It is not an “agent problem”; it’s a system problem
The recent submission by the Association of Australian Education Representatives in India (AAERI), highlighted by The Koala News, puts a spotlight on a structural weakness that many providers, recruiting from the subcontinent, have quietly inherited over the last decade – an opaque recruitment chain built on aggregators and largely invisible sub-agents.
India’s return to the highest risk level has made the concept of “not knowing who is recruiting on your behalf” increasingly problematic.
AAERI’s submission makes a simple but uncomfortable point: while institutions may contract with an aggregator, the real recruitment activity often happens several layers downstream, by individuals who are:
- not directly contracted
- not trained by the provider
- not visible in institutional records
- and often not monitored at all
Enters the ESOS Act amendment on 5 December 2025 introducing new expectations for recruitment and documentation practices, especially around agent activities. Under Standard 4 of the National Code and Section 21A of the ESOS Act, providers remain accountable for all agents acting directly or indirectly on their behalf.
That accountability chain is only as strong as the system supporting it. The concern isn’t simply about non-compliance. It’s about misaligned incentives.
Aggregator models are, by design, volume-driven. Speed and scale often take priority over student suitability, documentation quality, and long-term outcomes. In higher-risk markets, this creates the perfect conditions for:
- inconsistent advice
- undisclosed fees
- misrepresentation at education fairs
- and, increasingly, visa integrity issues
The submission also raises a critical operational reality that many providers are already feeling: How do you publicly list and monitor sub-agents if you don’t actually know who they are?
This is where the conversation needs to shift. Moving away from trust-based assumptions and towards system-based oversight:
- knowing exactly who is recruiting
- where they sit in the chain
- what information they provide
- and who are their clients
This is why agent management can no longer live in spreadsheets, inboxes, or ad-hoc declarations.
Modern agent ecosystems require:
- clear mapping of agents and sub-agents
- contract and training visibility
- application-level attribution
- performance and risk signals that surface early, not during an audit
If your recruitment model can’t be clearly explained, evidenced, and defended, the risk now sits with the provider.
From 2026, regulators won’t be asking whether you trust your agents. They’ll be asking how your systems prove it.
Check out our FREE self-assessment tool to see where you are at! https://www.educli.com/en/agent-assessment/quiz
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