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Close the SSVF Loophole to Secure the Export Education Industry

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Simplified Student Visa Framework (SSVF) Integrity Loophole:

It is well known across the Australian export education industry that serious ‘Agent Touting and Institution Poaching’ and associated ‘Provider and Course Hopping’ by international students, whether before or after completing at least 6 months of their principal course, is seriously destabilising and disrupting the Australian export education industry.

The main purpose of this brief submission is to help ensure that this serious phenomena can be quickly addressed once and for all with one simple SSVF policy amendment.

Since significant numbers of South Asian students show education specific bank loans to meet the Dept. of Immigration and Border Protection's (DIBP) Financial Capacity requirements, an associated issue feeding this serious trend that I wish to highlight in this submission is as follows.

Under Central Bank education specific bank loan rules and regulations across the subcontinent, once a student transfers from the institution for which their student visa was granted, their education specific bank loan immediately becomes void.

With this, such students (who typically do not apply for a new education loan, as they find it extremely difficult to do so once they are in Australia) would no longer satisfy the financial capacity conditions specified in the relevant legislative instrument F2017L00267.

Also, once they transfer, they would no longer be able to meet DIBP's Student Visa Condition 8516, which states that all international students must continue to satisfy the requirements for grant of their student visa. This means that they would no longer be able to prove they have sufficient financial capacity to support their study and stay in Australia and would therefore be in violation of their student visa conditions as they would no longer be GTE compliant.

Negative Impact of this Loophole on International Students and the Export Education Industry at large:

The SSVF Integrity ‘loop-hole’ that allows young, gullible, undergraduate students (who are making unwise decisions without their parent’s stabilising influence) to move sideways 'across' the Australian Qualification Framework (AQF) ladder (so they can take-up more flexible, far less rigorous and extremely inexpensive academic programs that they would never have been issued a student visa for in the first place) is not just a student visa integrity issue, it is also an issue of market fairness and education provider sustainability. This threatens the operating revenue and financial returns of education providers with highly developed and enormously expensive marketing operations offshore, as well as the security of the Australian export education industry and ‘Brand Australia’.

For example, the impact is being felt from as far back as when international students are counselled to study in Australia from offshore. At this stage, genuine education agents are reluctant to process potential international students who appear to represent a ‘flight risk’. When they reject them, many such students end up in the offices of nefarious agents, who happily process these students by using reputable education providers to ensure a student visa grant, only to encourage and/or assist them to transfer out after they are safely ensconced in the Australian migration zone and once their first semester’s tuition fees have been exhausted.


Under DIBP’s current SSVF related subclass 500 student visa policy, international students are rarely permitted to transfer from a higher level AQF course to a lower level AQF course at another institution either before or after their enrolment for at least 6 month’s in their principal course unless they successfully apply for a fresh student visa onshore.

As soon as this rule was introduced as part of the SSVF from July 01, 2016, the incidence of onshore agent touting and education provider poaching and the associated provider and course hopping to a lower AQF level course was substantially reduced.


This new student visa application requirement should be immediately extended to inhibit young and gullible Higher Education and VET level students from abandoning their initial provider and course to seek a sideways transfer to a less rigorous provider and course offered at the same AQF level. This requirement should be applicable either before or after their enrollment for 6 month’s in their principal course.

If such transferring students would be required to apply for a new student visa in order to prove their GTE compliance at the time, I believe onshore touting and poaching of young and gullible international students and the resultant provider and course hopping phenomena, would cease almost overnight.

Due to the stability that this simple SSVF amendment would immediately engender, Higher Education institutions offering undergraduate programs and even serious players in the VET sector, including and especially Australia’s hard-done-by TAFE institutions, would have a chance to recover their much needed international student numbers and associated revenue. Then, if TAFE students who seek a sideways transfer to another VET level institution that offers programs at the same AQF level would be required to apply for a new student visa to do so, this serious problem would be contained immediately thereafter.

With this, nefarious offshore education agents and their non-financial students (often presenting DIBP with non-viable student visa related financial capacity evidence) will no longer be able to target serious mainstream education providers in order to acquire a student visa. And, their hidden agenda to transfer to a less rigorous, more flexible and less expensive institution in order to reduce their tuition fee burden and maximise their paid work opportunities once they are safely ensconced inside the Australian migration zone would be thwarted.

If such non-financial students know that they cannot downgrade the academic rigour and overall cost of their course with ease, they will be highly unlikely to apply for a student visa from offshore in the first place.

Keeping DIBP’s Immigration risk rating reporting scheme in mind, following is another extremely important outcome if students who agree to change their education provider would have to apply for a fresh student visa. If this change were to be introduced, the associated Immigration Risk Rating liability and any negative statistics would be permanently transferred from the initial education provider and reputable offshore agent who recruited them, to the new education provider and the onshore agent who touted and poached them. This would solve yet another conflict for serious education providers and reputable offshore education agents.


The best outcome if such a change to the SSVF scheme is introduced to make sideways institution and course transfers more difficult for young gullible international students in the future, would be that genuine students (recruited by reputable offshore agents on behalf of serious education providers who maintain a highly developed and incredibly expensive offshore marketing presence) would be less likely to be influenced by nefarious agents offshore and agent touts and poaching providers onshore.

This petition has been prepared to assist concerned Department of Immigration and Border Protection officials, who are responsible for the protection of the Australian migration zone and therefore the integrity of the SSVF scheme, to understand how widespread the concern is across the Australian export education industry and within Australia’s all important education agency communities abroad.

It has also been designed as a urgent appeal for appropriate Dept. of Immigration and Border Protection and Dept. of Education and Training officials to take the necessary action to resolve this integrity issue, which if left unresolved will continue to disrupt and threaten the future viability and international standing of the all-important Australian export education industry.

Authored and Published by:

Louanne M. Hancock

Chief Executive Officer

Interface Education


Endorsed by:

Mr Rahul Ghandi


Australian Association of Eductaion Representatives in India (AAERI)


Endorsed by:

Mr Narayan Pahari


Nepalese Association of Australian Education Representatives (NAAER)

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