There was an audible collective sigh of relief from international student recruitment heads when the government agreed with the Migration Advisory Committee’s (MAC) recommendation that “the Graduate Route should remain in its current form.”
And the calling of the general election has provided a stay of execution for the implementation of the Home Secretary and Education Secretary’s announcement of undefined proposals to “regulate the recruitment of international students, cracking down on rogue agents.”
The MAC Review recommended that universities should be required to publish data on their spend on recruitment agents and the number of international students recruited through such means annually – data that universities have been increasingly unwilling to disclose.
For now, it seems likely that any proposals would include a strengthening of the Agent Quality Framework (AQF) Good Practice Guide for Providers using Agents – published by BUILA in 2021 – given the line “mandating universities to sign up to a stringent framework for agents.”
This could mean strengthening the hastily put together AQF Pledge in response to that Sunday Times “Pile them high” article earlier in the year.
The AQF pledge and its implementation
The pledge has now been signed by more than 130 universities and international pathway providers. These institutions have committed themselves to:
…ensuring that accurate information, advice, and guidance are accessible to all potential applicants, promoting a culture of proactive self-regulation, knowledge sharing, and best practices within the sector. The commitment also involves embedding the requirement for certified training and adherence to the National Code of Ethical Practice into legal contracts with agents.
But it is clear from a quick scan of university websites that there remain gaps in many institutions in implementing some of the commitments their leaders have made.
Current gaps and best practices
There are some examples of good practice, but many institutions have still not updated websites to list the agents they have contracted to recruit students on their behalf, explained the role of agents to prospective students, detailed what services students can expect from agents, or disclosed that agents are paid success and other fees for the successful enrolment of students.
Complaints procedures for prospective international students who have sought support from an agent also remain thin on the ground, and where they exist, thin on detail.
Uncertainty ahead
Of course, we won’t know the outcome of the election for another 6 weeks – and we have no idea what the Labour Party’s view of education agents is.
My letter to Yvette Cooper and Matt Western of 18 January 2024 remains unanswered.
But it would be prudent for international student recruiters to start getting their houses in order, be ready to stand by their AQF Pledge statements, and ensure they are at a minimum meeting the standards set out for them in The Good Practice Guide.
Introducing the compliance checklist
To support higher education providers in navigating these challenges, here’s a compliance checklist, grounded in the Good Practice Guide for UK Higher Education Providers Using Education Agents.
It covers various crucial aspects of agent management, including:
1. Agent Selection and Management
- Do we have a formal process for selecting education agents?
- Have we conducted due diligence checks on potential agents?
- Do we have written agreements outlining roles and responsibilities?
- Do we regularly monitor and evaluate the performance of our agents?
2. Agent Training and Support
- Do we provide training on institutional programs and application processes?
- Do we offer ongoing support and guidance?
- Are our agents provided with updated information about programs and policies?
3. Transparency and Integrity
- Do our agents provide accurate and transparent information to prospective students?
- Are our agents prohibited from making false claims or promises?
- Do we have mechanisms in place to address concerns about agents’ conduct?
4. Financial Arrangements
- Do we have clear policies on commission rates and financial agreements?
- Are these financial arrangements transparent and communicated clearly?
- Do we ensure compliance with relevant laws and regulations?
5. Recruitment Practices
- Have our agents signed up to the National Code of Ethical Practice?
- Are students provided with accurate information about program costs and visa requirements?
- Do we have processes to verify the authenticity of student documents?
6. Student Support and Welfare
- Do our agents provide adequate support throughout the application and enrolment process?
- Are students informed about support services at our institution?
- Do we have measures to ensure student safety and well-being?
7. Compliance and Monitoring
- Do we conduct regular audits and reviews of our agent network?
- Are there mechanisms for reporting non-compliance?
- Do we take appropriate actions in cases of misconduct?
8. Continuous Improvement
- Do we solicit feedback from students recruited through agents?
- Are there processes for continuous improvement in agent engagement?
9. Documentation and Record Keeping
- Do we maintain accurate records of all interactions with our agents?
- Are agreements and contracts kept up-to-date?
- Do we retain documentation for compliance and audit purposes?
10. Ethical Standards and Code of Conduct
- Do we have a clear code of conduct for agents?
- Are agents provided with guidance on ethical behaviour?
- Do we take action against agents violating ethical standards?
By leveraging tools like the compliance checklist, higher education providers can enhance their oversight of education agents, safeguard their reputation, and ensure a positive experience for international students.
It would also be prudent to develop data, where it is not already in place, to monitor the work of agents beyond just applications and enrolments, but also student progression rates at key points and rates of full tuition fee payments.
The full version of the checklist can be downloaded here.
