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Clamping down on unscrupulous student recruitment agents

The use of international agents carries major reputational risks. Vincenzo Raimo, Pii-Tuulia Nikula and Eddie West call for transparency and protection of student interests
This article is more than 1 year old

Vincenzo Raimo is a higher education consultant and visiting fellow at the University of Reading


Pii-Tuulia Nikula is a Principal Academic at Te Pūkenga – New Zealand Institute of Technology and Skills


Eddie West is Assistant Dean of International Strategy and Programs at San Diego State University

It has been over a month since home secretary Suella Braverman announced plans to crack down on “unscrupulous” education agents. However, details about the implementation of this new policy remain scant.

If we truly prioritise the wellbeing of students, as both government ministers and universities often claim, we should welcome this objective and provide support to the Home Office and the Department for Education in developing and implementing a policy that safeguards genuine students.

Full disclosure

It should be in the best interest of all universities to eliminate bad and unscrupulous agents from the market and allow reputable agents to thrive.

We should stand behind former universities minister Jo Johnson’s call for greater transparency about the role played by education agents and the need for Office for Students to publish agent performance indicators, including visa success rates, non-continuation rates, and completion rates of students supported by agents during their application to and enrolment at UK universities. This data would prove invaluable to prospective international students as well as universities seeking reliable agents while avoiding untrustworthy ones.

However, we encourage the government to go further and mandate universities to disclose the terms of their relationships with agents. These intermediaries, whom universities contract and incentivise to persuade prospective students to choose them over their competitors, should not operate in secrecy.

On commission

We estimate that UK universities collectively spent over £500 million on agent commissions last year, yet this area of their operations remains largely hidden.

There should be no room for covert agents within our universities. Prospective students should be able to easily find the names of a university’s agents, the services offered by these agents, and any associated costs students applying through them are expected to bear.

Importantly, prospective students should also be aware of how much universities pay their agents. Prospective students, much like those seeking financial services in the UK through an intermediary, should be able to assess the independence of the advice they receive when choosing one institution over another.

According to a survey conducted by the British Universities International Liaison Association (BUILA) reported in its good practice guide for providers using agents, a significant proportion of UK university international student recruitment staff believe that agents are motivated to send students to institutions offering higher commission fees. Is paying a higher commission than your competitor to your agent really putting the interests of students first?

A reputational risk

Followers of AgentBee, which monitors and reports on the actions of education or international student recruitment agents, are well aware of the many distressing stories where prospective students have been exploited by deceitful and unscrupulous agents who take advantage of their aspirations for an international education. Universities and the government must work together to protect students and prevent reputational damage.

We believe that universities should take much greater responsibility for the actions of the agents they engage to act on their behalf. We endorse the BUILA/Universities UK International (UUKi) recommendations for universities to thoroughly vet prospective agents and continuously monitor their work.

However, we find the guidelines published by BUILA and UUKi puzzling when it comes to commission transparency. The guidelines advise against universities publishing commission fees, arguing that doing so may be perceived as “collusive behaviour.” But it’s not really clear how the publication of agent commission rates constitutes collusive behaviour in the education industry and not, for example, in the financial services sector, or how it compares to other actions taken by universities, such as the way they publish their international tuition fees.

There’s a risk that the sector is perceived as concealing the escalating costs of international student acquisition and the sometimes uncomfortably close relationships between university recruiters and the growing number of commercial intermediaries involved in the international student mobility industry. As well as agents, these intermediaries can include a range of other actors such as rankers, portions of the education press, international student loan providers, student accommodation companies, pathway providers, and student travel and international student concierge services.

It’s agents all the way down

Close observers of the international recruitment ecosystem are well aware of the growing footprint of agent aggregators. Whilst so-called “master agent-sub agent” relationships have long existed, what’s new under the sun is the sheer size and complexity of these operations. The aggregators operate at increasing scale, in many cases subcontracting with thousands of sub-agents around the world. The aggregators’ growing influence has further undermined efforts at greater transparency, given that few if any of them make public their list of sub-agents.

