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Home News Market Update

Welcome to 2025! If you’re finding it hard to get back on track, here’s a quick overview of the policy landscape to catch you up

Dirk MulderbyDirk Mulder
January 23, 2025
in Market Update, Policy
Welcome to 2025! If you’re finding it hard to get back on track, here’s a quick overview of the policy landscape to catch you up
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Welcome back to 2025. The Koala has been on leave and is now back. This week’s wrap will include several stories by contributors that have been published over the break. You can subscribe to The Weekly Wrap here.

As an opener, The Koala thought it might be helpful to summarise the international education debate in Australia, providing context to how we got here, the events over the past 12 months and some of the key themes. The election can’t be too far away, so summarising the major party positions is also included.

How did we get here?

The issues go back as far as the borders closing due to the COVID-19 pandemic and re-opening again. Prior to the closure of Australia’s borders, the country experienced a peak in international student enrolments. In December 2019, there were 952,389 international enrolments in Australia. This figure represents the highest recorded number of international student enrolments in the country up to that point and almost achieving the 1 million students that former Trade and Investment Minister, Andrew Robb, predicted in 2012 would be possible by 2025.

When the COVID-19 pandemic hit, the government implemented several policies that significantly impacted international students. Australia closed its borders to international travellers, including international students, in March 2020. This led to a sharp decline in new international student arrivals, disrupting education providers and affecting students’ plans. In December 2021, there were 572,349 international student enrolments in Australian education institutions, down from 715,888 in December 2019.

International students were allowed to retain their visas even if they were studying online from their home countries.

The government introduced measures to extend the validity of visas for students unable to complete their studies within the original visa period due to COVID-related disruptions.

The Subclass 408 visa, also known as the “COVID-19 Pandemic Event Visa” was made available to international students and temporary visa holders who were unable to leave Australia due to travel restrictions. This visa allowed students to stay and work in Australia if they were employed in critical sectors such as health care, agriculture, or food processing.

In 2021, international students were temporarily allowed to work more than the usual 40 hours per fortnight in certain critical sectors, such as health care, aged care, and supermarkets. This policy aimed to address labour shortages while supporting students financially. This work limit relaxation was ultimately extended to all sectors of the economy in January 2022.

Many students faced financial difficulties, as they were ineligible for government welfare programs like JobKeeper and JobSeeker.

A significant number of students were stranded overseas, unable to return to Australia for in-person learning.

Incentivising students returning to Australia

To encourage international students to return to Australia after the pandemic, the government introduced several incentives to boost the international education sector and ensure the industry’s recovery. These incentives included:

Visa Fee Waivers

The government introduced temporary fee waivers for international students applying for a new visa or for those returning after the border reopened. This was a financial incentive to reduce the burden on students and encourage them to resume their studies in Australia.

Work Rights

The government extended post-study work rights for international students who had completed their studies but were unable to enter Australia due to the pandemic. This extension allowed students to work in Australia for a longer period after completing their qualifications, making it more attractive for them to return. And, as above, unlimited work rights were extended to all international students in January 2022.

Priority Visa Processing

International students eligible to return to Australia were given priority in visa processing, allowing them to secure their visas more quickly and easily. After initial delays, the government invested in additional visa processing staff and this was particularly beneficial for students waiting to return to Australia for in-person studies.

Increased Support for Education Providers

The government provided funding and support to English and Private Higher Education providers via the Innovation Fund, which helped them adapt to the new environment and offer more flexible study options, including hybrid or online learning. This was intended to ensure that international students who could not return immediately still had access to education and could transition back to Australia smoothly.

State and Territory Incentives

Various state and territory governments in Australia also introduced additional incentives for international students to return, such as scholarships, accommodation support, and special welcome packages. For example, New South Wales offered financial support to international students in distress during the pandemic and later launched initiatives to help them return to study.

Promotion of Australia’s Safe Reputation

The Australian government emphasised the country’s success in managing the pandemic and the high level of COVID-19 vaccination among the population. This messaging aimed to reassure international students that Australia was a safe destination to return to for education.

These incentives were part of a broader strategy to restore Australia’s international education sector, which had been significantly impacted by the pandemic. They were designed to ensure that Australia remained an attractive destination for international students and to help the sector recover and thrive in the post-pandemic world.

Election

The last Australian federal election was held on Saturday, 21 May 2022, and saw the Australian Labor Party elected to government, replacing the Coalition government.

18 months on from the 2022 election – Issues apparent

Hindsight is always a wonderful thing. In August of 2023 the Koala published this article, ‘A Sector Desperate for Action: Three Avoidable Issues Causing Concern’.

The issues were:

Provider hopping

Students arriving with a visa to enter higher education and transferring to the VET sector on arrival was a common practice and was facilitated by the dual Conformation of Enrolment (CoE) practice, that is allowing two CoE’s to be issued to the student.

Students who apply for a visa using one CoE, and when they arrived in Australia, they activated the other. The reason? Due to the Simplified Student Visa Framework (SSVF), it was easier to get through the visa system on the higher education application than the VET application. A work around of the system.

