Agent commissions shift every provider needs to understand

Under the latest ESOS and National Code amendments, agent commissions are no longer treated as just a commercial arrangement. They are now viewed as a regulatory integrity issue. The biggest compliance risk right now is not recording those correctly.

From 31 March 2026, commissions for most onshore student transfers are banned.

In simple terms, commissions are now seen as:
• a risk signal
• a behavioural incentive
• a compliance issue

If a student has already commenced with another provider and is recruited onshore to yours, paying commission will generally not be allowed.

This has major implications for:
• cookery and trade pathways
• onshore conversion models
• “rescue transfer” recruitment
• agent commission structures

Going forward, regulators will expect providers to answer simple questions:

• Why was this commission paid?
• What behaviour did it incentivise?
• Was the student already studying elsewhere?
• Is it consistent with your agent agreement?

If the answer is “that’s how we’ve always done it”, that won’t be enough anymore.

The reality is simple: Commissions are now a governance decision, not just a finance decision.

if you want to quickly check your compliance risk:

Take the free ESOS / Agent Commission Risk Assessment  https://www.educli.com/en/agent-assessment/quiz

It takes 3 minutes and shows whether your current agent practices would likely pass regulatory scrutiny.

#InternationalEducation #ESOS #CRICOS #EducationAgents #StudyInAustralia #HigherEducation #VET #Compliance #Educli