🚨 Regulatory alert for CRICOS providers – education agent commission changes

On 20 January 2026, the National Code of Practice for Providers of Education and Training to Overseas Students Amendment (Education Agent Commissions) Instrument 2026 was registered.

The amended National Code took effect the day after registration.

What’s changed

Standard 4 of the National Code has been amended to ban the payment of education agent commissions for the recruitment of a student who is transferring from another provider.

This applies to:

– percentage or flat-fee commissions

–performance or volume bonuses

– incentives, benefits or inducements

– indirect or third-party arrangements linked to transfer activity

If a benefit could reasonably influence recruitment, it is in scope.

ASQA is not just checking agent agreements, they are assessing whether providers can demonstrate:

• commissions are not paid for transfer students

• admissions, finance, compliance and PRISMS data are aligned

• transfer decisions are independent of agent financial incentives

• records are consistent, auditable and defensible

This is a systems and governance test, not a policy exercise.

Think about it:

Do you have the actual systems and framework in place for the new required evidence to be:

– gathered

– monitored

– reconciled

– and tracked

Can you confidently say you:

• understand what these changes are? 

• how these changes apply to your organisation?

• are prepared from 31 March 2026, that your admissions, finance and compliance data will all align and demonstrate this? 

• could defend your approach at a ASQA audit?

Need help?

If you unclear on how to:

– interpret these changes 

– align admissions, finance and PRISMS records

– have audit-ready evidence frameworks

We can help. We have the aligning framework systems ready! compliance@rtostandards2025.com.au