing. As English-language evidence sits upstream of all three metrics a student who was never really ready for the course is more likely to be refused a visa, to under-enrol, or to withdraw, institutions are having to demonstrate, more rigorously than before, how that evidence was gathered, verified, and judged sufficient at the point of offer, both to their own compliance teams and to UKVI itself.

Agent-sourced evidence is now squarely inside that chain of justification. As regulatory attention on institutions increases, so does attention on the English-language guidance and evidence that agents provide upstream of the admissions decision. Weak guidance creates a vulnerability that traces all the way back to an agent’s file; strong guidance protects the student, the institution’s compliance record, and the agent’s own standing with institutional partners.

Defining practice that works for students and agents

A forward-looking standard is emerging, and it rewards informed, student-centred practice, which includes:

  • Recommending the right test for the destination and programme, factoring in university acceptance, subject demands, security requirements, and timing
  • Where subscores are borderline, especially speaking and writing for postgraduate, research-intensive courses, advising testing to a margin above the stated minimum, and supporting an early retake rather than a late one
  • Treating MOI as a case-by-case judgement using the three questions above, not a standard substitute for testing
  • Communicating secure testing to students as an investment in their own progression, not a hurdle to clear
  • Keeping documentation authentic, consistent, and aligned with each institution’s current expectations, since these shift
  • Engaging admissions teams early to confirm current requirements and reduce delays

These aren’t extra burdens layered on top of an agent’s advising role they’re the parts of that role now most visible to institutions, most consequential for students, and most likely to distinguish the agents that institutions want to keep working with.

The role of agents in a changing landscape

Agents are often a student’s first trusted adviser. Their guidance shapes not just admission outcomes but a student’s confidence, performance, and ultimately their success once they arrive. Getting the English-language piece right is one of the clearest, most immediate ways an agent can add value to that relationship and one of the clearest ways to build a track record that institutions notice.

How ELSAA supports the sector

ELSAA is the English Language Standard Advisory Authority [link to https://englishlsa.com]. Our mission is to strengthen standards, improve transparency, and support risk-aware decision-making across the English-language ecosystem. We work with agents and institutions to:

  • Interpret emerging regulatory and compliance expectations
  • Identify appropriate English-language pathways
  • Reduce institutional and agent risk
  • Improve student progression and retention
  • Build trusted, future-ready recruitment practices

Agents who build this expertise put students at the centre of every decision and in doing so, strengthen their own standing with the institutions they work with. Strong English-language guidance isn’t an extra step; it’s the advantage.

The English Language Standard Advisory Authority (ELSAA) is an independent organisation dedicated to improving transparency, understanding, and informed decision-making in high-stakes English language testing. Through independent test reviews, comparative analysis, training, and advisory services, ELSAA supports universities, professional bodies, employers, and policymakers in evaluating and using English language assessments with confidence.

For additional background, please see:

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Joint sector alert sends a clear compliance message to Australian higher education and VET providers /2026/07/joint-sector-alert-sends-a-clear-compliance-message-to-australian-higher-education-and-vet-providers/ Thu, 16 Jul 2026 13:39:13 +0000 /?p=48343 There are two national quality-assurance regulators for tertiary education in Australia. TEQSA (Tertiary Education Quality and Standards Agency) is the regulatory body for Australian higher education while ASQA (Australian Skills Quality Authority) is responsible for the vocational education and training (VET) sector. There is some overlap between the two in that they jointly regulate institutions…

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There are two national quality-assurance regulators for tertiary education in Australia. TEQSA (Tertiary Education Quality and Standards Agency) is the regulatory body for Australian higher education while ASQA (Australian Skills Quality Authority) is responsible for the vocational education and training (VET) sector.

There is some overlap between the two in that they jointly regulate institutions that provide programming across higher education and VET, and they share jurisdiction over CRICOS-registered providers (the Commonwealth Register of Institutions and Courses for Overseas Students) delivering courses to international students.

The interests of the two regulators are naturally aligned in some ways, but TEQSA and ASQA rarely issue joint statements. However, earlier this month, they did just that, that they are watching how providers and agents are behaving with regards to onshore student transfers.

The joint message says:

“TEQSA and ASQA are aware of concerns that some advertising by registered providers appears inconsistent with the intent of the ban on the payment of education agent commissions in relation to onshore transfers.

“Both agencies view any attempts by providers or education agents to bypass this restriction as unacceptable and providers who are not adequately managing these risks or not meeting the relevant Standards may be subject to a compliance assessment and/or regulatory action.”

The caution speaks directly to a new rule that was introduced in January 2026, and that came into force on 31 March 2026. Under the new rule, education agents are no longer permitted to receive commissions from Australian schools and universities when an international student already in Australia (an “onshore student”) transfers from one institution to another without having completed their course with the previous provider.

The rule appears in revisions to the National Code of Practice – formally, – and it was part of a package of amendments to the Education Services for Overseas Students Act (ESOS) passed in November 2025.

The joint TEQSA-ASQA alert goes on to say that the two regulators have specific concerns in the following areas:

  • Recruitment or incentive arrangements that preserve commission-based behaviour (for onshore transfers);
  • Practices that encourage and facilitate unnecessary transfers of students from other providers;
  • Insufficient provider oversight of education agents;
  • Providers failing to declare their arrangements with third parties facilitating student transfers;
  • Improper management of data around agent activities and student enrolment, including inaccurate or delayed reporting;
  • Weak governance, controls, monitoring or record-keeping practices around recruitment and student enrolment;
  • Providers with poor risk management practices in respect of accepting higher risk students who have transferred from another provider and do not appear to be academically prepared for their new course.

