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Assessment Results

Completed on 30 Dec 2025 19:27

63%

Overall Compliance Score

Critical Compliance
18

Compliant Areas

Meeting requirements
48

Gaps Identified

Requiring attention

Scores by Category

Documentation

74%

Student Support

50%

Attendance

39%

Progress

62%

Refunds

86%

Marketing

75%

Agents

64%

Complaints

66%

Governance

58%

Scores by ESOS Standard

S4.1
50%
Agent Agreements
S4.2
60%
Agent Due Diligence
S4.3
70%
Agent Marketing
S4.4
50%
Agent Misconduct
S4.5
50%
Agent List
S8.4
0%
Attendance
S8.5
0%
80% Requirement
S8.6
50%
Attendance Records
S8.7
70%
Attendance Interv
S8.9
50%
20 Days Notice
S10.1
100%
Complaints Policy
S10.2
50%
Free Access
S10.3
50%
Acknowledgment
S10.4
100%
Timeframes
S10.5
50%
External Appeals
S10.6
50%
Enrol During Appeal
S10.7
60%
Records
S10.8
50%
Natural Justice
S2.2
100%
Written Agreement
S2.1a
100%
Course/CRICOS
S2.1e
50%
Fees
S2.1f
100%
Non-Tuition
S11.1
50%
Notify Changes
S11.2
70%
Resources
S11.3
50%
Financial
S11.4
100%
Staff Quals
S11.5
75%
Facilities
S9.1
100%
DSC Policy
S9.7
50%
PRISMS DSC
S7.1
50%
Transfer Restrict
S7.2
0%
Transfer Time
S3.4
50%
PRISMS
S1.1
40%
S1.2
50%
S1.4
100%
S8.1
100%
Progress Policy
S8.2
70%
Progress Reqs
S8.3
70%
Intervention
S8.8
50%
DHA Reporting
S2.1g
100%
Refund Policy
S6.2
50%
Orientation
S6.1
50%
Pre-Arrival
S6.3
50%
Welfare Services
S6.8
50%
Critical Incident
S6.6
50%
Visa Info
S6.7
50%
Support Contact
S5.1
50%
Under 18 Policy

AI Compliance Analysis

Overall Analysis

The provider has significant compliance gaps across several critical areas, including agent management, attendance monitoring, complaints handling, and student support. Many of these issues pose high or critical risks to the provider's ability to meet its regulatory obligations and support the welfare and outcomes of international students. Urgent action is required to address these deficiencies and ensure the provider is fully compliant with the ESOS National Code.

Priority Actions

  1. Implement a comprehensive agent management system, including written agreements, due diligence checks, performance monitoring, and procedures for terminating non-compliant agents.
  2. Establish a robust attendance monitoring system that meets all ESOS requirements, including minimum 80% attendance, systematic tracking, and timely intervention for at-risk students.
  3. Revise the complaints and appeals process to ensure it is accessible, transparent, and adheres to principles of natural justice, with clear processes for external appeals.
  4. Review and update all student support policies and procedures to ensure compliance with ESOS requirements, including orientation, pre-arrival information, welfare services, and critical incident response.
  5. Conduct a full review of all policies, procedures, and documentation to identify and address any other compliance gaps, ensuring the provider can demonstrate ongoing financial viability and capacity to deliver courses.

Compliance Gaps (48)

Attendance critical
Do you systematically monitor student attendance?
Your Answer: No systematic monitoring Score: 0%
ESOS S8.4 ESOS National Code S8.4
Compliance Requirement

Provider must have a documented attendance policy for courses where attendance is a requirement.

AI Finding

The provider does not have a systematic process for monitoring student attendance, which is a critical compliance gap under ESOS National Code Standards 8.4, 8.5, and 8.6.

Recommendation

Establish a comprehensive attendance monitoring system that meets all ESOS requirements, including a minimum 80% attendance policy, accurate record-keeping, and timely intervention for at-risk students.

Attendance critical
Does your attendance policy state a minimum attendance requirement of 80%?
Your Answer: no Score: 0%
ESOS S8.5 ESOS National Code S8.5
Compliance Requirement

Attendance policy must state the minimum attendance requirement (typically 80%).

