To: 

·         Mr. Jason Clare MP - Minister for Education

·         Mr. Tony Burke - Minister for Home Affairs, Minister for Immigration and

          Multicultural Affairs

·         Mr. Matt Thistlethwaite - Assistant Minister for Immigration

·         Mr. Julian Hill - Assistant Minister for Citizenship and Multicultural

         Affairs

 

We, the undersigned, from MECAA (Migration and Education Consultants Alliance Australia) group submit this petition to express our opposition to the proposed commission ban on onshore education agents under the ESOS Amendment Bill 2024. This bill, if passed, will have far-reaching and detrimental consequences on Australia’s various sectors as explained in this petition. 

·         International education sector, 

·         Onshore agents, 

·         Local businesses, 

·         Employment, 

·         Onshore Student support 

·         Diminished Quality of Counseling

·         Reduced Support for Smaller Institutions 

·         Ethical Consideration of Fair Compensation and 

·         Overall, on the broader economy. 

We urge you to reconsider and scrap this policy after proper consultation with the industry. Below are the key reasons why this commission ban is misguided and counterproductive.

Onshore education agents play a vital role in shaping the lives and careers of young international students during their formative years when they land in Australia for their educational journey. These students, often arriving in Australia at a crucial stage of personal and academic development, rely heavily on agents to successfully transition into a new culture, education system, and way of life. The support provided by agents is essential to helping them settle in, assimilate into Australian society, and build strong foundations for their future careers. 

Please do note that it’s not only about helping students with course selection or admissions into some colleges or universities, but agents play an integral part in building society for future. We need to understand meaning of agent and commission before we look further into impact and various role of education agents. 

Under Australian law, education agents are contracted with education providers in accordance with the National Code, ensuring compliance with stringent regulations. This existing framework already holds both education providers and agents to high legislative standards, promoting accountability and safeguarding the interests of international students.

Now, let’s address the devastating impact on Australia's third-largest export sector: 

1.    Impact on International Students’ Welfare: 

Guidance and Counseling

Agents provide indispensable guidance, helping students navigate complex decisions about course selection, visa compliance, and educational regulations. This professional advice ensures that students make informed choices that align with their long-term career aspirations and meet the legal requirements to stay in the country.

Cultural and Academic Adjustment

Adjusting to life in a new country can be overwhelming, especially for young students. Onshore agents are instrumental in easing this transition by helping students navigate cultural differences and academic expectations. This support fosters better academic outcomes, enhances their social integration, and ultimately boosts their chances of success in Australia.

Assistance with Settling Down

Agents offer crucial help beyond academic advice. They provide guidance on living arrangements, financial management, and adapting to life in a new environment, helping students feel more comfortable and confident. This comprehensive support helps young students quickly settle down and focus on their studies, paving the way for long-term success.  Without the incentive of commissions, the motivation for agents to provide these services diminishes, potentially leaving gaps in the support system. The government's proposal to ban commissions risks significantly undermining the quality of assistance available to international students, which could negatively impact their overall experience, academic performance, and ability to build a successful career in Australia.

Furthermore, the positive influence of agents on students’ lives far outweighs the negative stories that often dominate the discourse. The overwhelming majority of agents are committed to helping students build bright futures, and their contributions are being severely underestimated and undervalued by this proposed policy. By failing to recognize the positive impact agents have, the government risks depriving international students of the support they need during one of the most critical phases of their lives.

 

2. Impact on Australia’s Global Education Competitiveness

Australia’s international education sector, a key export industry, depends on the crucial support of onshore education agents. The proposed commission ban threatens to:

Reduce Student Retention: Without proper guidance, students may struggle to find suitable courses if the current course is not meeting their expectations, leading to early departures and weakening Australia’s ability to retain international students.
Harm Australia’s Reputation: Restricting onshore agents from guiding students in selecting appropriate courses without compromising compliance not only limits student choice and freedom but also risks harming Australia's reputation as a welcoming and supportive education destination. Onshore agents play a vital role in ensuring students are well-informed and aligned with compliance standards, and removing this option could undermine confidence in Australia's commitment to international education.
Limit Student Choice: Limiting the role of onshore agents would reduce the information available to students, leaving them less equipped to navigate complex compliance requirements and make informed course choices. This could severely impact their ability to make decisions during critical career-building years, potentially hindering their long-term professional growth. In a competitive global market where commission-based recruitment is norm, this ban would put Australia at a disadvantage, making it less attractive to prospective students.

