Australia to introduce an accreditation for Education Agents and why it is critical that it succeeds in chaining the onshore activities of agents. And a call being made to remove/reduce commission payments for onshore recruitment of students.

Australian Government is now funding the IEAA to carry out a feasibility study on how to operationalise an industry-led quality framework for international education agents. This is exploring the potential for an industry funded and led body which would accredit agents, monitor their performance and publish a register of accredited agents.

From what I understand the recommendations are that the system of accreditation would be voluntary for agents, however providers would be encouraged to use accredited agents. The Government is also funding the IEAA to develop an Australian Code of Ethics for international education agents, to enhance the quality and reputation of those involved in recruiting international students.

Through this blog, I highlight on how the “offshore” justification on use of education agents doesn’t necessarily argue the case for “onshore” agents.

“I have come to Australia to study an MPA and the fees at my institution is $30000 per year. I want to transfer to another institution where the fees are $15000 per year and where the attendance may be flexible. It will help if I may pay the fees in multiple instalment. Help me in changing the provider and getting the release letter.”

The above is a typical contact from an onshore student to an onshore agent.

And the question that begs an answer is:

Why is the onshore student approaching an onshore agent when he can easily walk into the institution that he desires and get an offer of place?

  • Yes, there is no need for a visa if the student is moving side-ways. Any institution (especially the low cost low quality private institutions) will happily meet the student at the door and help them make the change. The reasons are several and one of the growing ones now is that the certain onshore education/migration agents also pass on part of the commissions and some of the low quality institutions are doing most of the international recruitment through onshore poaching from other providers. Movement is mostly away from Universities and sadly the elements to attract students include low cost, multiple instalments, flexible classes and cash-back through onshore agents. Dirty? Absolutely.
  • There are a few genuine “change of provider requests” but then there too, is there a reason to engage an onshore agent? No.

An offshore agent is actually “a representative of the University representing the interest of the University in an overseas location where they are not present”. However, the onshore agent is actually “a migration agent double dipping as an agent of the student finding a program to suit the client’s migration intentions and is located in the same location as the Institution”.

 This is a major differential and thus I am now making a case for the payment for the service of the agent be made by the recipient of the service which in the case of offshore markets is the University while in the onshore locations is the student and so in other words am asking for a ban (or reduction) on payment of commission for onshore recruitment activity altogether.

Before detailing the concern with the activities of the onshore education agents, let us first understand the role of the education agent in “offshore” markets and the justification for the same:

Education Providers contact offshore education agents to assist with their promotions in the overseas markets, highlight the salient features, promote the destination country, provide career counselling, assist with applications, certifying documents after matching with the originals, provide guidance with student visa process, assist with accommodation/travel/forex along-with general pre-departure guidance. In return for the services offered by the offshore education agents, institutions pay a certain representation fee which may be fixed or a percentage. Some education representatives go beyond this role and also assist with institution to institution engagements and further take the complicated onus of verifying the financial and academic documents being put out by the student.

  • It is important to note that all through the process, the education agency is working as an “agent of the University in an overseas market” and not of the student.

Now let us understand the role of the “onshore” agents whether there is any justification for payment of commission:

Frankly none whatsoever that justifies engaging an “onshore” agent for a student who is simply changing institutions for the same or similar program of study. There is no visa to be done and if there is a need for visa extension, it is an easy process that a student is often assisted by the institutions itself. If the student needs assistance with this easy process, they may pay the migration agent a small fee. The onshore agency is not doing any background check on the student as that is not being required from an onshore student. The engagement of the onshore agent with the student is also very brief unlike that of offshore agent. It is simply that of filling up an application form and emailing to the institution. There is no accommodation services or pre-departure guidance. No verification of documents. And none of the onshore agents are equipped to assist in anything further.

  • Almost all of them are migration agents and they are only getting the students to move between institutions guided by occupations that are on SOL or generally migration outcomes. Thus if a student is seeking this kind of input from an agency, the agency becomes an “agent of the student” and not of the University and thus the payment for the services should be by the student and not by the University.

Now that you can differentiate the services offered by offshore agent and that of onshore agent, you can clearly make out that the services offered is far more by offshore representative justifying the commission payment. Institutions need to now begin to differentiate the commission paid to the onshore agents if it has to be paid at all.

In a future blog I shall detail how the US regulation of banning commission for onshore student recruitment and the NZ regulation of tying the student visa to an institution has a message for Australian policy makers.


  1. Thanks once again, Ravi. This is very interesting indeed – and sure to provoke some controversy among on-shore agents. But your point is well-made, and I assume that Universities might like it too.

    Liked by 1 person

    1. Tony, I know that it will provoke some controversy amongst onshore recruitment/migration agents but that is good. Some provocation is required as Universities that spend money in building a brand and then carrying out recruitment in offshore markets are often being disadvantaged and offshore agents who do most of the work don’t get paid too. I expect that with the proposed change to Standard 7 of the ESOS Act, which will allow student movements sideways even within the six month period, there will need to address this issue. I look forward to arguing for what I have stated… Time to bell the cat.


  2. Ravi, this is a very bothersome issue. Every time I am counselling a student, it feels like I am working for an onshore agent and giving my students on a platter to them. I can imagine how the big agents feel who spend lots on marketing/promotions/fairs etc. Students in their initial arrival in Australia are very vulnerable. Some take a year to settle down and during this transition period it is very easy to misguide a student to change his provider by luring them and paying part of the commission received by the onshore agent.Some are lured by the easy and flexible attendance in some low quality providers.I have lost many good students who went to good Universities in this year.

    Liked by 2 people

    1. What you have stated is exactly what many offshore agents face. Prior to July 2016, there was a hurdle in changing from an SVP to non-SVP and there continues to be an ESOS linked issue that restricts any movement till six months of the principle program. My concern is with the rumours that the ESOS review recommendations may include a change to the 6 month regulation which may make it easy for students to move institutions. This is where onshore touting will become a bigger concern.


  3. Ravi, it does indeed make me quite happy to hear that the Australian Government is looking at introducing a code of conduct and voluntary accreditation. All of the legitimate institutions – the ones who really don’t engage the unethical agents would adopt the new code and accreditation. It’s the small institutions that engage in unethical recruitment who would not ask their agents to adopt the code, or accreditation that need to be reined in. Have compulsory accreditation would be a great way to work around weeding out these unethical agents and institutions. Would it not be great if the accreditation could be incorporated into the ESOS Act?

    Liked by 1 person

    1. Firstly the expectation is that it will still be voluntary though education providers will be encouraged to use only accredited agents. Secondly the ESOS review is in process and my expectation too will be that it refers to the accreditation in some form.


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