Attendance critical
Do you maintain accurate attendance records for all students?
Your Answer: Manual records updated weekly Score: 50%
ESOS S8.6 ESOS National Code S8.6
Compliance Requirement

Provider must maintain accurate attendance records for all students.

Attendance critical
Do you intervene when students are at risk of not meeting attendance requirements?
Your Answer: Warning letters and counselling offered Score: 70%
ESOS S8.7 ESOS National Code S8.7
Compliance Requirement

Provider must intervene when students are at risk of not meeting attendance requirements.

Attendance critical
Do you provide 20 working days notice before reporting students for attendance breaches?
Your Answer: partial Score: 50%
ESOS S8.9 ESOS National Code S8.9
Compliance Requirement

Provider must notify student of intention to report and allow 20 working days to access complaints and appeals.

Complaints critical
Can students access your complaints and appeals process at no cost?
Your Answer: partial Score: 50%
ESOS S10.2 ESOS National Code S10.2
Compliance Requirement

Provider must ensure students have access to the complaints and appeals process at no cost.

AI Finding

The provider's complaints and appeals process is not fully accessible, as students may be required to pay to access the process, which does not meet the requirements of ESOS National Code Standard 10.2.

Recommendation

Revise the complaints and appeals process to ensure students can access it at no cost, as required by ESOS National Code Standard 10.2.

Complaints critical
Do you inform students of their right to external appeals through the Overseas Students Ombudsman?
Your Answer: partial Score: 50%
ESOS S10.5 ESOS National Code S10.5
Compliance Requirement

Provider must inform students of their right to access external appeals through the Overseas Students Ombudsman.

Complaints critical
Do you maintain student enrolment during internal appeals for provider-initiated actions?
Your Answer: partial Score: 50%
ESOS S10.6 ESOS National Code S10.6
Compliance Requirement

Provider must maintain student enrolment during internal appeals process for provider-initiated actions.

Documentation critical
Does your written agreement clearly state total tuition fees and payment terms?
Your Answer: partial Score: 50%
ESOS S2.1e ESOS National Code S2.1e
Compliance Requirement

Written agreement must state total tuition fees payable for the course and payment terms, including deposits required.

Documentation critical
Do you have a documented process for notifying the ESOS agency of changes to your registration?
Your Answer: partial Score: 50%
ESOS S11.1 ESOS National Code S11.1
Compliance Requirement

Provider must notify the ESOS agency of any changes that may affect their registration.

AI Finding

The provider does not have a documented process for notifying the ESOS agency of changes to its registration, which is a critical compliance gap under ESOS National Code Standard 11.1.

Recommendation

Develop and implement a documented process to notify the ESOS agency of any changes that may affect the provider's registration, as required by ESOS National Code Standard 11.1.

Governance critical
Do you have sufficient resources to deliver courses to all accepted students?
Your Answer: Resources adequate for current students Score: 70%
ESOS S11.2 ESOS National Code S11.2
Compliance Requirement

Provider must have sufficient resources to deliver courses to all accepted students.

Governance critical
Can you demonstrate ongoing financial viability and capacity?
Your Answer: partial Score: 50%
ESOS S11.3 ESOS National Code S11.3
Compliance Requirement

Provider must demonstrate ongoing financial viability and capacity.

Governance critical
Do you report deferral, suspension, or cancellation to PRISMS within required timeframes?
Your Answer: partial Score: 50%
ESOS S9.7 ESOS National Code S9.7
Compliance Requirement

Provider must report DSC to PRISMS within required timeframes.

Governance critical
Do you have policies preventing active recruitment of students within 6 months of their principal course commencing?
Your Answer: partial Score: 50%
ESOS S7.1 ESOS National Code S7.1
Compliance Requirement

Provider must not actively recruit a student within 6 months of their principal course commencing.

Governance critical
Do you create CoEs through PRISMS and report changes as required?
Your Answer: partial Score: 50%
ESOS S3.4 ESOS National Code S3.4
Compliance Requirement

Provider must create the CoE through PRISMS and report any changes as required.

Marketing critical
Does all marketing material display your CRICOS registration name, provider code, and course codes?
Your Answer: partial Score: 50%
ESOS S1.2 ESOS National Code S1.2
Compliance Requirement

Marketing information must include the provider CRICOS registration name and code and the CRICOS course code for each course.

