1. The purpose of our procedure
This procedure outlines our process for appointing, managing, reviewing and terminating of education agent arrangements for student recruitment activities.
Please read this procedure with the:
2. Who our procedure applies to
This procedure applies to members of the Adelaide University Community involved in the appointment and management of education agents, both overseas and within Australia.
3. Our education agents procedure
3.1 How we undertake due diligence
Regional Managers, International Recruitment conduct a preliminary assessment of prospective education agents and submit the outcome to the Executive Director, Future Students for endorsement.
The preliminary assessment considers alignment with:
- student recruitment objectives
- Admissions Policy principles and university business needs.
If the preliminary assessment does not satisfy these requirements, the prospective education agent is notified in writing.
Where the preliminary assessment is endorsed, the Agent Management team will complete the quality assessment and complete due diligence checks.
Staff must also assess the likely recruitment opportunities in the nominated country or region balanced against the number of commencements anticipated by the prospective education agent.
The Agent Management team refers the completed due diligence to the Regional Manager, International Recruitment for review.
3.2 How we approve arrangements
The Regional Manager, International Recruitment obtains endorsement for the proposed agreement from the Director, International Recruitment for education agency agreements and the Senior Manager, English Language Centre Operations for English Language Centre agency agreements, before submitting a recommendation and proposed agreement terms to the Executive Director, Future Students.
The Executive Director, Future Students recommends appointment or non-appointment to the relevant delegate. The relevant delegate approves or declines the appointment in accordance with the Delegation Policy.
The Executive Director, Future Students ensures the prospective education agent is notified in writing of the decision, including reasons. The Executive Director, Global Partnerships is informed where a partner education provider is to be appointed as an education agent.
3.3 How we develop and execute agreements
Following approval to appoint an education agent, the Agent Management team:
- prepares the agency agreement
- consults Legal Services
- nominates an account manager.
The agreement is executed by the relevant delegate in accordance with the Delegation Policy.
3.4 How we implement arrangements
Account managers provide induction and regular training to education agents to ensure they understand and meet their compliance obligations. They also manage the agent relationships.
Education agents are provided with accurate and up to date information about Adelaide University programs and services. Account managers ensure education agents understand and use this information to provide accurate and clear advice to prospective students.
3.5 How we monitor arrangements
The Agent Management team oversees monitoring of agent performance and prepares an annual performance review that includes:
- compliance with agreement and regulatory requirements
- quality of prospective student applications
- numbers of enrolled students and withdrawals
- student or stakeholder feedback
- data obtained from Provider Registration and International Student Management System (PRISMS)
- publicly and non-publicly available materials and resources
- genuine student requirement refusals, visa approval, refusal and cancellation data
- the number of students who are made an offer who commence, levels of student engagement and their academic progress, retention and completion, and other relevant information lawfully received by Adelaide University.
Where Adelaide University becomes aware, or has reason to believe, that an education agent, or the agent’s employee or subcontractor, has not complied with the National Code or the agency agreement, the University will take immediate corrective action.
Corrective action may include:
- additional targeted training, information or counselling, with costs to be agreed between the parties
- suspension of the agency agreement in one or more territories
- termination or non-renewal of the agency agreement
- legal action to recover any loss or damage incurred by Adelaide University
- any other corrective action Adelaide University considers appropriate.
A decision to suspend or terminate an agency agreement, or to take legal action, must be endorsed and approved in accordance with the Delegation Policy.
The account manager must notify the Senior Manager, International Compliance within three business days if they become aware that an education agent, or the agent’s employee or subcontractor, has been convicted of an offence or is subject to cancellation, suspension, disciplinary action, remedial action or conditions under section 17 of the Education Services for Overseas Students Act 2000 (Cth).
3.6 How we renew agreements
The Agent Management team initiates renewal or non-renewal at least three months prior to agreement expiry.
A renewal review assesses the agent’s previous and current performance and compliance with the agreement.
Where the agreement involves a partner education provider, renewal recommendations are made in consultation with the Executive Director, Global Partnerships.
The account manager completes the renewal form and recommends whether to renew the agency agreement. The recommendation is based on the expected outcomes originally proposed, the renewal review, the annual agent performance review, and whether there is a clear justification for continuing the agreement.
The account manager may recommend non-renewal of an agency agreement where one or more of the following apply:
- the education agent has generated no student commencements, or only negligible student commencements, during the agreement term
- the education agent has engaged in fraud, negligence, misleading conduct, poor student service or other conduct that may adversely affect Adelaide University’s reputation
- known or reasonably suspected breach of the agency agreement
- the original business case or value proposition no longer supports continuation of the agreement
- changes to the education agent’s business adversely affect the original business case.
