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Home News Compliance

When 2 plus 2 equals 3: How institutional evidence levels don’t add up

Dirk MulderbyDirk Mulder
March 27, 2026
in Compliance, Market Update
When 2 plus 2 equals 3: How institutional evidence levels don’t add up
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Only two universities have shifted evidence levels in the latest update from the Department of Home Affairs and the result is already raising eyebrows across the sector.

In a landscape dominated by headlines about visa refusals, tightening scrutiny and growing uncertainty, the minimal movement feels, at best, out of step with the broader narrative.

The two institutions in question, Queensland University of Technology and University of New England, are the only providers to see a change in their Evidence Level classifications in this latest release.

That is the sum total of movement.

And it prompts a question the sector is now quietly, and in some cases not so quietly, asking. How can only two institutions shift (and one went up) when stories of rising visa refusals have been so prolific?

Adding to the intrigue is the timing. The data was released on a Friday and, as one learned reader of The Koala spoke with put it, “The government loves to drop sh#t on a Friday.”

To understand the disconnect, it is worth revisiting how Australia’s evidence level system actually works.

As previously reported by The Koala News (TKN 30/9/25), Australia’s Department of Home Affairs assigns every institution registered under CRICOS (commonwealth-education providers for overseas students) an Evidence Level (sometimes called Assessment Level) — Level 1, 2, or 3. This level, combined with the applicant’s country of citizenship (which also has a country evidence level), influences how much documentation is required for a student visa under the Simplified Student Visa Framework (SSVF).

  • Level 1 = lower risk: fewer extra requirements like proof of English or detailed financial documentation.
  • Level 2 = moderate risk: more documentation might be required depending on country + provider combo.
  • Level 3 = higher risk: stricter evidence requirements and more scrutiny.

If a provider doesn’t have enough visa/outcome data (below a certain threshold), a default level is assigned. For many smaller providers, that will often be Level 2. For small countries lacking data, default is often Level 3.

On paper, it is a system designed to reflect risk based on actual outcomes.

But as The Koala News previously asked in its analysis, is the system still fit for purpose?

If refusal rates are climbing, if providers are reporting tougher visa conditions, and if agents are recalibrating markets in real time, then logic would suggest a more dynamic shift in evidence levels.

Instead, the latest update suggests near total stability.

While no official list is ever published, the sector has its own ways of calculating evidence levels, with unverified data already doing the rounds in practitioner networks.

That stability could be interpreted in several ways.

It may indicate that the system is working exactly as designed, relying on longer term data trends rather than reacting to short term fluctuations.

Or it could point to a lag, a system that is simply too slow to reflect what is happening on the ground.

A more uncomfortable interpretation is also emerging, that the evidence level framework is no longer capturing the realities of student mobility in 2026.

Because if the risk environment has changed, and most in the sector would argue it has, then a static set of institutional ratings begins to look increasingly disconnected from lived experience.

For providers, agents and students alike, that disconnect matters.

Evidence levels directly influence the complexity of visa applications. They shape recruitment strategies. They determine how Australia is positioned in an increasingly competitive global market.

And right now, the question is not just why only two institutions have moved.

It is whether the system itself is moving at all.

Photo: Reproduced with permission. Taken from Alek Voninski’s Opening Address at the IEAA National Symposium.

Tags: Evidence Levels
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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 StudyPerth) 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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