Progress critical
Do you have documented intervention strategies for students at academic risk?
Your Answer: Standard support and tutoring offered Score: 70%
ESOS S8.3 ESOS National Code S8.3
Compliance Requirement

Provider must implement an intervention strategy for students identified as at risk of not meeting progress requirements.

Progress critical
Do you report to the Department of Home Affairs when students do not meet course requirements?
Your Answer: partial Score: 50%
ESOS S8.8 ESOS National Code S8.8
Compliance Requirement

Provider must report to Department of Home Affairs if student is not meeting course requirements.

Refunds critical
Do you refund non-tuition fees in visa refusal cases?
Your Answer: partial Score: 50%
ESOS Act s47E, Refund Instrument
Compliance Requirement

Section 47E requires refund of non-tuition fees within 4 weeks of visa refusal.

Student Support critical
Do you have a documented critical incident policy with emergency response procedures?
Your Answer: partial Score: 50%
ESOS S6.8 ESOS National Code S6.8
Compliance Requirement

Provider must have and implement a documented critical incident policy with procedures for emergency responses.

Student Support critical
Do you inform students about visa conditions relating to course progress and attendance?
Your Answer: partial Score: 50%
ESOS S6.6 ESOS National Code S6.6
Compliance Requirement

Provider must provide information about student visa conditions relating to course progress and attendance.

Student Support critical
Do you have documented policies for accommodation, support, and welfare of students under 18?
Your Answer: partial Score: 50%
ESOS S5.1 ESOS National Code S5.1
Compliance Requirement

Provider must have documented policies for accommodation, support, and welfare of students under 18.

Student Support critical
Do you have documented policies for accommodation, support, and welfare of students under 18?
Your Answer: partial Score: 50%
ESOS S5.1 ESOS National Code S5.1
Compliance Requirement

Provider must have documented policies for accommodation, support, and welfare of students under 18.

Agents high
Do you have written agreements with all education agents you engage?
Your Answer: partial Score: 50%
ESOS S4.1 ESOS National Code S4.1
Compliance Requirement

Provider must enter into a written agreement with each education agent they engage.

AI Finding

The provider does not have written agreements with all education agents, which poses a high risk of non-compliance with ESOS National Code Standard 4.1.

Recommendation

Implement a system to ensure the provider has a written agreement in place with each education agent it engages, as required by ESOS National Code Standard 4.1.

Agents high
Do you conduct due diligence to ensure agents have appropriate knowledge and training?
Your Answer: Basic background checks conducted Score: 60%
ESOS S4.2 ESOS National Code S4.2
Compliance Requirement

Provider must take reasonable steps to ensure education agents have appropriate knowledge and training.

AI Finding

The provider only conducts basic background checks on education agents, which does not meet the requirement under ESOS National Code Standard 4.2 to take reasonable steps to ensure agents have appropriate knowledge and training.

Recommendation

Develop and implement a due diligence process to assess the knowledge and training of all education agents, as required by ESOS National Code Standard 4.2.

Agents high
Do you ensure agents comply with marketing requirements?
Your Answer: Periodic review of agent materials Score: 70%
ESOS S4.3 ESOS National Code S4.3
Compliance Requirement

Provider must ensure agents comply with requirements for marketing information and practices.

Attendance high
How quickly do you identify students falling below attendance requirements?
Your Answer: Within 2 weeks Score: 75%
Best Practice
Compliance Requirement

Early identification enables timely intervention and support.

Complaints high
Do you acknowledge receipt of complaints and appeals in writing?
Your Answer: partial Score: 50%
ESOS S10.3 ESOS National Code S10.3
Compliance Requirement

Provider must acknowledge receipt of complaints and appeals in writing.

Complaints high
Do you keep records of all complaints and appeals and their outcomes?
Your Answer: Records kept but not systematically tracked Score: 60%
ESOS S10.7 ESOS National Code S10.7
Compliance Requirement

Provider must keep records of all complaints and appeals and their outcomes.

Complaints high
Are your complaints and appeals processes based on principles of natural justice?
Your Answer: partial Score: 50%
ESOS S10.8 ESOS National Code S10.8
Compliance Requirement

Complaints and appeals processes must be based on principles of natural justice.

