The 1 April 2026 – Change for Migration Agents
The 1 April 2026 Regulatory change: What the Four New Instruments Actually Change for Migration Agents
A preview of this week’s Built to RUN — the fortnightly newsletter for migration agents who want to understand how the system actually works
On 1 April 2026, the regulatory framework governing registered migration agents changes for the first time in nearly three decades. The Migration Agents Regulations 1998 are replaced. The instruments that have governed CPD since 2017 and entry qualifications since 2018 are replaced. This is a preview of this week’s Built to RUN. Here is what each instrument actually says — and what it means for your practice.
Four instruments take effect simultaneously. Two are principal regulations made by the Governor-General. Two are legislative instruments (LINs) made by Assistant Minister Julian Hill. Together they replace a regulatory suite that, in its original form, has been in place since the Migration Agents Registration Authority was established in the late 1990s:
- Migration Agents Regulations 2026 (F2026L00118)
- Migration Agents Registration Application Charge Regulations 2026 (F2026L00119)
- LIN 26/001 — CPD Activities, Approval of CPD Providers and CPD Provider Standards (F2026L00244)
- LIN 26/002 — Specified Courses and Exams for Registration as a Migration Agent (F2026L00245)
The government’s own description is that the new instruments contain “contemporary language and updated references.” That framing undersells some of what has changed — particularly for CPD. Let’s go through each material change in turn.
Change 1 — Ethics and Code of Conduct CPD is now mandatory.
Section 7 of LIN 26/001 specifies two categories of mandatory CPD. The first is at least 5 points from Category A activities. The second — new — is at least 1 point from an activity covering ethical standards for migration agents, and at least 1 point from an activity covering the Code of Conduct. That is a minimum of 2 mandatory ethics and conduct points, both drawn from Category A or B activities.
Previously, ethics and Code of Conduct were included in the list of eligible CPD topics — but there was no requirement to actually complete them. An agent could satisfy the full 10-point requirement entirely through visa law updates, business practice sessions, or migration procedure activities without ever touching ethics or conduct content.
That is no longer possible after 1 April. Of your 10 points, at least 2 must now come from activities specifically covering ethical standards and the Code of Conduct. Your CPD plan needs to be structured around this requirement from the start of your renewal year, not retrofitted at the end.
Practical action: Check whether the CPD activities you have already booked or completed this year specifically cover ethical standards and the Code of Conduct. If not, identify approved activities that do and complete them before your renewal application. Note that agents holding an Australian legal practising certificate are exempt from section 31 requirements — their CPD is governed by their legal professional association.
Change 2 — The online CPD daily cap drops from 10 to 6 points.
Section 6(2) of LIN 26/001: an activity is worth a maximum of 6 points in any continuous 24-hour period where the activity is undertaken through online learning. The previous IMMI 17/047 instrument set this cap at 10 points.
Since the total CPD requirement is 10 points per renewal, an agent doing all their CPD online previously could complete the entire requirement in a single day. That is no longer possible. Online-only approaches now require at least two separate 24-hour periods — 6 points on day one, a minimum of 4 on another day.
This change is a deliberate quality signal. Regulators have looked at how CPD was being consumed and concluded that a single concentrated online session does not represent genuine professional development. The 6-point cap forces engagement across time rather than allowing a single-session tick-and-flick approach.
Practical action: If you currently complete all your CPD in a single online session close to renewal, restructure your approach now. Plan at least two separate CPD days across the renewal year. This also gives you more flexibility to satisfy the new mandatory ethics and conduct requirements separately from your general CPD points.
Change 3 — Private study activities must be completed within 12 months of enrolment.
Schedule 1, Item 4 of LIN 26/001: private study with assessment — a Category B activity — must be completed within 12 months of the date of enrolment. There was no equivalent completion deadline in the 2017 instrument.
Private study activities — self-paced online modules with an assessment component — have been a convenient CPD vehicle partly because they could sit uncompleted without any deadline. Agents could enrol in an activity during one renewal cycle and complete it in a later one. That flexibility is removed.
If you are currently enrolled in a private study CPD activity, the clock on that 12-month deadline begins from your enrolment date under the new rules. Activities commenced or completed on or before 30 June 2026 are protected by the transitional provisions in section 11 of LIN 26/001 — old rules apply to those for renewals lodged between 1 April 2026 and 31 March 2027.
Practical action: Check whether you have any private study CPD activities enrolled but not completed. If so, identify their enrolment date and complete the assessment before the 12-month deadline. Do not let modules lapse — they will no longer count, and you will need to re-enrol.
Change 4 — The approved education provider list has been consolidated.
Section 6 of LIN 26/002 specifies seven programs as prescribed courses: Graduate Diplomas at Murdoch University, Victoria University, Griffith University, Western Sydney University, UTS, and Australian Catholic University, plus the Master of Australian Migration Law and Practice at Australian Catholic University. Graduate Certificates from ANU, Griffith, Murdoch, and Victoria University remain accepted only if completed before 1 January 2018.
No new Graduate Certificate completions qualify for registration. The entry pathway is now firmly Graduate Diploma or higher. This reinforces the trajectory that has been in place since 2018 and closes off any remaining ambiguity about whether shorter qualifications remain viable entry routes.
