On 5 December 2025, significant legal reforms came into effect in Australia’s international education sector. The Education Legislation Amendment (Integrity and Other Measures) Bill 2025 amended the Education Services for Overseas Students Act 2000 (the ESOS Act) and related laws, bringing major updates to the compliance rules for CRICOS-registered providers. The aim is to strengthen trust in the sector and raise quality standards by responding to ongoing concerns about providers and agents who do not follow the rules. The reforms also seek to stop low-quality providers from quickly entering and leaving the market and to prevent agents from exploiting the student or visa system. For providers, these changes will bring new responsibilities and increased oversight compared with the past.
In this article, we look at the main changes introduced by the 2025 reforms, what is genuinely new or improved compared with the old ESOS rules, and what these updates mean especially for smaller VET colleges and new businesses. We also discuss how the Meshed Student Management Platform fits into this new structure and helps providers manage these challenges.
Overview of the 2025 ESOS Integrity Amendments
The Integrity and Other Measures Bill 2025 became law in December 2025. Its provisions took effect on 5 December 2025, introducing new changes for all institutions registered on CRICOS.
The main purpose of these amendments is to improve quality and transparency in international education broadly through the following measures:
- Defining and regulating the role of education agents and commission payments more clearly than ever before.
- Applying stricter “fit and proper” criteria to providers.
- Raising the bar for new providers entering the market by requiring prior domestic delivery.
- Removing long-inactive providers from the system through cancellation of registration after sustained inactivity.
- Increasing the government’s powers to suspend or cancel courses and registrations.
- Extending internal review periods for regulatory decisions.
Key Changes Under the 2025 ESOS Amendment Bill
New Definition of “Education Agent” and Regulation of Agent Commissions
One of the important changes is clarifying who is considered an “education agent” and introducing new rules for commissions paid to agents. Under the amended law, anyone who is not a salaried employee of the institution but helps to recruit or refer international students is now treated as an “education agent”. This includes sub-agents, overseas partners and similar parties; in other words, all third parties who contribute to student recruitment are legally recognised as “agents”. This closes off the familiar escape lines such as “this person is not officially our agent”.
The Act also explicitly defines the concept of an education agent commission in ESOS for the first time. This covers any kind of payment or benefit given to an agent in return for bringing in students: money, gifts, travel, bonuses and so on. The critical point here is: providers must now collect all information relating to these commissions and submit it when requested by the department. The amendment also introduces, for the first time in the ESOS Act, a clear definition of education agent commissions. This concept covers all monetary payments and any other advantages or incentives provided to an agent in return for recruiting or referring international students.
Increased Transparency in Agent–Provider Relationships
The reforms require education providers to make public information about their agents and business partnerships. Providers must share which agents they work with and the results of these collaborations, for example, student enrolments, attendance and achievement data. With this, they will be able to use the data to more easily identify concerning patterns such as high commissions associated with certain agents or negative student outcomes such as low achievement or high dropout rates. The aim is to help providers choose ethical, high-quality education agents and to give students a clearer sense of the agents who represent them.
Stricter Provider Requirements
The amendment further tightens the criteria used to assess whether an education provider is suitable to be registered on CRICOS. ESOS bodies must now take into account whether there are any conflicts of interest or control relationships between the real owners and decision-makers behind the provider and the education agents it works with. Regulators will also examine whether the provider or any associated persons are under investigation for specified offences. Such complex business links or legal issues may mean that a provider fails the “fit and proper person” test.
New Two-Year Operating Prerequisite for VET Providers
Most new vocational education and training (VET) providers must now demonstrate that they have delivered education to domestic students for at least two years before they can register to teach overseas students. This rule does not apply to public TAFEs. Providers that wish to move into the international space will now have to plan according to this requirement.
Cancellation After 12 Months with No International Students
The amended law allows a provider’s registration to be cancelled if it stops delivering education to overseas students for 12 consecutive months. In such a case, the provider will be removed from the CRICOS system. Schools and colleges will therefore have to monitor their international student enrolments much more carefully.
Increased Ministerial Powers to Suspend or Cancel Registrations and Courses
The changes grant the Department of Education new powers to halt new provider registrations or to suspend or cancel particular courses for overseas students. These powers are intended to enable a rapid response to issues of quality and legal compliance. Institutions must closely follow directions from the Department and ensure that their courses meet quality standards.
Extended Internal Review Period for Regulatory Decisions
Regulators now have 120 days to review certain decisions. The new law also allows them to temporarily suspend the effect of a decision during the review. The new law further allows the relevant decision to be put on hold temporarily while the review is in progress. For example, if a provider appeals a decision to refuse registration or impose a suspension, it may, under certain conditions, be allowed to continue operating while that appeal is being considered.
This arrangement is important in two respects:
- For providers, it helps to prevent sudden and irreversible consequences and creates a fairer process.
- For regulatory bodies, it offers more time to assess complex cases.
How the Meshed Platform Helps Institutions Stay Compliant
Now that these reforms are in force, education providers in Australia will need robust learning systems to meet the new compliance requirements. Meshed’s student management platform includes features that help institutions manage both regulatory compliance and a transparent, reliable way of operating.
Agent Data Tracking
Meshed allows institutions to record all education agents, link each student application to a particular agent, and track commission details and outcomes. Providers can easily share commission information via the platform when required.
Audit Trails and Integrity
Every action within the Meshed system is recorded, creating a reliable audit record covering student files, enrolment processes and changes to qualifications. All records are kept accurate and ready for audit. Meshed will not issue any certificate or diploma until all academic criteria have been met.
Supporting Provider Eligibility
Meshed helps providers maintain the operational records and quality standards required under the new law. Because the system manages both domestic and international student cohorts in a single system, providers can build the two-year domestic delivery history needed for CRICOS registration using the Meshed platform.
Simplified Compliance Reporting
Meshed connects with systems such as PRISMS and TCSI, synchronising international student data and visa updates. Enrolments, course changes, completions and cancellations are transmitted on time with minimal manual effort. Reports for audits or regulatory requests can be generated quickly.
Provider Challenges Under the New Rules and Meshed’s Solutions
Although the reforms are designed to improve the sector, they also create challenges, especially for smaller providers. Small vocational education colleges may find it difficult to operate solely in the domestic market for two years before enrolling international students. Meshed supports providers from the beginning by enabling domestic student management and performance tracking, helping them through this period.
Providers that rely heavily on education agents now face a much heavier compliance workload. Meshed reduces this burden by automating agent management and commission tracking. With the new law enabling authorities to act much more quickly, providers face higher risks arising from errors or missing data. Meshed helps you reduce this risk through alerts, validation checks and dashboards that highlight potential compliance issues at an early stage.
Our Final Thoughts on the New Law
By following these steps, Meshed Group will be able to strengthen its position as a trusted partner for education providers operating under the 2025 ESOS framework. The reforms promote higher quality and transparency standards in Australia’s international education sector, and Meshed’s student management platform supports this new law by making it easier for providers to integrate the new ESOS requirements seamlessly into their day-to-day operations.
Each new rule is an opportunity for providers to improve their compliance processes and for Meshed to add value. By guiding its clients through these changes, Meshed will reinforce its role within Australia’s global education system and support the country’s focus on quality, integrity and sustainability.