Complaints high
Are your complaints and appeals processes based on principles of natural justice?
Your Answer: partial Score: 50%
ESOS S10.8 ESOS National Code S10.8
Compliance Requirement

Complaints and appeals processes must be based on principles of natural justice.

Governance high
Do you have appropriate facilities and equipment for course delivery?
Your Answer: Facilities meet requirements Score: 75%
ESOS S11.5 ESOS National Code S11.5
Compliance Requirement

Provider must have appropriate facilities and equipment for course delivery.

Governance high
Do you assess transfer requests within a reasonable timeframe?
Your Answer: No defined timeframe Score: 0%
ESOS S7.2 ESOS National Code S7.2
Compliance Requirement

Provider must assess transfer requests within a reasonable timeframe.

Governance high
Do you assess transfer requests within a reasonable timeframe?
Your Answer: No defined timeframe Score: 0%
ESOS S7.2 ESOS National Code S7.2
Compliance Requirement

Provider must assess transfer requests within a reasonable timeframe.

Marketing high
Is your marketing information accurate and free from false or misleading claims?
Your Answer: Some review process exists Score: 40%
ESOS S1.1 ESOS National Code S1.1
Compliance Requirement

Marketing must not be false or misleading, including through exaggeration, inappropriate comparisons or misleading emphasis.

Progress high
Do you clearly articulate course progress requirements to students?
Your Answer: Requirements explained at orientation Score: 70%
ESOS S8.2 ESOS National Code S8.2
Compliance Requirement

Provider must clearly articulate course progress requirements to students.

Progress high
How often do you assess student academic progress?
Your Answer: Mid-course and end of course only Score: 40%
Best Practice
Compliance Requirement

Regular progress assessment enables early intervention.

Progress high
Do you keep evidence of compassionate and compelling decisions?
Your Answer: Informal records only Score: 30%
ESOS National Code S9.4
Compliance Requirement

Policy must include provision for deferral on compassionate or compelling grounds with evidence.

Refunds high
How do you handle refunds when students withdraw before course starts?
Your Answer: Policy exists but processing sometimes delayed Score: 60%
ESOS Act s47D
Compliance Requirement

Clear refund policy for student-initiated withdrawals required.

Student Support high
Do you provide an orientation program for new students?
Your Answer: Basic orientation materials provided Score: 50%
ESOS S6.2 ESOS National Code S6.2
Compliance Requirement

Provider must give students an age and culturally appropriate orientation program.

Student Support high
Do you provide students with access to welfare services, emergency assistance, and health services?
Your Answer: partial Score: 50%
ESOS S6.3 ESOS National Code S6.3
Compliance Requirement

Provider must give students information about and access to welfare services, emergency assistance, and health services.

Agents medium
Do you have procedures for terminating or suspending agents engaged in misconduct?
Your Answer: partial Score: 50%
ESOS S4.4 ESOS National Code S4.4
Compliance Requirement

Provider must have procedures for terminating or suspending agents engaged in misconduct.

Agents medium
Do you publish a list of your education agents on your website?
Your Answer: partial Score: 50%
ESOS S4.5 ESOS National Code S4.5
Compliance Requirement

Provider must publish a list of their education agents on their website.

Agents medium
Do you track student outcomes by agent for quality monitoring?
Your Answer: Basic tracking of enrolments and completions Score: 60%
Best Practice
Compliance Requirement

Agent performance tracking helps identify quality issues.

Documentation medium
How do you maintain student records and documentation?
Your Answer: Mix of digital and paper records Score: 50%
Best Practice
Compliance Requirement

Maintain comprehensive, accessible records for all students with appropriate retention periods.

Documentation medium
How do you maintain student records and documentation?
Your Answer: Mix of digital and paper records Score: 50%
Best Practice
Compliance Requirement

Maintain comprehensive, accessible records for all students with appropriate retention periods.

Student Support medium
Do you provide pre-arrival information and support to accepted students?
Your Answer: partial Score: 50%
ESOS S6.1 ESOS National Code S6.1
Compliance Requirement

Provider must offer students assistance to adjust to study and life in Australia prior to arrival.

Student Support medium
Do you provide students with contact details for student support services staff?
Your Answer: partial Score: 50%
ESOS S6.7 ESOS National Code S6.7
Compliance Requirement

Provider must provide details of the student support services staff member.