Regulatory Alert: Onshore Commission Ban Confirmed – The Future of Australian Student Transfers

Major Law Enacted: Integrity Act 2025 Transforms Student Mobility

Australia’s international education framework has entered a new regulatory era.

The Education Legislation Amendment (Integrity and Other Measures) Act 2025 has now been officially enacted, delivering one of the most significant reforms to the student visa ecosystem in over a decade.

This legislation strengthens the Education Services for Overseas Students Act 2000 (ESOS Act) and gives the Australian Government enhanced enforcement powers to protect international students from unethical recruitment and transfer practices.

Key Legislative Facts

• Royal Assent: 4 December 2025
  

• Commencement: 5 December 2025

• Policy Objective: Eliminate financial incentives that encourage unnecessary or exploitative onshore student transfers

This reform directly affects current and prospective international students, as well as education agents operating in Australia and offshore.

The Core Policy Change: Zero Commission for Onshore Transfers

The most consequential reform under the Integrity Act is the confirmed prohibition on commission payments for onshore student transfers.

 What Is Now Banned?

For the first time, Australian law formally defines:

• “Education Agent”

• “Education Agent Commission”

This allows the government to explicitly regulate — and prohibit — certain payments through amendments to the National Code of Practice.

Under the new framework:

Commission payments to education agents for students transferring providers while already in Australia are strictly prohibited.

  What Is an Onshore Student Transfer?

An onshore transfer occurs when:

• An international student is physically present in Australia, and
  

• Transfers their enrolment from one CRICOS-registered provider to another

This includes transfers between:

• Colleges
  

• Universities
  

• VET providers

• ELICOS providers

Scope of the Ban

The prohibition is broad and comprehensive.

It applies to any incentive that encourages an onshore transfer, including:

• Commission payments
  

• Referral or service fees
  

• Marketing support payments
  

• Cashback offers

• Non-monetary benefits or rewards

Rebranding commissions under alternative labels does not bypass the law.

  Why This Change Is Crucial for International Students

This reform is designed to protect students, not restrict choice.

1. Objective, Student-First Advice

Without commission-driven incentives, agents and intermediaries are legally required to prioritise:

• Academic progression
  

• Course suitability

• Long-term career outcomes

—not profit.

2. Higher Education Quality Standards

Education providers must now compete on:

• Teaching quality
  

• Student support services

• Genuine post-study and migration pathways

rather than offering high commissions to attract transfers.

 3. Reduced Course-Hopping Risks

Unnecessary transfers can negatively affect:

• Visa compliance
  

• Academic continuity

• Graduate visa eligibility

The ban reduces pressure on students to change providers for non-academic reasons.

Implementation & Compliance Timeline

While the Integrity Act is already in force, the operational enforcement of the commission ban is tied to the amended National Code of Practice.

What You Need to Know

• Legal Basis: ESOS Act amendments under the Integrity Act 2025
  

• Effective Application: Applies to all onshore transfers occurring after the amended National Code commences

• Status: Commencement is imminent

Important Warning for Students

If any agent or intermediary offers:

• Cash refunds
  

• Transfer bonuses

• Guaranteed incentives

linked to changing providers while you are in Australia, this may constitute a regulatory breach.

What International Students Should Do Next

 1. Review Your Academic & Career Goals

Before transferring, ensure your new course supports your:

• Career pathway
  

• Skilled migration eligibility

• Graduate visa strategy

(AiCademy’s AI Career Capacity Test can help with this assessment.)

 2. Verify Provider Compliance

Confirm that both your current and intended providers are:

• CRICOS-registered
  

• Fully compliant with ESOS and Integrity Act obligations
  

 3. Seek Ethical, Registered Advice

For guidance on:

• Onshore transfers
  

• Subclass 500 compliance
  

• Subclass 485 Graduate Visa

• Skilled or regional visa pathways

consult a registered migration or education professional.

 AiCademy’s Compliance-First Education & Visa Advisory

At AiCademy, our counselling framework is fully aligned with the Integrity Act 2025.

How We Help

• Ethical, non-commission-driven advice
  

• AI-based course-to-career mapping
  

• Visa-safe transfer assessments

• Long-term migration pathway planning

Your education decisions should be driven by future outcomes — not hidden incentives.

 Need Help With an Onshore Transfer or Visa Strategy?

 Thinking About an Onshore Transfer or Visa Option?

Make decisions that protect your student visa, future PR chances, and career outcomes.

No cashback
No hidden commissions
Fully compliant advice

Frequently Asked Questions: Onshore Student Transfer Commission Ban Australia

Q1: What is the onshore student transfer commission ban in Australia?

The onshore student transfer commission ban is a legal restriction introduced under the Education Legislation Amendment (Integrity and Other Measures) Act 2025, which prohibits education agents from receiving commissions or incentives when an international student transfers providers while already in Australia.

Q2: When does the commission ban take effect?

The Integrity Act commenced on 5 December 2025. The commission ban applies to all onshore student transfers after the amended National Code of Practice comes into force, which is expected imminently.

Q3: Does the ban apply to all education agents?

Yes. The ban applies to all education agents and intermediaries, regardless of whether they operate:

Onshore or offshore

• As individuals or agencies

• Any incentive linked to an onshore transfer is prohibited.

Q4: Can an international student still change courses or providers in Australia?

Yes. Onshore transfers are still allowed if they are:

Academically justified

• Compliant with visa conditions
• In the student’s best educational interest

The ban only removes commission-based incentives, not student choice.

Q5: What types of payments or incentives are now illegal?

The ban covers all forms of inducements, including:

Cash commissions

• Referral or service fees

• Cashback offers

• Marketing or promotional payments

• Non-monetary benefits linked to transfers

Renaming commissions does not make them legal.

Q6: How does this change protect international students?

The reform ensures that:

Advice is objective and student-focused

• Transfers are based on academic progression, not profit

• Providers compete on quality, not commissions

This reduces course-hopping and visa risk.

Q7: What should students do if an agent offers cash for a transfer?

Students should be cautious. Such offers may indicate non-compliance with Australian education law. It is recommended to:

Decline the offer

• Seek advice from a registered professional

• Verify CRICOS registration and visa implications

Q8: Does this affect offshore student recruitment?

No. The commission ban applies only to onshore student transfers. Offshore recruitment commissions are not covered under this specific reform.

Q9: Can this impact my student visa or future migration plans?

Yes. Unnecessary or frequent transfers can affect:

Student visa compliance

• Subclass 485 Graduate Visa eligibility

• Skilled migration planning

• Transfers should always align with long-term career and visa goals.

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