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Home News Market Update

Are Evidence Level Changes Revealing a System No Longer Fit for Purpose?

Dirk MulderbyDirk Mulder
September 30, 2025
in Market Update
January visa grant data is down down, except Bangladesh (perhaps they didn’t get the memo)
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A brief note released by the Department of Home Affairs today via the PRISMS system indicates that evidence levels have been updated.

While no official list is ever published, there are ways of calculating evidence levels and The Koala has been made aware of information circulating through international practitioner networks which, while unverified, suggests that the following may now be occurring:

Level 1:  Bangladesh and Sri Lanka

Level 2: India, Bhutan, Viet Nam, China and Nepal

Level 3: Fiji, Philippines and Pakistan

“The formula used by our Home Affairs Department to determine country risk levels has always been regarded as one of the ‘great mysteries of the universe’ by our sector, said Phil Honeywood, CEO of the International Education Association of Australia. “The fact that one or two provinces in a student source country can skew that nation’s whole risk profile has been lamentable.”

“Given the Albanese Government is trying to put life into its Southern East Asia Strategy, then lifting Vietnam back up to Risk Level Two will send all the right messages. Conversely, having The Philippines, which is now our major source of Allied Health students, at Level 3 just invites other nations to recruit there to our disadvantage. China going down from Level 1 to Level 2 has come as a massive surprise.

These lists are further complicated by the fact that they are never published for fear of treading on neighbours’ diplomatic toes. However, most offshore education agents seem to be well aware of risk level changes before most stakeholders back in Australia!” he said.

So, let’s refresh, how do evidence levels work again?

Both the applicant’s country of citizenship and the education provider are assigned evidence levels, and the combination of these factors determines the level of documentary evidence required for a student visa application.

Australia’s evidence levels: institutions

Australia’s Department of Home Affairs assigns every institution registered under CRICOS (commonwealth-education providers for overseas students) an Evidence Level (sometimes called Assessment Level) — Level 1, 2, or 3. This level, combined with the applicant’s country of citizenship (which also has a country evidence level), influences how much documentation is required for a student visa under the Simplified Student Visa Framework (SSVF).

  • Level 1 = lower risk: fewer extra requirements like proof of English or detailed financial documentation.
  • Level 2 = moderate risk: more documentation might be required depending on country + provider combo.
  • Level 3 = higher risk: stricter evidence requirements and more scrutiny.

If a provider doesn’t have enough visa/outcome data (below a certain threshold), a default level is assigned. For many smaller providers, that will often be Level 2. For small countries lacking data, default is often Level 3.

Australia’s evidence levels: country

Just like education providers, every country is also given an evidence level — 1, 2 or 3. These levels aren’t assigned at random. Instead, they’re based on how students from that country have fared in the past with Australian visas. Home Affairs looks closely at patterns such as visa cancellations, refusals, students overstaying their visas, or those who go on to apply for protection visas after studying.

The same indicators are applied when assessing institutions, with the heaviest weighting placed on refusals linked to fraud — which count for 40 per cent of the overall score.

How country + provider levels interact

When a student applies for a visa, Home Affairs looks at both levels together:

  • Low risk + low risk (Level 1 country + Level 1 provider): streamlined, minimal extra evidence required.
  • Mixed (e.g. Level 1 provider + Level 3 country): applicant may be asked for extra documents (English test results, financials).
  • High risk + high risk (Level 3 country + Level 3 provider): strictest requirements, greater scrutiny, and more chance of delay or refusal.

Why country evidence levels matter

Students from countries with a higher evidence level face a tougher road when applying for visas. Even if they are accepted into a well-known university, they can expect to be asked for more documentation — from proof of English language ability to detailed financial statements — before their application is approved.

In contrast, students from lower-risk countries enjoy a much smoother experience. Applications are often processed faster and with fewer hurdles, particularly when they are heading to a Level 1 provider. This combination of low-risk country and institution gives students the greatest chance of streamlined visa approval.

At its core, the evidence level system is about managing risk. By tightening requirements for certain applicants, the government aims to address areas where visa breaches, fraud, or overstaying have been more common in the past. It’s a targeted approach designed to protect the integrity of Australia’s international education system while still keeping the doors open to genuine students.

Sector continues to warns current settings encourage gaming the system

The visa-hopping dilemma currently plaguing the Australian education system becomes apparent upon understanding the information above.

Many students initially apply to Level 1 institutions, where visa applications typically undergo less rigorous scrutiny than those linked to Level 3 providers. Once onshore, these students often leverage the visa granted to transfer to other institutions.

Voices in the sector often claim that proof of funds when applying for a Level 1 institution are not consistently verified. Neither are English requirements. Therefore, a loophole exists where students can minimise the amount of information presented to the Australian government on their application, and once onshore, move institutions.

This loophole needs to be shut down. With many suggesting that the visa should be tied to the institution, if a move is made within the first six months of being onshore, a new visa would be required at a cost of $2000. Currently, no financial penalty or disincentive is imposed.

Ravi Lochan Singh, CEO of Global Reach – a student recruitment organisation who is well known across South Asia said in a LinkedIn post, “Regarding financial evidence, I understand that streamlined cases (which will now encompass all university-bound students from my region) allow for complete visa applications without the need for financial documents or evidence. However, formal briefings by Home Affairs consistently advise that, despite the completeness of the visa application, they would prefer the inclusion of financial evidence, even in streamlined cases.

“Therefore, I am left with a dilemma. Should I celebrate the improvement in risk levels for India, Nepal, Bhutan, Bangladesh, and Sri Lanka? How will this benefit my students? Will it not exacerbate concerns about visa hopping or attrition, as students can now easily enter Australia with universities and subsequently transition to non-university sectors that are experiencing higher risk levels without the need for new visa applications?”

 

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Dirk Mulder

Dirk Mulder

Dirk Mulder is the founder of the Koala and Principal of MulderPR, a strategy and marketing communications consultancy specialising in international education. Dirk has had extensive experience in International Education and Service Management, holding Directorships at the University of South Australia, Curtin University and Murdoch University as well the Lead for International Student Initiative across the Asia Pacific region at Allianz Partners. He has been member of the boards of Perth Education City (now Study Perth) and Education Adelaide, he has chaired the Universities of Perth International Directors Forum and has been a past board member of the Hawkesbury Alumni Chapter, his alma mater. His views are widely published and quoted across the media and has been seen in Campus Morning Mail, the Australian Financial Review and ABC television and online. Acknowledgement/disclosure: Dirk holds shares in and outside of the education sector including in IDP Education.

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