International agents are running rampant across Europe

But it’s increasingly clear that the level of cooperation required across Europe goes beyond national systems.

The pattern runs something like this.

An investigative journalist goes undercover and films a recruitment agent offering forged bank statements or making wild promises about easy employment, or cheap housing.

A broadcaster publishes the footage, a government announces a crackdown, and everyone acts as if this is a shocking new development – rather than the entirely predictable consequence of a funding model that treats fee-paying international students as cash cows while outsourcing their recruitment to unregulated middlemen.

In Finland, public service broadcaster Yle’s investigative unit MOT has spent the past year and a half documenting how third-party agents in India, Bangladesh, and other countries have been luring fee-paying students with false claims about part-time work, living wages, and a prosperous life in the “happiest country in the world.”

Students arrive heavily indebted and end up relying on food banks and social welfare. Universities of applied sciences acknowledged that partner agents had breached agreed principles but kept cooperating with them for months anyway.

At Arcada, the university admitted it had known about misleading claims by recruitment partners since mid-2023, continued the collaboration, and then apologised while refusing to refund tuition fees.

Students’ unions (SUs) have called for stricter oversight of agents, demanding reviews of agency agreements and calling for institutions to end the use of unreliable agents if responsible oversight isn’t possible.

In Sweden, public service broadcaster Sveriges Television (SVT) sent reporters with hidden cameras to visit recruitment agencies in Pakistan. Two of four agencies visited openly offered forged bank statements for a ten per cent commission and told prospective students they could drop out on arrival and work as cooks, delivery drivers, or cleaners.

According to SVT’s reporting, one recruiter was filmed claiming that the vast majority of their students don’t actually study. University West terminated agreements with four Pakistani agencies. Others – Dalarna, Linnaeus, and Skövde – remained “in talks.”

In Latvia, a TVNET investigation series raised the question of whether thousands of Uzbek students – making up almost nine per cent of all foreign enrolments – were actually studying or enrolled to secure residency and work. Latvian Radio and officials described some private colleges as effectively running an immigration business under the guise of education.

The Academic Information Centre flagged forged diplomas from multiple source countries. Parliament amended the immigration law to increase penalties and bar non-compliant institutions from inviting students, and diplomatic missions rejected 15 per cent of long-term study visa applications last year.

In Lithuania, authorities flagged a large number of study-related residence permits and revoked several hundred in 2025 for abandoned studies, though precise figures from primary sources are hard to pin down independently. Parliament advanced a bill halving bachelor students’ permitted work hours to 20 per week, restricting family reunification for master’s students, and creating a government-approved list of universities allowed to enrol foreign students – essentially a licensing regime for international recruitment.

In Denmark, the whole thing blew up over Bangladeshi and Nepalese students. The Ministry of Immigration and Integration announced in September 2025 that student visas had been “exploited as a backdoor to the Danish labour market.” Ministry data showed that 74 per cent of Nepalese students’ residence permits were linked to accompanying family members, compared with one per cent for Chinese students and two per cent for Americans.

Aarhus University reported that a third of its Bangladeshi cohort “do not appear study-oriented.” The government tightened academic entry requirements, cut the post-study work period from three years to one, restricted family reunification, and tasked the National ID Centre with retrospectively reviewing existing permits issued to Bangladeshi and Nepalese nationals.

Ministers presented the data as evidence of systemic misuse, but Bangladeshi and Nepalese students and community groups pushed back hard, arguing that the characterisation stigmatised entire national cohorts – and that part-time work was a matter of financial survival, not evidence of fraudulent intent.

In Poland, prosecutors charged 12 people over an alleged scheme involving more than 1,000 falsified documents issued by three private universities, with charges including organised criminal group participation, facilitating illegal residence, forgery, and money laundering.

Separately, the Tusk government suddenly re-enforced a dormant 1991 nostrification rule requiring foreign diploma verification. Recruitment agencies estimate the combined effect of tightened visa rules and nostrification enforcement may prevent 40 to 50 per cent of international students from arriving.

In the Netherlands, just last week the Labour Authority fined a college and two care providers a combined €700,000 for recruiting at least 62 Indonesian nursing graduates under false pretences, deploying them full-time as regular nurses while calling them supervised interns working 16 hours.

Internal immigration service correspondence from October 2021 had warned the project resembled exploitation to supply cheap labour. The college has since had its international recognition withdrawn – meaning it can no longer sponsor foreign students at all.

And beyond the EU, in Northern Cyprus arrests at one university over fake diplomas and embezzlement have exposed a sector where rapid growth to 23 largely profit-driven universities, lax visa controls, and weak regulation have turned international education into what journalists and the US State Department describe as a hub for corruption, trafficking, and smuggling. The higher education watchdog’s own chairman is under investigation over a suspected fake diploma. Northern Cyprus sits outside the EU regulatory space entirely, but the pattern of market failure is recognisably the same.

