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Home News Market Update

Ministerial Direction 111 and the 2026 National Planning Levels: What Our Latest Analysis Reveals

Guest ContributorbyGuest Contributor
September 18, 2025
in Market Update, Uncategorized
Ministerial Direction 111 and the 2026 National Planning Levels: What Our Latest Analysis Reveals
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Since late 2023, the Federal Government has issued a series of announcements reshaping the framework that governs international student recruitment. In our recent Key Data Update, we paused to reflect on how these changes are influencing both recruitment practices and student decision-making. You can see the complete analysis via this link: https://www.youtube.com/watch?v=z_EqB9YAZOA

A rapid adjustment and a new plateau

The policy framework introduced over the past two years had two main objectives: to reduce the growth of new student visa holders and to restore integrity to the international education sector.

Our analysis of the 12-month rolling average of student visas granted confirms that, over the last 24 months, the sector has experienced a significant decline. The latest figures show that the rolling average is now 31% lower than the peak reported in July 2023. After this sharp fall, the trend has stabilised: over the past twelve months, the rolling average has levelled out, currently sitting around 3% above the levels reported in June 2024.

However, as it has been reported, the impact has been uneven across sectors. Private higher education institutions, English language providers and VET programs have been hit much harder than most public universities. This divergence is creating fractures within the sector, with a widening gap between institutions able to maintain their pipeline and those struggling with lower visa approval rates.

Compared to the 31% decline across all sectors, the ELICOS granted visas are 62% lower than the 2023 twelve-month rolling average peak, while VET visas are 55% lower.

Social Licence: An open question

A key justification for these policy changes was the need to strengthen the social licence of international education. After almost 24 months of reforms and significant economic costs, it remains unclear whether that objective has been achieved.

Our analysis highlights the need for proper measurement of public perceptions. Without evidence of improved community attitudes, further changes to the policy framework risk being implemented without a clear understanding of whether the “social licence” has actually improved.

Timing is now critical under Ministerial Direction 111

The introduction of Ministerial Direction 111 is already changing the way universities engage with international applicants. While its full effects are unlikely to be felt until the second half of 2025, institutions have begun adapting their recruitment strategies now.

Timing has become central to student conversion. To manage applicant pipelines, universities are implementing initiatives that encourage early acceptance of offers, enabling them to navigate better the priority processing system created under MD111. In this new environment, conversion timing—not just volume and quality—has become a key driver of recruitment success.

2026 National Planning Levels: Continuity with a carrot

The Australian Government’s recent announcement of a 9% increase in National Planning Levels (NPL) and the continuation of current policy settings mark an important shift. After nearly two years of rapid tightening, the message now is one of managed growth and continuity.

The announcement has given the sector something it has long sought: policy continuity.

Notably, the 2026 framework also introduces the first real “carrot” in an otherwise stick-heavy regime. Publicly funded universities that invest in student accommodation or deepen engagement with Southeast Asia will be able to apply for additional NOSC places. This incentive marks a subtle but significant shift in tone, signalling that the government wants to shape behaviour rather than simply constrain it.

This shift towards managed growth reflects not only a political recalibration but also the Government’s growing focus on the economic role of international education. With trade tensions and macroeconomic volatility, it makes sense that policymakers are evolving from pure restriction to a model that recognises the economic benefits of welcoming a larger, better-managed cohort of international students. In one sentence: the model is shaped by policy but driven by economic factors.

You can see the complete analysis via this link: https://www.youtube.com/watch?v=z_EqB9YAZOA

Keri Ramirez is a Director at Studymove

 

Tags: MD 111Studymove
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