On 26 August 2023, the Australian government removed the functionality for concurrent Confirmations of Enrolment (CoEs) from the Provider Registration and International Student Management System (PRISMS).

This change means that international students are no longer permitted to enrol in multiple courses concurrently within the first six months of their principal course of study.

Unfortunately, the damage had been done.

Uncapped work rights

In a Campus Morning Mail story on 14 Feb 2022 [Phil] Honeywood says, “with the largest number of students coming from the sub-continent, it will take time before we understand to what extent the recent uncapped work rights policy is acting as a major pull factor to come to Australia. Many institutions are also concerned about the impact that long hours of paid work outside of classes will have on students’ academic progress.”

Right, he was. While uncapped work rights had been turned off, the residual impact remained. The international education sector had always been seen as a ‘study first, work second’ visa. The previous Coalition government sought to change this under the pressure of the business lobby during the pandemic. While potentially not a bad idea, its implementation needed to be short and sharp. Address the issue and go back to the norm as soon as realistic.

Unfortunately, it wasn’t short and sharp. It was due to be reviewed in April 2022, but the government went into caretaker mode by issuing the election writ on 11 April of that year. A new government was elected and pushed back the decision and by the time a decision was made and implemented, it wasn’t until 1 July 2023 that ‘48 hours a fortnight’ was established as a new normal – this period of approximately 18 months did significant damage and sent signals to the market that Australia was ‘open’ to work via a student visa.

This move and the delay in correcting it created a cohort of students dependent on income generation, addicted to the idea that work could be promoted in front of study, which had never been the case before.

Closing of the 408 Event visa

On 31 August The Hon. Clare O’ Neil, then Minister for Home Affairs announced that Labor was ending the Covid Event visa. The key points of this announcement were:

  • From February 2024, the visa will be closed to all applicants. This will provide certainty to our visa system now that the circumstances that drove the operation of the visa no longer exist.
  • From 2 September 2023, the Pandemic Event visa will only be open to applications from existing Pandemic Event visa holders.
  • All other visa holders will be ineligible for the Pandemic Event visa. This is a transitional measure to promote visa integrity.
  • Anyone with a valid Pandemic Event visa will remain lawful until their current visa expires.
  • The staged closure of the visa is another measure to ensure the visa system is serving the needs of the Australian people.
  • From 2 September 2023, new applications will receive a six month visa. A Visa Application Charge of $405 AUD will also be introduced.

The program being closed to all applicants took place approximately 26 months after the borders were opened (December 2021). Numbers fluctuate in the public domain; however, it is fair to say that in September 2021, there were approximately 120-160k students on the 408 visa compared to approximately 6k in December 2021.

2024: A year of change

In 2024, the Australian Government implemented several significant changes to the international education sector, aiming to enhance its sustainability, integrity, and alignment with national interests.

Adjustments to Visa Processing and Fees

Slowed Visa Processing: In December 2023 the government introduced Ministerial Direction 107. This aimed to align visa processing with an individual institution’s standing (or evidence level) in the SSVF. The effect of MD107 was an inconsistent visa processing mechanism which the sector complained at length on. It was later described by Minister for Education, Jason Clare, as a “throttling mechanism” for student visa issuance.

Inconsistent Visa outcomes: Over the previous 12 months, many providers complained of inconsistent visa outcomes and “cut and paste” visa letters being administered by DHA. The SMH ran a story on 31/12/24 where it states “In the latest six-week period, 67 per cent of department decisions to reject student visas were set aside by the tribunal.”

Increased Visa Fees: On July 1, 2024, the fee for international student visas was increased from $710 to $1,600. This substantial hike, according to the government, aimed to address administrative costs and ensure adequate resources for visa processing and compliance monitoring, but was seen by the sector as another way of bringing down student numbers in Australia.

ESOS Act Amendment and Proposed Cap on International Student Enrolments

The Education Services for Overseas Students Amendment (Quality and Integrity) Bill 2024 was introduced to the parliament on 16 May 2024.  In summary, it sought to introduce:

  • Ministerial power to cap system, institution, and course enrolments
  • Ministerial power to intervene on CRICOS registrations
  • Ministerial power introduced for course suspension and cancellation
  • A change in the definition of an Agent – broader and causing issues
  • Prevention of cross-ownership between agents and institutions
  • Measures to change agent commissions declaration and broader definition
  • Amendments to see new operators required to deliver to Australian students for two years prior to being eligible for international student delivery
  • A fit and proper test for providers

The Bill was immediately referred to the Senate Standing Committee on Education and Employment for inquiry and report by 15 August, with submissions to be received by 1 July 2024.

The lower house passed the bill with one amendment on 13 August 2024.

On 14 August 2024, the Senate agreed to extend the Committee’s reporting date to 6 September 2024.

At the end of August 2024, while the Senate Committee was still considering the Bill, the government announced that the cap for international student enrolments would be set at 270,000, with 145,000 allocated to university enrolments.

On 6 September 2024, the committee sought a further extension to the reporting date to 16 September 2024.

On 12 September 2024, the committee agreed to accept further submissions until 26 September 2024, and to hold an additional public hearing on 2 October 2024.