The English Language Centre is advised of potential renewal or non-renewal of an agreement.
Renewal decisions by the Regional Manager, International Recruitment are endorsed by the Executive Director, Future Students, and approved by the relevant delegate.
The Agent Management team advises the education agent in writing of Adelaide University’s decision.
For agreements involving a partner education provider, the Executive Director, Global Partnerships must be informed of the renewal review outcome, the annual agent performance review outcome, and the justification for continuing or not continuing the agency agreement.
3.7 How we terminate agreements
Termination is managed with advice from Legal Services.
The Agent Management team considers:
- rationale for termination
- transition arrangements
- legal, financial and reputational impacts
- other areas of Adelaide University, directly and indirectly involved in the partnership
- compliance with relevant regulatory and legislative requirements.
Agency agreements will be terminated immediately if Adelaide University has reason to believe an education agent or an employee or subcontractor of that education agent has engaged in false or misleading recruitment practices.
Termination decisions by the Regional Manager, International Recruitment are endorsed by the Executive Director, Future Students, and approved by the relevant delegate and communicated in writing.
3.8 How we manage record keeping
The Agent Management team:
- record executed agreements and supporting documentation in accordance with the Records Management Procedure
- lodge the executed agreement with Records Management for registration as a legal document in Content Manager, the University’s legal document register, by completion of the Legal Document Lodgement Form including defined governance meeting cadence and performance monitoring.
Account managers must provide timely updates to the Agent Management team to ensure that education agent information is maintained and must record all interactions with education agents.
3.9 Our annual reporting
The Agent Management team together with the Senior Manager, International Compliance, prepares an annual report on education agent performance and activity for the Academic Board.
4. Who holds a responsibility within this procedure
Refer to the Delegation Policy for all delegations at Adelaide University.
4.1 The Executive Director, Future Students is required to:
- review recommendations for education agent appointments and endorse recommendations to the relevant delegate.
4.2 The Executive Director, Global Partnerships is required to:
- consult on arrangements involving partner education providers.
4.3 The Director, International Recruitment is required to:
- endorse recommendations for the appointment of education agents.
4.4 The Senior Manager, English Language Centre Operations, is required to:
- endorse recommendations for the English Language Centre agreements before endorsement by the Executive Director, Future Students.
4.5 Regional Managers, International Recruitment are required to:
- conduct preliminary assessments of prospective education agents.
4.6 The Agent Management team is required to:
- coordinate due diligence, assessments and approval documentation
- manage agreement development and execution processes
- maintain central records of education agent arrangements
- oversee monitoring, annual review, reporting and renewal processes
- prepare the annual report for the [Academic Board].
4.7 Account managers are required to:
- manage the education agent relationship, including monitoring ongoing performance and compliance.
5. Definitions used in our procedure
Please refer to our Adelaide University glossary for a full list of our definitions.
Account manager means an Adelaide University staff member appointed by the Director, International Recruitment to be responsible for the management of a specific signed agreement including liaison with both internal and external stakeholders as applicable.
Adelaide University Community refers to a broad range of stakeholders who engage with Adelaide University and includes (but is not limited to) all students, staff, and non-staff members of Adelaide University including alumni, honorary titleholders, adjuncts, visiting academics, guest lecturers, volunteers, suppliers and partners who are engaging with and contributing to the work of Adelaide University.
Education agent means a person or organisation (in or outside Australia) who recruits overseas students and refers them to education providers in doing so, the education agent may provide education counselling to overseas students as well as marketing and promotion services to education providers.
Education agent relationships mean relationships between Adelaide University and education agent whereby the education agent has been appointed as an authorised representative to facilitate the recruitment of students to Adelaide University.
Partner education provider means an entity (university or private) which delivers education study programs outside of Australia, and with whom Adelaide University has an established or proposed written agreement.
Student recruitment means the promotion and marketing of Adelaide University by the education agent with the goal of having students apply and enrol in a university course or program in return for a financial payment to the education agent.
6. How our procedure is governed
This procedure is categorised, approved and owned in line with the governance structure of Adelaide University and the offices and officers listed below.
Parent policy | |
Policy category | Corporate |
Policy owner | Deputy Vice Chancellor – International and External Engagement |
Approving authority | Vice Chancellor and President |
Procedure owner | Deputy Vice Chancellor – International and External Engagement |
Responsible officer | Executive Director, Future Students |
Effective from | 1 January 2026 |
Review date | 5 years after date this version is approved |
Enquiries | Policy Unit policy.enquiries@adelaide.edu.au |
Replaced documents | None |