In Germany, the ambassador to India publicly warned students in June 2025 against agents offering “complete packages,” noting that nearly 15 per cent of Indian student visa applicants had submitted fake documents. The Foreign Office rolled out new automated verification infrastructure in late 2025, introducing multi-stage digital screening of visa applications before human review. And an RTL/Stern investigation exposed thousands of fake language certificates being sold via TikTok for around €1,500 each.

Ireland is also tightening. Ministers have ordered officials to draft measures to cut English-language student numbers and stiffen study-visa conditions, with options including a national quota linked to accommodation capacity, raised financial thresholds, and limits on part-time work. Minimum funds requirements were increased from June 2025 to €10,000 for the first year. Wider changes are expected from September 2026.

Victims or villains

The coverage – and the regulatory response – splits into two almost incompatible narratives, the split tracking uncomfortably along lines of which country is doing the telling and which country’s students are being told about.

In Finland and the Netherlands, the dominant frame was “students as victims.” The Yle investigations centred on indebted students relying on food banks. SUs drove the narrative toward institutional and agent accountability. The Finnish government talked about preventing students “falling into a vulnerable position.” The Dutch Labour Authority’s language was about “bogus constructions” that exploit workers. The blame landed squarely on institutions and intermediaries.

In Denmark and Latvia, the frame flips. Students weren’t presented as victims – they were presented as gaming the system. The Danish immigration minister’s framing was student visas as a “backdoor to the Danish labour market.” Ministry data on family reunification rates was deployed to suggest that migration, not study, was the primary motivation. In Latvia, the headline literally asked “Fictitious students?” The debate centred on whether enrolment is a pretext for residency, not on whether students were misled.

Both framings can describe the same person. A student who was promised easy employment by a fraudulent agent, arrived indebted, and then works 40 hours a week in hospitality while nominally enrolled is simultaneously a victim of misleading recruitment – the Finnish framing – an abuser of the student visa system – the Danish one – evidence of institutional failure to monitor attendance – the Latvian one – and a victim of labour exploitation – the Dutch framing.

Whether any particular individual is primarily one or several of these things depends on their specific circumstances – but the regulatory response in each country treats the framing as though it applies to the whole cohort.

The framing choice, though, tends to determine where regulatory action gets directed. Countries that lead with the victim frame tend to go after agents and institutions – Finland’s proposed agent ban, the Dutch fines. Countries that lead with the abuse frame direct action at students themselves – Denmark’s retrospective permit reviews, Latvia’s mass cancellations, Lithuania’s work hour restrictions.

There’s also – and this isn’t comfortable to say, but the coverage is consistent – a correlation with source countries. When students come from South Asia, the backdoor-to-the-labour-market framing is more prominent. When they’re from countries with less political salience in European migration debates – Indonesia in the Dutch case – the exploitation framing dominates. Denmark’s entire regulatory package was squarely triggered by and targeted at students from Bangladesh and Nepal.

Follow the money

But neither frame really gets at the structural question underneath – why does this keep happening, in variant after variant, country after country?

The answer isn’t a single cause – but three pressures that keep showing up in different combinations.

The first is fiscal dependence on international enrolments. European government after European government wants mass higher education but is struggling to pay for it. International student fees have become an almost universal pressure valve.

In Finland, a 2022 law change expanded English-language programmes and eased residence permits for non-EU students. At the same time, the government was making steep cuts to higher education funding. Metropolia’s deputy CEO openly admitted that without agents, an estimated 40 per cent of tuition-fee-paying students would be lost.

Latvia, Lithuania, and Estonia have declining domestic populations – birth rates have been falling for years, and emigration to western Europe has hollowed out the young adult cohort. Latvia’s education ministry framed revised foreign student admission rules as helping “replace declining domestic cohorts.” That’s not cross-subsidisation – that’s existential institutional survival. When your existence depends on international enrolments, the incentive to look the other way on recruitment quality is enormous.

Migration-system design doesn’t help. In Denmark generous work rights plus family reunification created an offer that agents could market as a migration package rather than an education product. The government essentially designed a system that was more attractive as an immigration pathway than as a study destination.

Sweden’s version is revealing in a similar way. Swedish universities are publicly funded and didn’t charge international students anything until 2011. When fees were introduced, enrolments from outside the EU collapsed. The recovery has been driven largely by agent-mediated recruitment from South Asia – and the agents are paid by the universities.

Halmstad alone paid 8.6 million kronor to agencies over three years. The universities need the fee income, the agents need the commission, and the incentives to check whether the student turns up to study are weak.

And then there’s labour-market demand. The Netherlands case wasn’t about university funding at all – it was about healthcare staffing shortages. Care providers and a college constructed a scheme to import Indonesian nurses as “students” to fill gaps that the Dutch labour market couldn’t. The incentive was cheap, compliant labour dressed up in an educational wrapper.

