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Risk priorities
  • Academic integrity
  • Recognition of prior learning
  • Shortened course duration
  • Student work placement
  • Marketing, recruitment, and delivery of international education
  • Non-genuine providers and bad faith operators
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  • Marketing, recruitment, and delivery of international education

Marketing, recruitment, and delivery of international education

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Key focus for priority

 

  • Provider viability
  • Market manipulation
  • Misleading marketing practices
  • Offshoring services
  • Unregulated education agents
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Risk overview

The delivery of training to international students introduces unique risks to providers operating under the Education Services for Overseas Students (ESOS) framework that do not typically apply to domestic vocational education and training (VET). The integrity and quality of international VET and English Language Intensive Courses for Overseas Students (ELICOS) are influenced by complex global and local political, economic, and social factors.

Challenges such as provider dependence on visa settings for financial stability, market manipulation and unethical recruitment practices create vulnerabilities within the sector. These risks are interconnected, with disruptions in the international student market having potential flow-on effects across the broader VET sector.

Many ESOS providers rely on education agents to attract and recruit international students. However, some agents pressure providers and threaten to withdraw their business if the provider refuses to accommodate non-genuine student enrolments. This heightens the risk of genuine providers compromising their compliance to maintain student flow and viability, undermining the integrity of VET and enabling visa fraud.

The presence of non-genuine students also contributes to regulatory non-compliance and diminishes educational quality, undermining confidence in Australian VET and displacing legitimate international students from accessing educational opportunities.

 

Key points from research

  • Economic pressures and visa policy changes are expected to reduce the number of onshore international students, creating financial and operational challenges for ESOS providers.
  • Some providers may adopt high-risk strategies to remain viable, including engaging in unethical recruitment practices, lowering the quality of training and student support, or shifting components of delivery offshore such as assessment or back-office services to stabilise financial health.
  • More ESOS providers are joining forces — either by being bought by other companies or by working together in informal groups. Which in some cases might conceal ownership or control.
  • Some providers and third-party agents engage in deceptive marketing, misrepresenting training quality, resources and costs, as well as migration outcomes.
  • In response to financial and migration policy pressures, some providers are reconsidering their operational models, moving components of their business offshore. Reporting indicates that providers are outsourcing elements of onshore training and assessment to offshore third parties, which introduces risks to the quality, currency and consistency of education and increases the complexity of effective regulatory oversight.
  • Complex education and migration networks, often with undisclosed cross-ownership or financial ties, enable collusive behaviours that undermine ethical student recruitment.

 

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