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:

• “Study highlights gaps between English standards set by test developers and those used by universities and professional bodies“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“

The post Why sharper English-language guidance is becoming an agent’s sharpest tool for student success appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

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:

• “Australia introduces new rules restricting agent commissions for onshore student transfers“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “Who decides about quality? Education agents and the question of increased regulation“

The post Joint sector alert sends a clear compliance message to Australian higher education and VET providers appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

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:

• “���Ϲ��� Podcast: Are you using the right digital channels to reach international students?“

The post ���Ϲ��� Podcast: Sustainable international student recruitment from a UK-China perspective appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

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.

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

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

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

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

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

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

AQSA adds that:

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

That additional detail is understood to include reporting on:

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

Ownership disclosures

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

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

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

For additional background, please see:

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

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

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

Background

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

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

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

A briefing from the Department of Education underscores the point:

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

Unpacking the new rules

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

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

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

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

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

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

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

Adjustment period for providers

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

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

Illustrative examples

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

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

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

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

For additional background, please see:

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

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

“Australia’s future success requires a focus on quality, integrity and a great student experience,” said Assistant Minister for International Education Julian Hill. “That’s why we’re cracking down on exploitation, increasing transparency, and safeguarding the reputation of our sector. These changes will protect genuine students and support our high-quality providers.”

Amendments for international education

The legislation steers clear of hard caps on new international student commencements and instead focuses on other mechanisms to control the quantity and quality of students coming into the country.

The amendments will also impact the delivery of offshore education by Australian educators, requiring that providers be authorised by the Tertiary Education Quality and Standards Agency (TEQSA) to operate overseas. Along with the UK and US, Australia accounts for a high share of all transnational education delivered across the world. The quality of Australian educators’ overseas courses and partnerships are thus integral to the reputation of the Australian education brand.

Another feature of Australian international education is the significant role of agents in recruiting students for universities, vocational education institutes (VET), and language schools (ELICOS). According to a recent student experience survey cited by the government, 88% of international students surveyed in 2024 used an education agent to help them study in Australia.

The legislative amendments explicitly sharpen the definitions for both making it clear that any party not in the permanent employ of an institution that engages in overseas recruitment can be classed as an agent. Similarly, the amendments spell out that agent commissions include any benefits given on behalf of an institution – monetary or otherwise – to an agent in connection with international recruitment.

The importance of those refined definitions is made clear both in the amendments themselves – which confer new powers on the Department of Education to collect and share data on agents and agent commissions – and in government communications that make it clear that some type of ban or restriction on onshore commissions is forthcoming.

It is generally expected that any such regulations will be grounded in the new legislation and detailed in upcoming changes to Australia’s National Code of Practice for Providers of Education and Training to Overseas Students.

A government communique adds that, “The new definition [of education agent] supports transparency of provider/education agent relationships and integrity in the international education sector… The new definition will enable the Secretary of the Department of Education (the department) to request information on education agent commissions paid to education agents. [It] also allows the regulators greater powers to examine cross-ownership arrangements between providers and other entities in the sector under the new fit and proper provider requirements.”

Meanwhile, the Department of Education explains that the updated definition of agent commissions, “responds to sector concerns about substantial increases in education agent commissions and the types of monetary and non-monetary payments made to agents. This has highlighted the need for greater transparency regarding agent and provider activities and interactions for the sector and for students. Introducing a definition of ‘education agent commission’ will identify the range of payment and incentive arrangements providers have with their education agents in relation to overseas or intending overseas students. This change will have complementary benefits in facilitating the sharing of accurate agent information with providers, to help providers make informed decisions in choosing ethical, high quality education agents. Greater transparency around education agent commissions will support stronger integrity in the sector.”

Finally, the legislative amendments also extend new powers to government ministries and agencies to restrict provider programming for international students, including that:

• Most prospective VET providers will now need to enrol and teach domestic students for two years before being allowed to enrol international students. This is to ensure the primary motivation for VET providers is to deliver a high quality of education and student experience – not to gain revenue from international student tuition fees. An exception is made for TAFE institutions that are government-funded.

• The Department of Education may now cancel the registration of providers that, for 12 consecutive months, do not deliver courses to overseas students. This is aimed at providers who shut down their existing business to avoid debts or regulatory penalties, then open the same kind of business without those liabilities.