3. Economic Consequences

The commission ban could severely impact the broader economy by:

Decreased Enrolment in Regional Universities: Smaller and regional Universities rely heavily on onshore agents to recruit international students. A reduction in student numbers will harm local economies and the education sector alike.
Job Losses: Onshore education agents, largely small to medium-sized businesses, depend on commissions for survival, paying employees, rent and other operational expenses. A ban would cause widespread small to medium size business closures, leading to job losses, harming local economies, further weakening struggling commercial real estate markets especially where education is a key economic driver. This ban threatens severe economic consequences.

4. Unfair Targeting of Onshore Education Agents

Commissions are a widely accepted practice across various sectors, including mortgage brokers, insurance, financial advisors, real estate agent and many more. Singling out one professional sector of onshore education agents creates an unfair double standard. It is unjustified and discriminatory. Internationally, commission-based student recruitment is norm. The proposed ban on Australian onshore agents would create a global outlier, reducing Australia’s ability to compete in the international education market. The war here is not about onshore agents Vs offshore agents. It’s about perception. There may be a bias that onshore agents are less reliable or ethical, leading to disproportionate focus on their practices while overlooking potential issues in offshore recruitment all together where industry is much more irregulated and “fee after visa” terms are tarnishing the whole industry for long time. Onshore agents will be placed at a competitive and unfair disadvantage compared to larger international agencies that operate with different geographical areas and still representing Australian education system over there. 

5. No Clear Benefits or Evidence for the Ban

The government has not outlined any concrete benefits of the commission ban. Specifically, there has been no clear explanation of how the commission ban will improve transparency, benefit Universities or Institutions, enhance student experience or their study outcomes. To date, no data or projections have been made available on the potential impacts of the ban. Without a risk analysis, the policy lacks credibility. Such a significant policy should be grounded in data, industry consultation and research. However, this commission ban appears rushed and politically driven, without thorough consideration of its consequences. There is limited or no empirical evidence demonstrating that banning commissions leads to improved outcomes for students or the education system as a whole.

6. Harm to Australia’s Skilled Workforce Pipeline

International students, recruited by onshore agents, are a vital source of skilled labour for Australia. They contribute positively to the economy and society, often becoming permanent residents or citizens. By hampering student recruitment and retention, the commission ban could affect Australia’s ability to attract and retain talented individuals who contribute to the skilled workforce. Many international students fill critical skill gaps in industries such as healthcare, aged care, support work, hospitality, engineering, construction, technology and many more sectors. A reduction in their numbers could exacerbate existing workforce shortages in these sectors. Many international students transition to skilled work and residency in Australia. A decline in enrolment could diminish the pool of future skilled migrants who contribute to the economy.

7. Regulation, Not Elimination

Rather than imposing a blanket ban on commissions, we propose a more balanced approach. Regulating, rather than eliminating, commissions and bonuses for education agents in Australia can strike a balance between ethical recruitment practices and the operational viability of agents. The government should engage in industry consultation with key stakeholders like onshore agents, Universities, private RTOs, ELICOS providers etc.  to develop policies that are both effective and sustainable. 

Conclusion

The commission ban on onshore education agents under the ESOS Amendment Bill 2024 is a misguided policy that threatens to destabilize Australia’s international education sector, reduce economic growth, and harm the interests of students, agents, and education providers alike. We strongly urge the government to scrap ANY SUCH bill and engage in meaningful consultation with industry stakeholders to draft a more balanced and evidence-based policy. By working together, we can ensure that Australia remains a global leader in international education, while protecting the livelihoods of thousands of professionals and the interests of international students.

We kindly request that you consider these points and revise the proposed bill to better serve the international education sector and its stakeholders.

Sincerely,

             

 TEAM MECAA  

 

(Migration and Education Consultant Alliance Australia)

Group of 600+ Education and migration agents who are playing active roles for building better educated society.