The Shocking Reality: Anyone Can Become an Education Agent Without Qualifications, Licensing, or Oversight—And They Control 75% of Student Enrolments
In Australia's highly regulated education landscape, one glaring anomaly persists that threatens the integrity of the entire sector: the virtually non-existent barriers to becoming an education agent. While registered training organisations undergo rigorous audits and universities face strict regulatory frameworks, the individuals responsible for recruiting three-quarters of all international students operate in a shadowy realm with minimal accountability, oversight, or professional standards. This regulatory blind spot has created a perfect storm of perverse incentives, questionable practices, and systemic vulnerabilities that now threaten the sustainability of Australia's fourth-largest export industry.
THE REGULATORY PARADOX: STRICT OVERSIGHT EVERYWHERE EXCEPT WHERE IT MATTERS MOST
The stark contrast between how education providers and education agents are regulated reveals a fundamental inconsistency in Australia's approach to sector integrity. Australian educational institutions face some of the world's most comprehensive regulatory frameworks. CRICOS registration demands exhaustive documentation and compliance with the ESOS Act. ASQA and TEQSA conduct regular audits, issue compliance notices, and have the power to suspend or cancel registrations. Financial viability assessments, fit and proper person tests, and detailed reporting requirements create multiple layers of accountability for institutions.
Meanwhile, education agents—who influence approximately 75% of international student enrolment decisions and serve as the primary contact point for prospective students—face virtually no direct regulation. The alarming reality is that anyone can declare themselves an education agent without formal qualifications, business registration, or mandatory training. While providers must enter agent details into PRISMS (Provider Registration and International Student Management System), there is no centralised register, licensing system, or minimum competency requirements for the estimated 6,000-8,000 agents operating in the market.
This regulatory disparity creates an environment where institutions bear the compliance burden and reputational risk for agent misconduct, which they may have limited capacity to control. Recent data reveals the scale of this challenge: over 200 education providers now face visa refusal rates above 50%, with non-genuine students and agent-linked fraud identified as primary drivers. As one college owner observed, "In most regulated industries—finance, real estate, travel—you can't operate without formal structures, licenses, and professional oversight. Yet somehow, anyone can call themselves an 'education agent' without accountability."
THE MOUNTING CRISIS: NON-GENUINE STUDENTS AND VISA INTEGRITY
The consequences of inadequate agent standards have escalated dramatically in recent years, creating unprecedented challenges for Australia's international education sector. Student visa refusal rates jumped from 8.5% in 2021/22 to a concerning 19% in the first half of 2023/24, with Department of Home Affairs data identifying agent-facilitated fraud as a significant factor. This surge in refusals could lead to 91,715 fewer students in 2023/24, representing a potential economic loss exceeding $1.5 billion in tuition and related spending.
Beyond financial impacts, the "non-genuine student" phenomenon has emerged as a critical concern for sector integrity. These are individuals who view education as secondary to work opportunities or migration pathways, often guided by agents who explicitly promote these aspects rather than educational quality. The telltale question identified by many providers—"How many days do I really need to attend class?"—reflects a fundamental misalignment between visa requirements and student intentions, frequently stemming from misleading agent advice.
The scale of exploitation has been highlighted by several alarming trends. In the first half of 2023 alone, 17,000 concurrent enrolments were created—more than in 2019 and 2022 combined—enabling "course hopping" between providers, often facilitated by agents seeking multiple commission payments. Document fraud, false financial declarations, and misrepresentation of study intentions have all increased, with agent involvement identified in many cases. As visa integrity deteriorates, the reputation of Australian education suffers, creating a self-reinforcing cycle that threatens the sector's long-term sustainability.
The government response has been increasingly stringent. Financial requirements for student visas increased by 17% in October 2023, requiring students to demonstrate $24,505 in savings. The Genuine Temporary Entrant test was replaced in March 2024 with the Genuine Student Requirement, focusing more directly on study intent and logical course progression. While necessary, these measures treat symptoms rather than addressing the root cause: the lack of professional standards and accountability for the agents who serve as gatekeepers to Australia's international education system.