• The government is also empowered to cancel entire courses due to concerns around quality or relevance to Australia’s skills needs.

The major amendments for the ESOS Act and the TEQSA Act are summarised in the following table.

Industry reaction

Australia’s international education sector generally approves of efforts to strengthen integrity in the system and to better protect students. But some believe that the provisions of the newly passed amendments are vague and really intended to obscure the real goal of constraining new international enrolments. Some industry stakeholders also decry the government’s response to . Ian Pratt, Managing Director at Lexis English, wrote on :

“After numerous Senate hearings (ignored), industry consultation (ignored, but Julian got some nice photos for his socials), peak body negotiations (largely ignored), one failed attempt in the Senate then last minute amendments by the Greens (ignored) and LNP (token, but welcome), Hill and Jason Clare MP will finally have the chance to claim some kind of victory [with Bill 2025].”

Also writing online, Sukh Sandhu, the Director, Compliance, Risk Management, and Strategic Planning at CAQA Australian Higher Education Group, offered of the legislative package and said: “At its heart, the Education Legislation Amendment (Integrity and Other Measures) Bill 2025 is trying to answer a simple public question: can Australians trust that our international education system is genuine, high quality and not being used as a back door to migration abuse?

For too long, a small but damaging minority of providers and agents have made that question harder to answer. In that sense, many of the integrity measures in this Bill are not only understandable but overdue.

Yet integrity cannot come at any cost. A regulatory system that treats every provider as a potential suspect, concentrates power without transparent safeguards, or discourages new high-quality entrants would ultimately damage the sector it is meant to protect.”

For additional background, please see:

• “Australia introduces new integrity measures through proposed amendments to the ESOS Act”
• “The next era of international education: Trust, transparency, and a focus on quality”
• “Who decides about quality? Education agents and the question of increased regulation”

The post Australia passes integrity legislation; sharpens definition of agents and agent commissions appeared first on ���Ϲ��� Monitor - Market intelligence for international student recruitment.

Since 1995, ���Ϲ��� Berlin has served as a catalyst for connecting the world through education. With our 30th anniversary approaching, our sector is facing a new challenge: the need to build better systems and standards for ensuring transparency, compliance, and student wellbeing.

In all four of the world’s leading study destinations – Australia, Canada, the UK, and the US – governments are taking a closer look at how students are recruited. From tightening visa policies and integrity audits to mandatory declarations of agent use, the message is clear: compliance and accountability are now as critical as marketing and conversion. The challenge now is to reshape how institutions, agents, and governments interact in this new context.

The next thirty years will belong to those who not only recruit globally, but who also act responsibly.

How it all began

In the 1990s, international education was still a limited, even experimental, activity. Apart from short-term language study holidays within Europe, students from a small number of countries travelled mainly to the UK and the US for tertiary studies or exchanges. Yet the soft power, innovation, revenue, and intercultural understanding generated by student mobility soon drew in many more students, institutions, and destinations. What began as a trickle of cross-border enrolments became a pillar of globalisation.

Three decades of expansion

In 2002, there were roughly 2.5 million international students worldwide, of whom more than a third came from China. By 2023, that number reached nearly 7 million, a 176% increase.

These numbers reflect a focus on growth. The expansion in outbound mobility did not only benefit schools and universities, but it also boosted governments and entire economies. In 2021/22, international student spending contributed US$52.2 billion to the UK economy and US$26.5 billion to Canada’s. In 2023/24, it accounted for US$32.7 billion in Australia and US$43.8 billion in the United States.

The benefits are not just fiscal. Nearly 60% of international doctoral students in the OECD study science or engineering. They drive research and innovation and lead major start-ups. Their collaborations consistently produce high-impact papers and cutting-edge research. In short, the mobility pipeline feeds the innovation pipeline. The lab bench does not care about passports, and the citation record proves it.

The cultural dividend of international student mobility is impossible to measure. International students bring the world closer together, forming friendships, business partnerships, and academic networks that last a lifetime. They return home as ambassadors for their host countries, carrying new languages, values, and professional skills that shape diplomacy and multilateral trade. In a world increasingly divided by politics, international education remains one of the few systems that consistently builds bridges rather than borders.

