Further analysis of international student enrolment caps released yesterday by Claire Field, Principal at Claire Field & Associates, continues to highlight the perverse outcomes caused by the Government’s arbitrary methodology used to calculate individual provider limits for 2025. Claire’s analysis also provides an insight into a looming future for Australia’s international education sector, one in which the Minister has unprecedented powers to set enrolment caps with no obligation to consider the impact of the caps or the methodology.
Highlights of the analysis
Claire’s full analysis is essential reading for anyone who has a stake in the whether the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024 passes Parliament:
- Unpacking the international student caps for each provider was released on 22 September and is available here.
- More problems in how international student caps have been allocated was released yesterday and is available here.
Just two of the findings from yesterday’s analysis demonstrate just how bonkers the ill-conceived methodology is (‘bonkers’ is the technical term for it):
- 129 providers enrolled no new international students in 2019, 2022, 2023 or 2024 YTD, but were all granted a cap for 2025 of 30 new students.
- five universities and 9 dual sector non-university higher education providers have enrolled no international VET students between 2019 and 2024 and have been given caps allowing them each to enrol 30 new VET students in 2025.
On this evidence, these caps are likely to go unfilled.
Little certainty for the future
When indicative enrolment caps for the higher education sector were released last month, they were welcomed by parts of the sector, with the rationale that it at least gave certainty in comparison to Ministerial Direction 107. However, this latest analysis shows that the only thing that is certain is that the sector should be concerned about its implications for 2026 and beyond.
For 2025, there is a spotlight on the flaws in the methodology because of the Senate Committee inquiry into the Bill.
But what happens in future years?
If the Bill passes in its current form, there can be no certainty, when the Government of the day:
- can change the methodology it uses every single year, to achieve any result of its choosing
- is only required to release individual provider enrolment limits by 1 September each year for the following year
- does not have to undertake any consultation in setting enrolment limits, and,
- enrolment limits from 2026 can apply to new, or new and ongoing students, at the discretion of the Government, as I have previously highlighted (TKN 240924).
The current Government has signalled that the National Provider Level will be released through the annual budget cycle. But that’s not in the legislation and can be changed on a whim by the current or future Government. And even if the NPL is released in a May budget cycle, individual provider caps don’t have to be released until 1 September.
The legislation provides no avenues for appeal or dispute, and even if it did, there is hardly time from 1 September for the kind of scrutiny that has been applied to 2025 caps.
Last hurrah?
Submissions to the Senate Committee closed yesterday, the fourth hearing will be held next week on 2 October, and the Senate Committee will report by 8 October. It feels like this is the final opportunity to influence the outcome of the Senate Committee’s inquiry and the Government’s reconsideration of the ESOS Amendment Bill.
The Government must shelve enrolment limits and work collaboratively with the sector to develop a strategy that ensures the sustainability of Australia’s international education industry.
