A CPD session that revealed gaps in migration practices
A CPD session that revealed gaps in migration practice.
Six things came out of that room. We are developing Educli to fill this gap.
A recent CPD session on handling MARA complaints and investigations was scheduled as a technical walkthrough. What it actually delivered was a candid picture of where Australian migration practice stands, and a list of structural gaps the profession has been carrying for years without a systematic response.
This post is what came out of that room. Six observations from the session, what each one means for the profession, and how Educli is being built to close them.
1. The complaints process runs on documentation. Most practices are not ready.
The session’s central message, repeated in different forms across every topic, was this: when OMARA comes, it asks for your records. Contracts. Correspondence. File notes. A complete timeline of what happened, when it happened, and what was communicated to the client at each stage.
Not because regulators are adversarial. Because that is the only way to evaluate a complaint fairly, on evidence and not on memory. An agent who cannot produce a coherent file is not necessarily a bad agent. But in a complaint scenario, they are an exposed one.
The standard is not “I remember what I advised.” The standard is “I can show you, timestamped, what I advised, when I advised it, and that the client received and acknowledged it.” Those are different things. The gap between them is where most complaints find traction.
Speed of response to OMARA requests was also emphasised. Investigations are time-limited. An agent who can produce a clean, organised file quickly sends a signal about the practice. An agent who cannot, even if ultimately exonerated, has already framed the investigation adversely.
How Educli closes this gap: The PROOF Engine captures every client interaction: notes, documents, correspondence, status changes, automatically as work happens. Not as extra admin. The audit trail is a by-product of the practice running normally. When OMARA requests a file, the export is ready.
2. Financial management and trust account handling are a high-risk area.
This one landed with weight in the room. Financial management, including fee disclosure, client account handling, billing records, and in some practices trust accounting, is one of the areas where complaints most commonly have merit and where agents are least well-prepared.
The Code of Conduct obligations are specific. Written cost disclosure before work commences. Clear separation of practice funds from client funds where applicable. Invoices that correspond to work actually performed and agreed in the service agreement.
Most agents use separate accounting software for billing. The problem is that when a complaint arrives, financial records and case records exist in different systems. Reconstructing a coherent picture of what was agreed, what was invoiced, and what was paid, across the timeline of the case, becomes manual, slow, and incomplete.
There is also a gap in how agents document the cost agreement itself. Verbal agreements are not agreements OMARA can examine. A signed service agreement with a clear fee schedule, linked to the client file, is the only form that holds up.
How Educli closes this gap: Financial management is a core layer in the platform: instalment plans, invoicing, Xero sync, and fee disclosure linked directly to the client file and service agreement. The cost agreement is part of onboarding, not a separate document to chase. This is one area where Educli covers a gap the market has not fully addressed.
3. Client risk assessment at intake is not happening systematically.
The session made a point experienced agents know but rarely formalise: a significant proportion of complaints involve clients who should not have been taken on, or who were taken on without adequate assessment of the risks involved in their case.
This is not a criticism of agents. It is a structural problem. Most practices do not have a formal intake risk assessment process. The decision to take on a client, and what to advise them at the point of engagement, happens informally, often under time pressure, and is rarely documented.
A documented risk assessment at intake serves two functions. First, it forces a structured evaluation of the client’s circumstances before any commitment is made: visa history, character issues, complexity of pathway, client’s realistic expectations. Second, it creates a record that the agent identified the risks, advised the client of them, and obtained informed consent to proceed.
The client you say no to is as important as the client you say yes to. Turning down work you cannot properly service is a Code of Conduct obligation, not a commercial choice. A documented decision not to proceed is also protection.
How Educli closes this gap: A structured intake risk assessment tool linked to the client file is on the Educli development roadmap. In the meantime, a consistent intake checklist used at every initial consultation and stored in the file is the practical minimum. We have a template available as a free resource.
4. Nobody is teaching agents how to run a practice as a business.
This was said directly in the room. Not as a critique of the profession, but as an observation about the CPD market. Agents are well-served with content on visa law, legislative updates, and procedural compliance. They are almost entirely unserved with content on how to operate the business side of their practice: systems, delegation, financial management, practice growth, and handling difficult client situations professionally.