THE TRANSPARENCY REVOLUTION: NEW DATA REVEALS AGENT PERFORMANCE
A significant step toward reform arrived with the introduction of Agency Integrity Performance Reports in PRISMS. For the first time, education providers can access comprehensive performance data on agents, including visa grant/refusal rates, course completions, and student outcomes—even for agents they haven't previously worked with. This unprecedented transparency has begun to shift power dynamics in the sector, creating both opportunities and challenges for all stakeholders.
The implications of this data revolution are profound. Providers now have access to objective metrics for evaluating agent performance, beyond the subjective impressions and personal relationships that previously dominated selection processes. The data creates a moral and professional obligation to partner with agents based on integrity and outcomes rather than convenience or volume. For students, increased awareness of agent accountability mechanisms represents a crucial protection against exploitation and misinformation.
However, significant limitations remain in the current approach. Access to agent performance data is restricted to providers with a direct relationship to that agent, limiting sector-wide transparency. There are no mandatory thresholds for agent performance that would trigger automatic review or deregistration. The onus remains primarily on providers to monitor and act on concerning trends, creating inconsistent enforcement and potential conflicts between quality assurance and revenue generation goals.
The logical evolution of this transparency initiative would be a national, publicly accessible register of education agents with performance metrics and compliance history. This approach would align with international best practices in the United Kingdom, New Zealand, and Canada, where more robust agent oversight frameworks exist. Recent stakeholder consultations have shown growing support for such measures, balanced against legitimate concerns about commercial sensitivity and competitive positioning in the global education market.
THE HUMAN COST: STUDENT EXPLOITATION AND PROVIDER VULNERABILITY
Behind the statistics and regulatory frameworks lie human stories that illuminate the real-world consequences of inadequate agent standards. International students—often making life-changing decisions with limited information in unfamiliar legal and educational contexts—are particularly vulnerable to exploitation by unscrupulous agents. Case studies reveal disturbingly common patterns: agents withholding refunds after visa refusals, providing unauthorised immigration advice, or steering students into unsuitable courses based on commission rates rather than educational fit.
The implications extend beyond individual hardship to create systemic vulnerabilities for providers dependent on agent networks. Educational institutions caught in the crossfire face devastating consequences when associated with high-risk agents. Visa refusal rates above 50% can trigger regulatory scrutiny, potential suspension from enrolling international students, and severe reputational damage. With international education contributing significantly to institutional budgets, the financial stakes are enormous, especially for smaller private providers operating on tight margins.
Even well-intentioned agents struggle in the current environment. Without mandatory training, clear professional standards, or consistent expectations across the sector, many agents operate with an incomplete understanding of Australian regulatory requirements, course structures, or visa conditions. The absence of a formalised professional development pathway undermines the capacity of agents to provide accurate, ethical advice, even when they genuinely wish to do so.
This uneven landscape creates distinct winners and losers. Established providers with strong brands and sophisticated compliance systems can exercise greater selectivity in agent relationships. Smaller institutions may feel compelled to work with higher-risk agents to meet enrolment targets, perpetuating a cycle that endangers both student outcomes and institutional sustainability. Students from wealthy backgrounds with strong English skills can navigate the system more effectively, while those from disadvantaged contexts face heightened risks of exploitation in the absence of robust consumer protections.
REFORMS AND RESISTANCE: THE PATH TO PROFESSIONALISATION
Recent regulatory reforms have begun addressing agent-related vulnerabilities, though significant gaps remain. The ban on transfer commissions aims to curb "course hopping" by removing financial incentives for agents to encourage unnecessary provider changes. Prohibitions on cross-ownership between agents and providers target collusion and conflicts of interest that prioritise profit over educational outcomes. Enhanced VET oversight, including a dedicated integrity unit with expanded investigative powers, provides additional scrutiny of high-risk partnerships.
However, these measures address symptoms rather than the fundamental issue: the need for comprehensive professionalisation of the education agent role. A truly effective reform agenda would require several interconnected elements: mandatory licensing with minimum qualification requirements; a national register with performance data accessible to both providers and students; direct penalties for agent misconduct independent of provider relationships; and standardised training aligned with the Australian International Education and Training Agent Code of Ethics.
