Australia’s international education sector has been handed a timely, and pointed, reminder that while regulation may be strong, the system around education agents still has some clear gaps.
The International Education Association of Australia (IEAA) this week released its Agent Quality Research report, underpinned by comprehensive research commissioned from Edified, offering what it describes as a practical, evidence-based pathway to lift standards across one of the sector’s most influential, and scrutinised, channels.
The message is measured, but unmistakable: the framework is solid, the intent is there, but consistency, transparency and accountability remain uneven.
At the heart of the report is a simple tension. Australia already operates “one of the most mature and comprehensive regulatory environments globally,” yet integrity concerns tied to a small portion of agents and providers continue to surface, exposing weaknesses in enforcement and oversight.
Rather than pushing for sweeping new regulation, IEAA has taken a more pragmatic route.
Smart. And, an approach the government could take note of.
The report stops short of prescribing a single solution. Instead, it lays out three scalable policy models: effectively a “menu” that government and the sector can choose from, depending on appetite and timing.
From signal to system
The three models build progressively.
The first, a light-touch “Signal” approach, centres on a national agent register, baseline training and a code of ethics, essentially creating visibility where little currently exists.
The second, “Standardise”, introduces stronger system-wide expectations: mandatory training, clearer provider obligations, better data sharing and mechanisms to capture student voice.
The third, “Strengthen”, moves into more robust territory, with compliance monitoring, public transparency and deeper government oversight.
It is a deliberately staged approach. Start small, build confidence, then scale if needed.
As IEAA’s Agent Quality Research Steering Committee co-chair Jonathan Chew puts it, the report is not about accelerating regulation, but about offering “measured and meaningful regulatory models” to inform the next phase of policy thinking.
A system that works… until it doesn’t
One of the more striking elements of the report is its acknowledgement that the current system is not broken, but nor is it complete.
Australia’s ESOS framework places clear legal responsibility on providers to manage agent behaviour. But in practice, this creates a fragmented system in which oversight sits within individual provider-agent relationships rather than across the sector as a whole.
When things go wrong, the response is often local and reactive. When things go right, there is little in the way of recognition or reward.
The result? Limited transparency, inconsistent standards, and a market where students have little visibility into agent quality.
Stakeholders consulted for the report were broadly aligned on the issues:
- Enforcement of existing rules is inconsistent
- “Bad actors” can still operate through gaps in oversight
- Data visibility is limited
- Student feedback is largely absent from quality assurance
- And perhaps most critically, there is no shared, system-wide view of agent performance
The missing piece: visibility
If there is one theme that runs through the report, it is visibility.
A baseline agent register is described as “essential” not as a heavy-handed regulatory tool, but as a way to bring transparency and coordination to a highly decentralised system.
Without it, intelligence about agent performance remains siloed. With it, the sector gains a common reference point.
It is a small step on paper, but potentially a significant shift in practice.
Students at the centre, in theory and in reality
The report also highlights a familiar gap between policy intent and lived experience.
Across global models reviewed, from the UK to Canada, student welfare is consistently positioned as a priority. But few systems actually capture or use student feedback to assess agent quality.
Australia is no exception.
Students rely heavily on agents for guidance, yet have limited ability to verify their credibility or share their experiences in a way that shapes the system.
Fixing that disconnect is likely to be one of the more complex, and politically sensitive, parts of any reform.
Reform, but not overreach
There is also a clear awareness of reform fatigue.
With recent government interventions already targeting integrity, including changes to commissions and provider requirements, the report deliberately avoids calling for heavy new regulation.
Instead, it leans into co-design, sector ownership and proportionate change.
As IEAA CEO Phil Honeywood notes, the goal is to provide government with “a way forward… informed by global best practice.”
The Koala’s take
For a sector that has spent the past 18 months navigating policy uncertainty, visa changes and shifting public sentiment, this report lands at an interesting moment.
It does not demand immediate action. It does not prescribe a single path.
But it does something arguably more useful: it reframes the conversation.
Agent quality is no longer just about compliance. It is about system design, incentives and shared accountability.
And perhaps most importantly, it signals that the next phase of reform will not or should not be about whether change happens, but how far, and how fast, the sector is willing to go.
The report can be seen here.
