Most providers still don’t know about ESOS commissions

From 31 March 2026, paying education agent commissions is no longer just a commercial decision. It’s a compliance requirement.

Under the updated ESOS / National Code framework:
-> If a student has already commenced study onshore, the receiving provider is prohibited from paying any commission for recruiting that student
-> Cancelling enrolment or reissuing a CoE does not reset this
-> Course name doesn’t matter, the provider listed on the visa CoE does
-> Non-monetary “workarounds” (bonuses, services, gifts, marketing support) must be also captured

There are a few exceptions:
– Courses are packaged at the time of application for visa
– Progression changes within that package
– Compassionate and/or compelling reasons

The reform is a deliberate attempt to stop onshore student poaching. 

It removes incentives for unnecessary transfers and forces providers to own the recruitment practices and support it with evidence.

The real risk for providers in 2026 isn’t, “Are we paying commissions?”

It’s:

“Can we explain why we paid this commission when asked?”

If your answer relies on “that’s how we’ve always done it”, you should review your strategies. 

Commissions are now a governance issue, and providers who start early will be fine. Those who don’t will learn under pressure.

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If you want to assess your agents commission management, we have created a free tool for you https://www.educli.com/en/agent-assessment 

#ESOS #InternationalEducation #Compliance #EducationAgents #StudentVisas #Governance #Educli