Ministerial Direction 115: What Private VET & ELICOS Providers Need to Know

The Australian Government has released Ministerial Direction 115 (MD115), which will replace MD111 and take effect on 14 November 2025. This directive introduces a new framework for prioritising offshore student visa (subclass 500) applications, aligned with the National Planning Level settings for 2026 and beyond.

While MD115 is not labelled as a “cap,” it creates a priority-based processing order that will significantly influence how quickly visas are granted—particularly for private VET providers relying on offshore markets.

How the New System Works

MD115 ranks offshore student visa applications according to each provider’s PRISMS enrolment numbers, compared to their indicative allocation of new overseas student commencements for that calendar year.

Once a provider reaches certain milestones, visa processing priority changes:

Provider Position	Processing Category
Less than 80% of allocation	Priority 1
Between 80% – 115%	Priority 2
Above 115%	Priority 3

Major Impacts on Private VET Providers

1. Slower visas past 80%

Once you exceed 80% of your indicative allocation, students move into Priority 2, which brings slower processing and more integrity checks.

2. Recruitment must be staged

Colleges that normally process large offshore intakes at once may need to spread COEs across months to avoid triggering Priority 2 too early.

3. Competitive disadvantage against TAFE and universities

TAFEs and public universities are protected under multiple Priority 1 categories. This means they often maintain faster visa decisions for the same student markets.

4. Growing reliance on ELICOS pathways

Standalone ELICOS students are always Priority 1, regardless of allocations. For some VET providers, ELICOS-first packages may become a strategic necessity.

What MD115 Does (and Doesn’t) Change About Country Risk

MD115 does not change country-risk rankings or create new risk rules.

However:

• It allows integrity concerns to override priority.
  
• Even Priority 1 cases can slow if the student comes from a market with high refusal or fraud indicators.
  
• Medium and high-risk markets may feel pressure earlier once a provider crosses 80%.
  

How MD115 Interacts with Country-Risk Levels

Low-Risk Markets

What to expect:

• Faster decisions under Priority 1
• Good movement even in Priority 2
• Minimal integrity interventions
  

Strategy:

• Keep COEs paced to stay under 80%
• Strong documentation is still good practice
  

Medium-Risk Markets

What to expect:

• Noticeable slowdowns once you move into Priority 2
• More verification and RFIs during peaks
  

Strategy:

• Pre-screen financials, SOP, study rationale
• Pace COEs to maximise time in Priority 1
• Only release COEs to agents with high conversion and low refusal rates
• Use ELICOS-first only where necessary
  

High-Risk Markets

What to expect:

• Integrity checks can remove Priority 1 speed advantages
• More RFIs, longer triage, risk of refusal
• Priority 2 + high-risk = compounded delays, more deferrals, refund pressure
  

Strategy:

• Deep pre-screening: verified funds, interviews, career alignment
• Limit COEs per agent or market each month
• Use two-step offers (conditional → unconditional after integrity checks)
• Redirect some volume toward Pacific & Timor-Leste (always Priority 1)
  

Practical Action Plan for Providers

• PRISMS pacing plan – Schedule monthly intake targets to stay below 80% through Feb / Jul / Oct peaks.
• Market mix rebalancing – Boost low-risk and Pacific/Timor-Leste enrolments; set monthly limits for high-risk markets.
• ELICOS pathway strategy – Use ELICOS-first packages where needed to keep offshore applicants in Priority 1.
• Agent tiering – Stronger controls on COE release based on conversion and integrity performance.
• Integrity kits per country – Funds checklist, SOP templates, interview scripts, career-mapping documents.
• Refund risk control – Two-stage offers, staged invoicing, and clear defer policies.
• Monitoring dashboard – Track: PRISMS utilisation %, market risk level, refusals, RFIs, agent conversion.

Bottom Line

Ministerial Direction 115 does not change country-risk ratings, but it amplifies their impact. Once a provider moves past 80%, medium and high-risk markets are the first to feel delays.

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