Chief commissioner of TEQSA, Peter Coaldrake, outlined in a letter the “significant” compliance risks institutions face in international student recruitment, admission and support, as the agency is “investigating risks” to compliance with several providers.

The risks include students changing providers shortly after arrival in the country (often using onshore recruiters), unethical recruitment behaviours by some education agents and “inadequate information” to overseas students during recruitment, Coaldrake said.

All institutions registered in the CRICOS list of providers “have obligations to protect and enhance Australia’s reputation for quality education”, Coaldrake continued.

Any failure to meet obligations means that the international community loses confidence in Australian education, he warned as he pointed to the importance of overseas students for diversity, financial sustainability and research capabilities for institutions.

“As a sector it is important for us to ensure we protect the integrity of our international education,” he wrote on August 11.

“It is important for us to ensure we protect the integrity of our international education”

TEQSA urged institutions to ensure robust admissions and student support processes and procedures mitigate and identify key risks, in addition to ensuring recruitment targets “are appropriate”, with operational separation between teams and key performance indicators for recruitment and admissions.

Institutions must also “effectively manage risks associated with substantial and/or rapid growth in the number of international students, exposure in key markets and any consequent risks on your institution’s financial position”, he continued.

The agency also wants institutions to exercise “effective oversight and management” of education agent behaviour, “both onshore and offshore”.

Australia’s agent regulations are regarded as some of the toughest in the world, Oliver Fortescue, partner at Edified, reminded.

“Even with these in place Australia sees the same kinds of practices that are seen in countries with significantly less agent quality assurance in place,” he told The PIE.

Speaking with The Australian, International Education Association of Australia CEO Phil Honeywood said that the warning was “long overdue”.

It is likely that higher education institutions would welcome the increased focus on “what has been a vexing problem for many years”, Fortescue noted.

Honeywood suggested that Australian authorities could learn from Canada, where the regulator has been “becoming more vigilant”. Earlier this year, Canada identified an unscrupulous agent that had duped up to 700 students with fake admission letters.

There are also concerns in the sector that the Department of Home Affairs, TEQSA and ASQA are not effectively using powers under current regulatory settings.

Condition 8202 of the student visa (subclass 500) states that a student switching providers must maintain enrolment in a provider that is either the same level or higher in the Australian Qualifications Framework as they were originally granted their visa for.

Stakeholders say that many of the issues around switching providers could have been avoided if this power had been enforced.

Institutions also seek to recruit students from other providers. Torrens University for example offers an New Alternate Pathway Scholarship giving any students that switch after six months a 35% discount on tuition fees.

According to The Australian Financial Review, more than 20 providers have been identified as being significant poachers of students once they are in Australia. There is no suggestion that Torrens is included among those institutions.

Debate is also continuing around the role of agent aggregator platforms, as well as the use of sub-agent networks. Detractors warn that aggregator platforms mean that institutions do not have written agreement with each education agent, which TEQSA said providers should have in its November 2022 update.

Institutions should publish a “correct and up-to-date” list of the agents they have contracts with on their websites, the regulator has said.

Those in the sector who are supportive of aggregator platforms, such as John McPartland, vice president for international at Global Study Partners, say that referrals from other agents is a “long-established practice”. Others say that agent contracts have long included clauses that ban the use of sub-agents but suggest that the clauses have been overlooked or ignored.

“The difference is the professional aggregators are transparent about it,” McPartland wrote online.

Universities say they will sanction any underperforming agents, meaning current regulations in Australia are sufficient.

Recent analysis by agent risk management platform AgentBee found that numbers of sub-agents claimed by aggregator platforms has “remained stable in the first half of 2023”, with Adventus.io rising to 8,000+ agents by late May 2023 from 7,000+ at the start of the year.

Both KC Overseas and Shorelight have dropped, with KC Overseas decreasing from 9,000 to 3,000 “highly active” sub-agents and the latter’s website reporting a decrease from 7,000 to 3,000.

The latest update from TEQSA – which doesn’t mention aggregator platforms – says it has “observed an increase in potential indicators of risk” with respect to institutions’ obligations, especially under relevant ESOS and migration legislation. It added that its findings suggest that “overseas student recruitment and admission practices across the sector are not adequately robust, and risks are not being effectively monitored and managed”.

Along with increases in student transfers, unethical recruitment and lack of information during recruitment, TEQSA said that students may have been recruited without appropriate qualifications or academic preparedness and they might not be bona-fide or comply with the terms of their visa.

There is an increase in non-commencements, incompletion rates and visas not being granted, inadequacies in identifying, notifying and assisting overseas students at risk of not meeting course progress requirements and improper management of enrolment data, including inaccurate or delayed reporting, it added.

Without timely, accurate and regular reports, key decision-makers will not understand risks to overseas student compliance, it said.

Fortescue added that the majority of students traveling to Australia study, comply with visas and are “a fantastic addition to the country”.

“Similarly, most contracted agents working with Australian HE providers operate ethically to support these students achieve their education goals and are an essential and disrespected part of the international education industry.

“Australian HE providers generally have world class agent management practices in place”

“In my opinion Australian HE providers generally have world class agent management practices in place but even the best operations are sometimes susceptible to unethical agent practice and/or unethical students that use their visa success reputation to gain access to the country.”

The sector is “challenged by a small number of providers that advise international students to leave their primary HE providers for lower cost alternatives, often in breach of their visas”, Fortescue added.

“Sadly, these kinds of practices are damaging the reputation of the whole sector and present a challenge to all the major recruiting countries.”

Education counsellors in India have also warned that dishonest players are ‘damaging’ the reputation of the industry.

Independent Tertiary Education Council Australia Higher Education is one body that has been working at governmental level to strengthen the integrity of the student visa system, according to ITECA chief executive, Troy Williams.

Its members say students should faithfully complete their studies with the institutions their original visa was with “unless exceptional circumstances apply”.

“The need for a registration framework for international student visa agents is a policy reform that ITECA Higher Education, and the broader ITECA network, has championed for some time,” Williams told The PIE.

“Students and institutions are let down by agents that are only interested in a quick buck, that’s why ITECA Higher Education has argued for reforms that put students at the heart of the higher education system.”