Thirty years of connection and change

Over the past three decades, ���Ϲ��� Berlin has grown alongside the industry itself, from a small gathering in 1995 to the world’s leading forum for international education partnerships. As always, the focus of the event evolves in response to changing circumstances, regulatory environments, and sectoral trends. Providing systems and structures that support greater transparency, trust, and accountability is not a new priority for ���Ϲ��� – it is a pillar of our operations. What’s more, we now offer agents and institutions more programmes and services supporting greater integrity and quality control than ever before. 

The human infrastructure behind it all

When thinking of what has driven the success of the industry so far, it would be wrong to underestimate the role of education agents. For decades, agents have helped families to navigate complex systems, translated opaque policies into clear expectations, and made international study accessible far beyond elite circles. Agents function as counsellors, logistics experts, and cross-cultural guides.

In fact, education agents have become one of the most quietly powerful forces in international education. They perform a unique dual role by guiding families through complex admissions systems and helping universities to reach more students in a diverse range of markets.

Yet as new regulatory frameworks emerge, such as the UK’s Agent Quality Framework and Canada’s pending federal registry for education agents, we risk forgetting just how much value these intermediaries create.

Guardrails but not roadblocks

No one disputes the need for higher professional standards, transparent data, and accountability. The scandals and negative headlines we have all seen in recent years show what happens when those are absent. But as it stands, policy makers have often blurred the distinction between unethical operators and legitimate, responsible businesses.

Without that distinction, the danger is that the blunt compliance mechanisms, however well intentioned, could consolidate market power among a handful of large agencies. This would leave local experts behind, and it would limit student choice. What is needed is not less oversight, but smarter oversight built on shared data, sound codes of practice, and technologies that make it easier to scale quality controls.

In this environment, voluntary accreditation frameworks such as  are helping to raise standards globally. With more than 2,300 accredited agencies in over 130 countries and nearly 700 institutional supporters across 50 countries, IAS has become the world’s largest quality-assurance framework for education agencies. It recognises businesses that meet rigorous ethical and operational criteria, providing governments and educators with a trusted benchmark of professional integrity. IAS demonstrates that accountability can be collaborative when well considered and structured.

Collaboration and systematised quality controls are essential for sustainable growth in the new era of international education. , for example, brings transparency to both sides of the recruitment relationship.

For institutions, it offers AI-powered analytics and real-time data for comprehensive due diligence checks on agent partners, flagging potential risks early by monitoring regulatory sanctions, legal filings, and social media activity.

For agents, it provides tools to protect their reputation and gain clearer visibility into their sub-agent networks, helping them demonstrate integrity and meet rising government expectations for accountability.

These innovations are supported by a broader commitment to professional development through , which today counts more than 144,000 registered learners and over 21,000 graduates across 130 countries. ���Ϲ��� Academy provides structured learning pathways for education counsellors, institutional staff, and sector professionals, making training and certification measurable and accessible worldwide.

�ճ���� platform gives educators a practical way to ensure their recruitment partners are both effective and compliant. It enables structured, multilingual training for agent networks so that every counsellor understands an institution’s background and academic offer, admissions process, ethical standards, and regulatory requirements. It also allows institutions to monitor counsellor progress and training outcomes, giving them clear visibility and measurable oversight of network-wide compliance. The platform is equally valuable for master agents, who can use it to train and inform their sub-agents.

Beyond professional development, Train Your Agents helps educators to demonstrate compliance, protect institutional reputation, and support agents with credible, up-to-date knowledge. In an era demanding transparency, it provides clear proof of responsible recruitment across the global network.

These tools are not about policing; they are about empowering international educators and promoting quality assurance. Together, IAS, Due Diligent, and Train Your Agents create a framework where integrity becomes operational, where compliance strengthens opportunity rather than constraining it.

The next thirty years

If the past three decades were about expansion, the next will be about trust. Collaboration between governments, educators, and quality agencies will be essential to achieve this.

International education remains one of the most positive forms of global exchange ever created. The small agency owner in Nairobi, Lahore, or Ho Chi Minh City, the one who knows every student’s family by name, is as vital to that ecosystem as the vice-chancellor or the minister.

At its core, international education has always been about students. We should welcome and design frameworks and partnership models that protect their dreams and ambitions while empowering responsible agents and institutions to support them safely. The future belongs to those who evolve, embrace transparency, and continue to earn the trust of the students we serve.

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