On 16 September 2024, the Senate agreed to extend the committee’s reporting date to 8 October 2024.

Due to the decision of the Senate to rearrange its routine of business on 8 October 2024, the report was tabled on 9 October 2024, rather than the due date of 8 October 2024.

During its inquiry into the Bill, the Senate Committee held 4 public hearings, two more than originally anticipated. These can be read here:

Senate hearing on the ESOS Bill: Here’s what happened

By George! Day 2 of Senate Hearing to the ESOS: How it played out

3rd Senate Hearing Day: How it went down

Fourth Senate Committee Hearing: A Wrap of Proceedings

To summarise an intense sitting time in Parliament, it became clear the Coalition was no longer in support of the Bill, while the Greens, if taking into account what was said by Senator Mehreen Faruqi during the Senate Committee hearings, never were.

Technically, the Bill is still live but was not put up for debate during the remaining sitting days of 2024.

Introduction of Ministerial Direction 111

Effective from December 19, 2024, Ministerial Direction 111 replaced the previous Direction 107. MD 107 linked visa processing priorities with the institutions standing in the SSVF. Many in the sector, especially regional institutions, believed this was inequitable. Minister Clare conceded this point as the caps debate was occurring. This new directive provides updated guidelines for the assessment and processing of student visas.

In brief, Priority 1 – High, processing applies to student visa applications associated with providers who have not yet reached their prioritisation threshold, which is 80 percent of their 2025 indicative allocation of new overseas student commencements in the higher education and Vocational Education and Training sectors.

Indicative allocations for both higher education and vocational education and training providers can be found at:

  • Indicative allocations for higher education new overseas student commencements 2025 – Department of Education, Australian Government and
  • Indicative allocations for VET new overseas student commencements 2025 – Department of Employment and Workplace Relations, Australian Government​

Priority 1 – High visa processing will also ap​ply to a range of sect​ors and student types, for example, the schools and higher degree by research sectors, as well as scholarship and TAFE students, and those from the Pacific and Timor-Leste.

Priority 2 – Standard visa processing will apply to providers who have reached their prioritisation threshold, subsequent entrants, and any other offshore Student visa application.

There are a number of exceptions/exemptions.

For complete details, please see  Ministerial Direction ​111.

Financial Pressures and Institutional Responses

The combination of decreased enrolments, increased operational costs, and policy changes led to intensified financial pressures on Australian providers. A number of Australian universities are now moving through restructuring operations to balance their budget, with most citing a decrease in international student income as a key driver. At the end of 2024 the first major private provider went into administration and now ceases to operate. Many in the sector believe this is the first of many.

The Election and 2025

Migration is a central issue in the upcoming federal election, with both major political parties honing in on this space. The international education sector has been caught up in this and faces some of its most challenging times as a consequence.

Both parties have sought to link migration with ongoing housing pressure and Australians feeling the pinch as the cost of living has continually risen in 2024. The housing link has largely been disproven by reports from the Property Council, the ANU Migration Hub and The Go8.

The Treasurer, Jim Chalmers, stated to David Speers that the migration programs’ impact on housing accessibility is “at the margins at best”, and building new houses is the answer to the housing crisis when interviewed on ABC’s Insiders program on 21 May 2024.

Torie Brown, Executive Director of – the Student Accommodation Council, a division of the Property Council of Australia, wrote an op-ed for the Koala on 26 November 2024, and she summarises the situation eloquently.

While the link between international students and housing stress continues perpetuating, no matter how false, the sector will continue to face dilemmas.

Labor Party’s Position:

The Australian Labor Party (ALP) has introduced reforms targeting temporary skilled migration and international students. These measures aim to address concerns about the impact of high migration levels on housing affordability and infrastructure. However, the ALP’s approach has faced criticism for potentially being unsustainable and lacking long-term planning.

Coalition’s Position:

Opposition Leader Peter Dutton has pledged to reduce migration levels, focusing on limiting the number of international students and temporary workers. He argues that this strategy will alleviate pressure on housing and public services. Dutton’s stance has sparked debate, with some expressing concerns about the potential economic impact and the need for a balanced approach to migration.

The Coalition started out seemingly to support Labor’s international student cap policy, but withdrew its support. While Dutton has pledged to go harder and made some very naive remarks (that’s being kind), he hasn’t been clear about how he would go about it.

Tracy Harris writes on the latest from the Coalition here.

Public Sentiment:

Public opinion on migration is divided. Some Australians support stricter immigration policies to address housing shortages and job competition, while others emphasise the economic benefits and cultural diversity that migrants bring. The debate continues to evolve, influenced by global events and domestic challenges.

As the election approaches, migration remains a pivotal issue, with both parties seeking to gain advantage from the electorate and the sector appears to a key battle ground.

In the lead up to the Federal Election The Koala will continue to keep you updated on all developments that impact the international education sector. It looks like 2025 will be another challenging year.

Note: Student data has been sourced from the Department of Education international student data pivot tables.

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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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New Factsheet released – Indicative Allocations and Ministerial Direction 111

New Factsheet released - Indicative Allocations and Ministerial Direction 111

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