Sector alert: Recruitment, admission, and support of overseas students

11 August 2023

TEQSA reminds higher education providers of the importance of robust processes and mechanisms for identifying, analysing, and responding to risks regarding the recruitment, admission, and support of overseas students.


Recently, TEQSA has observed significant risks in the recruitment of overseas students which we are currently investigating. This has highlighted the importance of providers having robust recruitment and admissions processes that are supported by effective oversight and self-assurance measures.

When recruiting overseas students, under the National Code of Practice for Providers of Education and Training to Overseas Students 2018 (National Code) and the Higher Education Standards Framework (Threshold Standards) 2021 (HES Framework), registered providers have obligations. These obligations are outlined in the table below.

Obligation Standard
Recruit responsibly and ensure students are appropriately qualified for, and well-informed about, their chosen course of study Standard 2 of the National Code
Standard 1.1.1 of the HES Framework
Ensure their education agents act ethically, honestly and in the best interests of overseas students Standard 4 of the National Code
Safeguard the integrity of Australia’s migration laws by supporting overseas students in fulfilling their visa requirements Standard 8 of the National Code
Standard 7.2.3 of the HES Framework
Ensure representations of the higher education provider, its educational offerings and charges are accurate and not misleading Standard 7.1.1 of the HES Framework
Monitor the performance of agents, taking prompt corrective action in the event or likelihood of misrepresentation or unethical conduct Standard 7.1.4 of the HES Framework
Maintain updated enrolment information in the Provider Registration and International Student Management System (PRISMS) database Standard 9 of the National Code


TEQSA has observed an increase in potential indicators of risk with respect to these obligations.

These include:

  • high numbers of overseas students, after arriving onshore, transferring to other higher education providers or Registered Training Organisations (RTO), which may indicate students are being recruited:
    • without being provided sufficient information about their chosen provider, course, or life and study in Australia
    • without appropriate qualifications or academic preparedness for their course of study
    • who are not bona-fide or will not comply with the terms of their visa.
  • an increase in non-commencements, incompletion rates, and visas not being granted
  • reports of unethical behaviour by some education agents in recruiting overseas students, both onshore and offshore
  • inadequacies in policies and processes for identifying, notifying, and assisting overseas students at risk of not meeting course progress requirements
  • improper management of enrolment data, including inaccurate or delayed reporting
  • substantial and/or rapid growth, including recruitment in new markets.

Each of these suggest that overseas student recruitment and admission practices across the sector are not adequately robust, and risks are not being effectively monitored and managed.

Identifying, analysing, and responding to risks

Providers need to be able to demonstrate, through robust governance oversight. that risks related to recruitment, admission and support of overseas students are identified, analysed, and mitigated effectively.

To effectively identify these risks, TEQSA expects providers to monitor and measure the performance of overseas student cohorts. This should consider the risk profile associated with each education agent, and the performance of overseas student cohorts. This may include their country of origin, their chosen course, and the qualifications accepted for entry into that course (including English language testing and credit for prior learning).

The monitoring and management of recruitment risks should complement and draw from existing processes for interim monitoring, comprehensive reviews, external referencing, and student feedback.

Measures of performance should consider student outcomes in the first six (6) months and thereafter. TEQSA expects providers to identify students that may not have been appropriately prepared for the course, considering rates of non-commencements, incompletion, unsatisfactory course progress, and issues with English language proficiency after commencing study.

Where the provider identifies potential indicators of risk, it should seek to understand their causes. TEQSA expects providers to assess whether, and ensure overseas students are:

  • sufficiently informed about their chosen provider, course of study, life, and cost of living in Australia.
  • appropriately qualified for the course of study they are enrolled in, including English Language proficiency, prior learning, and work experience
  • provided with the support needed to help them transition to living and studying in Australia
  • are bona-fide students with a genuine intent to study in Australia and comply with all visa requirements
  • recruited ethically, responsibly, and in the best interests of the student, whether recruited directly or by an education agent.

Effective management of these risks may include, but is not limited to, a provider:

  • undertaking pro-active identification of concerning behaviour by education agents followed by prompt corrective action
  • consistently improving or enhancing the quality and accessibility of information provided to overseas students, both through education agents and directly by the provider
  • informed by active monitoring and student feedback, improving and better tailoring onshore support for overseas students to meet their needs
  • informed by academic monitoring, making amendments to course entry requirements to ensure recruited students are adequately prepared for their course of study.

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