International delivery

Risk overview

Accelerated growth in the number of international students, with numbers preceding pre-pandemic levels, has increased the risk of student exploitation and potential risks to quality and integrity in international education. Some providers offering courses approved on the Commonwealth Register of Institutions and Courses for Overseas Students (CRICOS) are not genuinely delivering education to international students, which damages the reputation of Australian education and undermines fair competition in the VET market.

These providers support visa fraud by not enforcing class attendance or progression requirements and facilitate academic cheating as a shortcut to meet assessment requirements for students who have not genuinely undertaken study. These providers also potentially expose their staff and students to criminal activities, including student labour exploitation and human trafficking.

Key points from research

1. Some ESOS providers are not meeting obligations to monitor an overseas student’s course progress and attendance to ensure overseas students can complete the course in which they are enrolled within the expected duration specified on their Confirmation of Enrolment.
2. Some providers and third parties are engaging in misleading or hostile marketing practices, Marketing for ‘ghost college’ RTOs typically centre around claims of visa application success and ensured migration pathways, rather than the education itself.
3. Some providers are issuing fraudulent qualifications to both onshore and offshore international students for financial gain, either via recognition of prior learning or where the student did not undertake the required study.
4. Professional facilitators such as education and/or migration agents may enrol their clients into RTOs they own or manage, possibly presenting a conflict of interest detrimental to students – for example, vulnerable students being signed up for VET courses without knowing who their provider is, or the use of unethical or unlawful contracts that may violate Australian consumer protection laws.

Our regulatory response

We are conducting a ‘compliance blitz’ on the standards and conduct of CRICOS providers to safeguard Australia’s international reputation as a provider of high-quality education and training. Providers who are not doing the right thing can expect an unannounced monitoring visit from us. 

We are:

• targeting our monitoring of Fit and Proper Person requirements, student attendance, delivery locations, student recruitment practices, agent management, financial viability, and false and misleading marketing practices 
• using our full range of regulatory tools, monitoring (intelligence, data and surveillance), including unannounced site visits, investigations and a range of compliance enforcement actions
• responding to serious non-compliance with enforcement of sanctions to remove or suspend the registration of providers as well as court actions against non-registered organisations that are operating illegitimately
• applying expanded offence and civil penalty provisions to cover a broader range of false or misleading representations by RTOs about their operations, and increased maximum penalties for breaches of relevant offences or civil penalties under the NVETR Act – for example, for issuing false qualifications
• collaborating with policy agencies and stakeholders on reforms to strengthen integrity and lift the standards in international education, tackle exploitation of the student visa system, and support measures to meet skills needs.