Issued in late-July, AAERI warned members allowing sub-agents to apply to a provider or for a student visa on behalf of a student could lead to future reputation damage.

“AAERI is apprehensive that without suitable controls over sub-agent use… the industry will continue to endure service and compliance issues,” the advisory said.

“Education is an intangible asset, and the customer needs to be vetted”

“This practice is a dangerous trend where not only the interest of the student is compromised, but also there is a risk to the ‘Australian Education brand’ in the South Asian market.”

In its advisory, AAERI made five recommendations when using sub-agents, including that only the principal agent takes responsibility for admissions and visas and that provider includes a list of “engaged sub-agents” on their sites.

Currently, Australia education providers are required to list agencies with whom they have a contract on their website.

AAERI’s head of visa and compliance committee Rahul Gandhi said the advisory sought to protect the interests of Australian providers, whose accountability for agent behaviour has increased in recent years, after the release of the 2018 National Code.

“Australian universities devote resources in educating and training their principal agents and their counsellors who are dealing with the students,” he said.

“These efforts are wasted, and the intent fails when the principal agent purely acts as a ‘master agent with a back-office’.”

The note also said a growing number of online platforms were being used as “window dressing” to give the appearance of a business-to-business arrangement and allow sub-agents to route student applications through a principal agency.

“Anyone can buy an airline ticket or book a hotel room via various online portals and paying via credit card,” Gandhi said.

“When it comes to overseas education, can we adopt the same model across South Asia and sell education courses online without vetting the customer?”

Gandhi added these types of online booking models not only had the potential to damage the reputation of other education agents but also put students’ interests at risk.

“Education is an intangible asset, and the customer needs to be vetted based on the academic, financial and English proficiency before [they] remit fees to an overseas education provider,” he said.

“The larger goal is that we all want the student to be successful at the end of the course and without vetting, they may not be able to complete the course.”

He added the advisory note was not to dissuade sub-agent usage but to provide further guidance for principal agents moving forward.

“Subagents are part of the industry from day one… but there is a need to define the role,” Gandhi said.

“This practice is a dangerous trend”

Speaking with The PIE News, Gandhi pointed to the upcoming publication of agent performance data by the Australian Government to implement the recommendations, by using a Unique ID during all steps of the application process.

AAERI, which has aired its concerns over publishing data, has pushed for a unique agent identifier to combat onshore student churn in an effort to provide a clearer picture over the proposed visa and academic outcomes data.

“This will reduce the fraud and make the principal agent more accountable, and at the same time the Department of Education & Training’s project on agent data report will reveal an accurate picture,” Gandhi said.

Australia hosted 108,000 Indian students in 2018, and year-to-May data indicates the number will continue to grow in 2019.