There is one transitional note worth flagging. Griffith’s Master of Australian Migration Law and Practice — not listed among the current prescribed courses in section 6 — is available as a transitional pathway under section 11 where the course commenced before 1 April 2026 and was completed before that date or within 12 months of commencement. Current Griffith Master’s students have a protected pathway to registration.
Practical action: If you are advising anyone on the path to becoming an RMA, verify that the program they are enrolled in or considering is on the prescribed list in section 6 of LIN 26/002. If they are mid-way through a Griffith Master’s, confirm whether the transitional provision in section 11 covers their expected completion date.
Change 5 — English language requirements have been restructured for new applicants.
Section 7 of LIN 26/002 creates two pathways. Applicants who completed secondary and tertiary education in English-medium institutions in Australia, Canada, New Zealand, Republic of Ireland, Republic of South Africa, UK, or USA need only complete the Capstone Assessment. Everyone else must complete the Capstone plus an approved English language test. Six tests are accepted: IELTS Academic (overall 7.0), PTE Academic (overall 63), TOEFL iBT (overall 91), C1 Advanced (overall 178), LanguageCert Academic (overall 73), and MET (overall 62). English language test results must be within 3 years of the registration application date.
The addition of LanguageCert Academic and MET to the accepted test list gives applicants two additional options beyond the familiar IELTS and PTE. Most tests require all band scores to be achieved in a single sitting — IELTS Academic and MET are the exceptions where component scores can be combined across sittings.
The TOEFL iBT transitional provision (section 12) is significant for anyone who has recently sat the test. The current Schedule 1 minimum is overall 91. Applicants who sat TOEFL before 1 April 2026 or within 3 months of commencement can use an older benchmark — overall 94 with per-component minimums of 20 (listening), 19 (reading), 24 (writing), and 20 (speaking) — as long as the test was taken within 2 years of the registration application date. Note that the transitional TOEFL benchmark is higher, not lower, than the new Schedule 1 minimum. If your TOEFL result exceeds 91 overall and meets the new per-component minimums, you can apply under the new rules regardless.
Practical action: If you are preparing a registration application that requires an English language test, cross-check your test result against both the new Schedule 1 minimums and the transitional TOEFL provision to determine which path works in your favour. Ensure the test date is within 3 years of your intended application date.
Change 6 — The Notice of Intention requirements have been updated.
Section 28 of the Migration Agents Regulations 2026 sets out the notice requirements for people intending to apply for registration. The notice must be published on the MARA website for at least 30 days and must include the applicant’s full name, any other name by which they are or have been known, citizenship, mailing address, and details of any intended employer or proposed business name.
The substance of the notice requirement is largely carried over from the 1998 regulations, but the detail is more explicit about what information must be included — particularly the requirement to disclose any other name by which the applicant is or has been known. This is a transparency measure and is likely connected to identity verification concerns that have emerged in recent years.
Practical action: If you are advising a new registration applicant, ensure the Notice of Intention filed with MARA includes all required fields under section 28 of the new Regulations — including disclosure of any alternative names. Notices published under the old regulation 4 before 1 April 2026 are protected by the transitional provision in section 61 of the Migration Agents Regulations 2026.
Registration fees from 1 April 2026
The Migration Agents Registration Application Charge Regulations 2026 set the following fees. A person is applying for repeat registration if they have previously been registered within the 3 years before the current application.
| Application type | General charge | Non-commercial charge |
|---|---|---|
| New registration (not repeat) | $1,760 | $160 |
| Repeat registration | $1,595 | $105 |
Non-commercial charges apply where the agent provides immigration assistance solely on a non-commercial basis. Agents currently registered on non-commercial terms are protected by the transitional provision in section 9 of the Charge Regulations — the 1998 rates continue to apply for the remainder of their current registration period.
The transitional provisions in LIN 26/001 create a genuine buffer for agents who are mid-cycle at commencement. If you apply for repeat registration between 1 April 2026 and 31 March 2027, you may include CPD activities commenced or completed on or before 30 June 2026 — and those activities are assessed under the old rules. That means more than 6 online points in a 24-hour period can count if earned before 30 June, and the ethics and conduct mandatory requirement can be met with 1 point each from pre-30 June activities.
After 30 June 2026, all CPD activity is assessed under the new rules regardless of when your renewal falls. Plan accordingly — if your renewal is in the second half of 2026, you have until the end of June to complete activities under the old framework.
This post is the teaser. The full practitioner’s guide drops in this week’s edition.
The newsletter covers the transitional provisions in full, the CPD activity table with points and conditions, the complete English language score requirements for new applicants, and what these changes mean for how you structure your practice going into the next renewal year. Fortnightly. No noise. Written for agents who want to understand how the system actually works — not the spin, the mechanics.
Subscribe to Built to RUN →Sources: Migration Agents Regulations 2026 (F2026L00118); Migration Agents Registration Application Charge Regulations 2026 (F2026L00119); LIN 26/001 — Migration Agents (CPD Activities, Approval of CPD Providers and CPD Provider Standards) Instrument 2026 (F2026L00244); LIN 26/002 — Migration (Specified Courses and Exams for Registration as a Migration Agent) Instrument 2026 (F2026L00245). All instruments registered on the Federal Register of Legislation, commencing 1 April 2026.
This post provides general information only and is not legal advice. Verify all requirements directly with MARA before making registration or CPD decisions.
Jan Karel Bejcek is the founder of Educli, a workflow management and compliance operating system for MARA-registered migration agents and CRICOS education providers.