The path to implementation faces several obstacles. Commercial considerations create resistance from those benefiting from the current low-barrier environment. Some provider representatives argue that additional regulation could disadvantage Australia in the competitive global education market, particularly if other destination countries maintain less stringent requirements. Technical challenges exist around the enforcement of standards for offshore agents operating beyond Australian jurisdiction. Cultural and linguistic barriers complicate the creation of universally applicable standards across diverse source markets.
Despite these challenges, the weight of evidence suggests that maintaining the status quo poses greater risks than thoughtful reform. International comparisons demonstrate that stronger agent oversight frameworks in countries like the United Kingdom and New Zealand have not undermined competitive positioning and may actually enhance destination reputation by building trust in recruitment processes. The recent regulatory hardening in response to visa integrity concerns indicates that failure to address root causes will likely result in blunter, less targeted interventions that could harm both legitimate agents and providers.
THE QUALITY IMPERATIVE: BEYOND REGULATION TO EDUCATION VALUE
While regulatory reform represents a necessary step, addressing agent standards must be part of a broader conversation about educational quality and value. As one commenter noted, "Many international education providers, particularly in the VET sector, need to significantly improve the quality of their course materials. Currently, many assessments are perceived as uninspiring or even pointless, which fails to engage students or foster genuine interest in studying in Australia."
This perspective highlights a crucial dynamic: when educational value is questionable, non-educational motivations become more prominent in student decision-making. If courses offer minimal engagement, limited skills development, or poor employment outcomes, it becomes more difficult to distinguish between "genuine" and "non-genuine" students. The resulting dynamic creates a race to the bottom where price sensitivity and work rights overshadow educational quality as enrolment drivers.
Breaking this cycle requires parallel efforts across multiple dimensions. Providers must invest in meaningful, engaging educational experiences that deliver genuine value to international students. Marketing messaging should emphasise educational outcomes and skill development rather than lifestyle or migration pathways. Agent training should focus on accurately representing course content and academic expectations, creating realistic expectations among prospective students.
The introduction of stronger agent standards could actually catalyse this quality improvement process. When agents are evaluated on student course completions and outcomes rather than merely enrolment numbers, they have a greater incentive to match students with appropriate courses. Providers focused on educational quality rather than volume would benefit from more sophisticated, professional agent relationships that prioritise student success. A virtuous cycle could emerge where increased professionalism drives better outcomes, which in turn attracts more genuine students seeking legitimate educational opportunities.
CONCLUSION: PROFESSIONALISING THE GATEKEEPERS
Australia's international education sector stands at a critical juncture. The $41 billion industry supporting over 250,000 jobs represents not just an economic asset but a cornerstone of Australia's global engagement and soft power. Yet its foundations have been undermined by a fundamental inconsistency: rigorous regulation of providers alongside minimal oversight of the agents who serve as primary gatekeepers to the system.
The introduction of Agency Integrity Performance Reports in PRISMS represents an important first step toward greater transparency and accountability. However, more comprehensive reform is needed to address the root causes of current challenges. Mandatory licensing, standardised training, public performance data, and direct accountability mechanisms would align education agent standards with those in other regulated professions, creating a more sustainable and trustworthy recruitment ecosystem.
Critics may argue that additional regulation risks disadvantaging Australia in the competitive global education market. Yet the evidence suggests the opposite: countries with stronger agent oversight frameworks have maintained strong market positions while enhancing their reputations for quality and integrity. More fundamentally, the current trajectory of rising visa refusals, increasing regulatory scrutiny, and growing public concern about non-genuine students presents a far greater threat to sector sustainability than thoughtful professionalisation of agent standards.
The path forward requires balanced, collaborative approaches that recognise legitimate stakeholder concerns while addressing fundamental vulnerabilities. A staged implementation timeline, detailed consultation with industry bodies, and alignment with international best practices could create a framework that enhances sector integrity without disrupting legitimate recruitment activities. The ultimate goal must be a system where students can trust the advice they receive, providers can confidently partner with professional agents, and Australia's reputation for high-quality education is protected and enhanced.
As one industry expert observed, "If we want a sector that's sustainable, respected, and future-ready, we need to start by cleaning up our own backyard." The time has indeed come to raise the bar for the benefit of genuine students, quality providers, professional agents, and Australia's standing in global education.
