Australia should introduce a registration system for education agents to prevent “bad actors” sullying the reputation of international education, according to a report.

The register would need to be compulsory, with government oversight “essential” to ensure “credibility and consistent uptake”.

Authorities must also make better use of existing regulation to stamp out misbehaviour – particularly poaching, which it says is best managed through enforcement of the current rules along with imposition of new visa requirements.

The , by Melbourne consultants Edified, acknowledges Canberra’s “jurisdictional limitations” in controlling agents outside Australia. Nevertheless, government agencies could boost the “effectiveness of existing safeguards” through more rigorous policing.

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“Enforcement is uneven,” the report says. “Bad actors can continue to operate through gaps in oversight, data visibility and accountability.”

It recommends “routine” site visits to Australian schools, colleges and universities, combined with more active monitoring of their compliance with regulations in the Education Services for Overseas Students (Esos) Act and the National Code of Practice for Providers of Education and Training to Overseas Students.

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But educational institutions must also contribute through data sharing and “student feedback loops”. And they must be held accountable for the behaviour of the agents they enlist.

The report was commissioned in November by the International Education Association of Australia (IEAA), which had assembled a committee to scrutinise education agents’ behaviour amid escalating integrity concerns.

Chief executive Phil Honeywood said Canberra had made agent governance and integrity a key priority, and the IEAA wanted to equip the government with “a way forward…informed by global best practice”.

The report offers three models for the proposed register of agents. IEAA vice-president Jonathan Chew, chief insights officer at Navitas, said the report did not “jump to any conclusions” about which option was best.

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Instead, it “provides a menu of measured and meaningful regulatory models,” Chew said. “The detail is there to inform future analysis and consultation.”

The basic model features a compulsory register managed by government and co-designed by international education operators and representatives. Agents could be deregistered for non-compliance, while institutions would sign on to a code of ethics and “baseline” training.

Under the second model, the register would be “searchable” and agents would have to renew their registration every two years. Reporting of agents’ non-compliance would be mandatory, data sharing would be encouraged and training would be more extensive.

The third model would feature publication of agents’ registration status and monitoring of their compliance. “Sub-agents” and individual counsellors would be listed on the register, training would be ongoing and data sharing would be handled through a centralised platform.

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The register could be managed within the Department of Education to ensure access to “existing Esos enforcement levers” and data on students and providers. “The framework should be scalable, beginning with a light-touch approach and building over time as needed,” the report says.

It says Australia’s regulation of international education is “mature” and “comprehensive”, but “regulation alone is insufficient when enforcement is inconsistent and system gaps can be exploited.

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“The quality of education agent practice is largely managed through private, bilateral arrangements between institutions and agencies. This can result in fragmented oversight with limited transparency. [We need] greater visibility of the scale of the issue.”

john.ross@timeshighereducation.com