The response to the Government’s new international student enrolment caps in 2025 is a big thumbs down, according to new submissions received by the Senate Committee inquiry into the Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024.
“An equivalence should be brought to what would happen if the Federal Government, without any real warning, approached the mining industry and applied a cap to all its production at a percentage between 50% and 60% of its operations of 2023.” (Denison Toyer, Submission 168).
Prior to September, the Senate Committee inquiry had received 70 submissions, with a handful received after the 1 July closing date. In a clear reaction to the release of enrolment caps for 2025, the re-opening of submissions to the inquiry has seen a further 116 submissions published on the inquiry website as at time of writing, including supplementary submissions.
These are some of the themes covered across the new submissions.
Financial viability and provider closures
The financial viability of providers, especially those who have been allocated low/single digit caps, is another theme in the submissions. “Many provider businesses will be driven out of business if the bill is passed as currently written”, according to The Academy of Interactive Entertainment Ltd and AIE Institute Ltd.
Providers have highlighted the significant long-term commercial investments made in leasing and upgrading facilities, and the cost of fixed overheads, regardless of the number of students enrolled.
Job losses
Submissions raise concerns about widespread job losses, of teaching staff and professional and support staff. For example, Lead College predicts 30 job losses from early 2025 due to the impact of enrolment caps and Sheridan will make half of its academic positions redundant at the end of 2024.
Enrolment caps methodology
Most new submissions to the inquiry are from private providers, which is unsurprising given the low caps that have been allocated to this part of the sector. These submissions are highly critical of the methodology used to calculate enrolment caps, especially the disparity between the public and private sectors, the “one-size-fits-all” approach to the private sector, and the lack of transparency.
The anomaly that providers with no enrolments in 2023 will receive a cap of 30 students, whereas historical data used for other providers, resulting in single digit caps, is an example.
If you are interested in more detail, and haven’t already read Claire Field’s excellent analysis, she has provided a submission to the inquiry. Submissions are available here and Field’s is number 130.
CRICOS
Providers have highlighted the discrepancy between CRICOS registration and caps, especially for providers who have recently been registered or re-registered.
ASQA
Providers have called for the Australian Skills Quality Agency (ASQA) to take more action to regulate non-compliant providers.
Impact on pathways
Although the ELICOS and school sectors have been exempted by the Government from enrolment caps, the impact on the ability for these students to pathway to VET and HE providers is raised as a concern.
Ministerial Direction 107
Universities Australia took the opportunity to provide a supplementary submission calling for the immediate revoking of Ministerial Direction 107. Other providers did the same, highlighting the impact of slow visa processing on their ability to recruit international students.
Others raised concerns about the high visa refusal rates, including Charles Institute of Technology which had 90% of its international student visa applications refused in 2023 and 2024, following an average visa approval rate of 81% prior to this.
$1600 student visa fee
Some submissions also raised concerns about the impact of the government’s student visa fee hike.
Flight training
One notable cohort of submissions come from flight training providers, with enrolment caps compromising partnerships with airlines to train their pilots. Some also predict that Australia’s aviation sector will be impacted.
The final day of public hearings is tomorrow, 2 October and the Senate Committee is set to report on 8 October. We will soon see how easy or hard it is for the Senate Committee to ignore the evidence provided in the submissions.