It is good to see that some Australian universities are now actively considering transparency of agent commissions, much to the chagrin of the International Education Association of Australia which opposes commission transparency. The chief executive of the Group of the Eight, Australia’s Russell Group equivalent, recently asked “why would we not require disclosure of commissions?” and warned the Joint Standing Committee on Foreign Affairs and Trade that “our reputation… is going to be damaged if we don’t actually address the reputation of our agents and the disclosure and transparency.” It would be great to see individual universities or university groups show leadership in this area. Of course, adding the requirement of commission transparency to the Australian ESOS legislation might have some unintended consequences, such as an increase in non-commission payments, which would need to be carefully considered.

Transparency from agents, universities, and governments is a recurring theme in Student Recruitment Agents in International Higher Education. We had the privilege of editing this book which shares research on the agent industry and highlights best practices from agents, university recruiters, and governments. The book also sheds light on the proactive measures taken by the governments of Australia and New Zealand to regulate how their education institutions work with agents. We urge the UK government to also start playing an active role in protecting genuine international students hoping to study in the UK.

5 responses to “Clamping down on unscrupulous student recruitment agents

  1. Frankly speaking I’m always sceptical of taking advice from so called experts who aren’t working at the coal face, or dealing with agents daily and are not tasked with meeting recruitment targets. This story is a bit like an old sports injury, it calms down and then a bad tackle, like Suella, results in it once again flaring up. Agents are absolutely essential to our recruitment efforts, ok stating the obvious, but the reason organizations such as BUILA get heavily involved, is to help ensure people like our Govt, who know nothing about our sector, aren’t the ones making the rules. Also, to suggest that we should hold agents accountable responsible for student outcomes is utter nonsense. Universities set the entry criteria for admission, agents work to these for admission, it’s incumbent upon the University to ensure a student passes, not an agent 3000 miles away. The University’s admissions systems and their CAS issuance policies should be robust enough to weed out the non genuine students, and if there’s pattern developing therein, take action with agent involved, sacking them if justified. On the issue of being transparent about commission rates, this is utterly pointless and unhelpful to students, so they see what will be published – a range of 15-20% – and?? This is just more noise, achieves nothing, doesn’t help students, is potentially commercially sensitive and won’t happen IMO. In regards to aggregators, we should welcome them, as many of their agents will be the unscrupulous ones who can’t get contracts with Universities directly, so the aggregators must manage the quality process and are held accountable for the quality of the student in terms of visa success etc. They will live or die by their reputation so they will be careful who they recommend to Universities. A lazy article all in all.

    1. Countries like Sri Lanka, some aggregators have appointed more than 150 sub agents under their master agent contracts. They even appointed travel agents and they work with rough financiers as well. You can imagine such a small country got so many small agents and they do not even did their studies in the overseas.

  2. I agree with Coal Face Frank, there is no value in publishing commission rates. This is a B to B relationship between the University and the agents; it is also commercially sensitive information. I will also note (which this article suprisingly does not) that Mr Johnson is a board member and investor in one of the largest aggregators: Applyboard. Finally I will note that Apply Board does not reveal its sub agent network, which is concerning to HEIs who use them. Surely of relevance to this story?

  3. These are the same so called experts who told us all recruitment would go into decline through and after Covid. They are akin to professional politicians, they simply don’t get it and can’t as they aren’t close enough to the day to day. I don’t blame Wonkhe tbh, they are like all the other organisations out there who just keep rolling out the same old people at conferences, webinars etc. I saw an ad today for a UUKi event titled the future of international recruitment. They don’t know the future, and they definitely know less than I do, and many others in the country, they create and fuel and justify their own existence. Aside from some lobbying which is occasionally useful, though dependants lobbying was a terrible failure, they add little or no value, yet the sector and the media related to HE keep quoting them etc. It’s so boring, Universities do all their own work, none of these quangos really help, I should join one on reflection, it might be relaxing to have no targets to meet, Exec to satisfy, and a 9-5 day, every day. Ah, I’m the mug.

  4. The usual lazy, regurgitated stuff, suppose it fills column inches but doesn’t reflect well on the sector as a whole. HE is a business, supply and demand, profit & loss, and as such bends and waves with the current winds, always has always will, it just comes in different guises. Be good to see how many agents, and HE practitioners, provided input to this article and many others very similar to it. Having been in the business for more years than I care to remember, not much changes except technology.

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