The alert then outlines the compliance expectations the regulators have for providers working with agents on onshore transfers:

“Providers need to be able to demonstrate, through robust governance oversight, that their arrangements, practices and controls are consistent with the recent changes to the National Code preventing the payment of education agent commissions in relation to onshore overseas student transfers.”

TEQSA and ASQA expect all providers to undertake a check of their current processes and practices, including:

  • Reviewing agreements with education agents and other third parties;
  • Checking what education agents are promoting in-market;
  • Reviewing admissions and transfer practices to ensure they do not contravene the ban on onshore transfers;
  • Demonstrating compliance through clear policies, monitoring, and record-keeping.

The instruction concludes with a more specific warning: “Providers who are not adequately managing these risks or not meeting the relevant Standards may be subject to a compliance assessment and/or regulatory action.”

The joint alert makes it clear that TEQSA and ASQA are concerned about onshore transfers; that they expect providers to take any actions needed to address these concerns; and that they may ramp up compliance checks or other interventions going forward.

Regular readers will appreciate that this is not strictly an Australian story. Rather, the direction of travel is clear across destinations: providers should expect greater scrutiny of their international recruitment activities by governments and regulators. Implementing effective quality checks and oversight of recruitment programmes is key to compliance.

For additional background, please see:

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Ϲ Podcast: Sustainable international student recruitment from a UK-China perspective /2026/04/icef-podcast-sustainable-international-student-recruitment-from-a-uk-china-perspective/ Wed, 29 Apr 2026 02:14:11 +0000 /?p=47413 Listen in as Ϲ’s Craig Riggs and Martijn van de Veen recap some of the latest developments in our sector, including the new pressures on the ROI that students expect from study abroad and how education agents are looking at recruitment for Japan. Martijn is then joined by an expanded panel for a discussion on…

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Listen in as Ϲ’s Craig Riggs and Martijn van de Veen recap some of the latest developments in our sector, including the new pressures on the ROI that students expect from study abroad and how education agents are looking at recruitment for Japan.

Martijn is then joined by an expanded panel for a discussion on sustainable recruitment through a China-to-UK lens.

The panel includes Christina Ke, Managing Director of UOffer Global; Dave Amor, Founder and Director of Higher Insights; Jian Li, Deputy Director (Education) with the British Council; Cheryl Xu, Director of China Office for the University of Portsmouth; Kiran Patel, Senior Director Commercial and Deputy Head of China with The China-Britain Business Council; and Tony Lee, Chief Visionary Officer at Ϲ.

The discussion occurs as the UK has solidified its position as the preferred study destination for Chinese students, recently overtaking the US on the strength of its strong higher education brand and the efficiency of its postgraduate models.

However, Chinese families are becoming increasingly results-oriented, prioritising employability and return on investment over rankings alone, while the UK government’s International Education Strategy has shifted the focus toward “sustainable” growth.

This creates a new landscape where value, student experience, and strict compliance are paramount, and our panel considers what this means for UK recruitment in China going forward.

You can listen right now in the player below, and we encourage you to subscribe via your favourite podcast app in order to receive future episodes automatically.

For additional background, please see:

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UK Home Office publishes updated visa sponsor guidance for “agents and third parties” /2026/04/uk-home-office-publishes-updated-visa-sponsor-guidance-for-agents-and-third-parties/ Wed, 15 Apr 2026 17:02:42 +0000 /?p=47328 The UK government has expanded its regulatory oversight for British institutions’ engagement with education agents. 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…

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The UK government has expanded its regulatory oversight for British institutions’ engagement with education agents.

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:

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Australia moving to wider sharing of education agent data /2026/02/australia-moving-to-wider-sharing-of-education-agent-data/ Thu, 26 Feb 2026 18:59:00 +0000 /?p=47045 On 28 November 2025, the Australian House of Representatives passed the Education Legislation Amendment (Integrity and Other Measures) Bill 2025. The bill includes amendments to the Education Services for Overseas Students Act (ESOS) with the goal, the government says, of strengthening “the integrity of the international education [to] ensure it maintains its social licence.” Those…

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On 28 November 2025, the Australian House of Representatives passed the Education Legislation Amendment (Integrity and Other Measures) Bill 2025. The bill includes amendments to the Education Services for Overseas Students Act (ESOS) with the goal, the government says, of strengthening “the integrity of the international education [to] ensure it maintains its social licence.”

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:

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Australia introduces new rules restricting agent commissions for onshore student transfers /2026/01/australia-introduces-new-rules-restricting-agent-commissions-for-onshore-student-transfers/ Wed, 21 Jan 2026 20:26:16 +0000 /?p=46837 As of 31 March 2026, education agents will no longer be permitted to receive commissions from Australian schools and universities when an international student already in Australia (an “onshore student”) transfers from one institution to another without having completed their course with the previous provider. Up to this point, institutions or schools have been able…

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As of 31 March 2026, education agents will no longer be permitted to receive commissions from Australian schools and universities when an international student already in Australia (an “onshore student”) transfers from one institution to another without having completed their course with the previous provider.

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:

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