The qualification that produces a MARA-registered agent teaches migration law and procedure. It does not teach practice management. So agents enter the profession with strong technical knowledge and almost no operational framework for running a compliant, sustainable practice. They build it through trial and error, which is expensive, slow, and exposes them to exactly the kind of complaints the session was discussing.
This is the premise Built to RUN™ was developed on. It is not a theoretical framework. It is the operating system that came out of running a practice, founding a CRICOS provider, and seeing where the gaps actually sit.
5. Handling client complaints before they reach OMARA is an underdeveloped skill.
The session covered the formal complaints process in detail. But a quieter point landed with more force: most complaints that reach OMARA should never have got there. The client raised a concern. The agent dismissed it, delayed responding, or handled it in a way that escalated rather than resolved.
Clients who feel heard rarely escalate. Clients who feel ignored almost always do.
A written internal complaints procedure is an OMARA expectation. It does not need to be complex. Document who the client contacts, who reviews it, what the timeline is, and what outcomes are possible. Acknowledge within two business days. Respond substantively within ten. Log every complaint regardless of outcome.
The skill is not the procedure. The skill is handling the moment when a client is angry, feels wronged, and is looking for a reason to escalate. That is not a compliance question. It is a professional one. And it is almost entirely absent from CPD content.
How Educli closes this gap: A dedicated CPD session on managing client complaints professionally, from first contact to resolution, is on the Educli development list. It would qualify for ethics category CPD and address something the market is not currently being taught.
6. Agents are isolated. They want peer connection, not more content.
This came up organically, not as a structured topic. The discussion in the room kept returning to one thing: agents do not have anywhere to talk to other agents about the operational reality of running a practice. Not the legislation. Not visa processing. The harder questions: how do you handle a client who lies to you, what do you do when a staff member underperforms, how do you price yourself when the market is pushing downward.
CPD content does not fill this gap. It cannot. The gap is not information. It is the professional isolation of running a small practice in a specialised field where most people outside the room do not understand what the work actually involves.
Not a Facebook group. Not a forum. A small, structured peer community of agents who are serious about building practices that work, with a regular cadence, shared accountability, and the ability to ask the questions that do not have a CPD module.
The RUN™ Network is the answer to this. It is in development. When it launches, it will be a small invitation-only cohort, not designed for scale but for signal quality. The agents who join the first cohort will shape what it becomes.
What the room confirmed
Six signals. Three of them are structural practice problems every agent faces, and that Educli was specifically built to address: documentation, financial management, and client risk assessment. Two are content gaps the CPD market has not filled, and that Built to RUN™ is designed to close: business practice education and client complaint handling. One is a community need that sits above both, and that the RUN™ Network is being developed to answer: peer connection.
None of these are new problems. They came out of a room of experienced practitioners at a CPD session. Which means they are problems that have been sitting in the profession for years, quietly generating complaints, investigations, and stress, without a systematic response.
The Built to RUN™ thesis is that these problems are connected. They do not exist in isolation. An agent with proper systems, a clean financial layer, a documented intake process, and a peer group to test their thinking against is not a more compliant agent. They are a fundamentally different kind of practitioner, one who does not need to fear a complaint because the practice was built to answer it.
Six things came out of that room. Educli is being developed to fill every one of them.
If any of the six signals above described your practice, start here.
The Practice Maturity Index is a free 4-minute diagnostic that measures your practice across five dimensions: systems, technology, compliance infrastructure, financial management, and practice independence. It tells you exactly which level your practice is at and what the specific gap is to the next level. No obligation. Useful regardless of what you do next.
Take the PMI, free, 4 minutes →This post reflects observations from a CPD session attended in April 2026. It is not legal advice and does not constitute advice about specific OMARA complaint or investigation matters. For specific regulatory concerns, seek independent legal advice.
Jan Karel Bejcek is the founder of Educli, a practice management and compliance operating system for MARA-registered migration agents. MARN 0965239. Registered since 2009.