In Poland – and, outside the EU, in Northern Cyprus – there have been cases where what’s been documented looks closer to organised criminality and regulatory collapse than to the ordinary institutional pressures operating elsewhere. Some private institutions appear to exist primarily as visa businesses rather than educational institutions. At that point the question isn’t “why are universities cutting corners on recruitment?” – it’s “are these actually universities at all?”

Underneath all of that is a classic principal-agent problem. Universities pay agents per student recruited, agents maximise volume, and students are the product being sold rather than the customer being served. And because agents operate in source countries where the university has no presence and no realistic ability to monitor conduct, oversight is practically impossible even when institutions claim to want it.

The Finnish universities that said they’d “review and possibly terminate contracts” with dodgy agents are making a promise they can’t credibly keep unless they’re willing to forgo the revenue those agents generate – some think the funding model doesn’t give them an alternative.

They’re all scandals that sit at the intersection of fiscal dependence, migration-system design, and weak cross-border regulation of agents and sponsors. Any one of those pressures can generate problems on its own. When all three operate together, the result is the full spectrum of harms, from exploited students to fraudulent documents to institutional complicity.

A patchwork of panic

In Finland the Orpo government outlined three reforms – codifying minimum income requirements for non-EU students in law, introducing a one-year waiting period for family reunification on student permits, and investigating a potential ban on unofficial education agents – restricting recruitment to agents with formal university agreements.

On top of that, Finland has proposed revoking student residence permits if non-EU students claim basic social assistance, with automated data-sharing between the Social Insurance Institution of Finland, known as Kela, and the immigration service. A €100 application fee for non-EU applicants was introduced from autumn 2025 to deter speculative applications.

In Denmark the September 2025 package included tightened academic admission requirements with entrance exams and language tests at university discretion, strengthened document verification via the National ID Centre, restricted family reunification for third-country students, and reduced the post-study work period from three years to one.

Separately, rules introduced in May 2025 for “unaccredited” programmes stripped work rights and family reunification entirely from those visa categories – applications from Bangladesh and Nepal collapsed from 523 in April to 15 in May. The government then brought forward planned changes originally scheduled for summer 2026 to apply from winter 2025. And the National ID Centre was given authority to retrospectively review existing permits issued to Bangladeshi and Nepalese students for possible fraud.

Sweden has a proposed bill that would tighten study requirements and remove the possibility of working indefinitely on a student permit, but its adoption date remains undecided. Latvia has amended the immigration law to increase penalties and bar non-compliant institutions from inviting students – some 2,534 students’ residence permits were cancelled between 2022 and 2024.

Lithuania’s draft bill would halve permitted work hours, restrict family reunification, require Lithuanian language proficiency for permit renewals after five years, and – most significantly – create a government-approved list of universities allowed to enrol foreign students. And Poland’s response has been enforcement-led – prosecutions for alleged organised fraud – combined with the sudden re-enforcement of nostrification requirements that caught actual students in the crossfire.

Germany has invested in automated verification infrastructure – multi-stage digital screening of visa applications – and publicly warned applicants against agents, but hasn’t legislated specifically on recruitment practices. Ireland is still at the policy-options stage, with measures expected from September 2026.

Where is the EU

There’s no dedicated EU-wide framework for regulating education agents or coordinating student-recruitment integrity across member states. The EU does have shared migration and border information systems – the Schengen Information System and the Entry-Exit System – but nothing that specifically targets the agent networks, the institutional incentive structures, or the cross-border pattern documented above. Each member state is responding individually, reactively, and usually only after investigative journalists have done the work that regulators should have been doing all along.

The question is whether this has to be the case – or whether there’s enough legal competence for the EU to act, if it wanted to.

Article 165 of the Treaty on the Functioning of the European Union (TFEU) gives the EU only supporting, coordinating, or supplementary competence in education, and directly prohibits harmonisation of member states’ laws. The EU can’t legislate to tell universities which agents to use or what admissions standards to apply. That’s the biggest single barrier to pan-European action on the recruitment side.

But immigration is different. Article 79 TFEU gives the EU competence to develop a common immigration policy, including conditions of entry and residence for third-country nationals, and the students and researchers directive (2016/801) – adopted on the Article 79(2)(a) and (b) legal base – already exists under this basis. All member states except Ireland and Denmark – both of which have opted out – have implemented it. The directive sets minimum conditions for admission of third-country students, and it isn’t wholly blind to institutions – it defines “higher education institution” by reference to national recognition, requires student acceptance by such an institution, and lets member states establish approval procedures for higher education institutions. But it stops well short of regulating cross-border agent behaviour or sponsor-side recruitment integrity in any detailed way.

There’s arguably a case for amending it to include provisions on recruitment integrity – requiring member states to see that institutions using agents have contractual accountability mechanisms, or mandating standardised pre-departure information for students. That would sit within the immigration legal base rather than the education one, sidestepping the Article 165 prohibition on harmonising education law.

Whether such provisions would survive a competence challenge would depend on how closely they were tied to migration-admission conditions rather than the organisation of education systems – it’s an open legal question, not a foregone conclusion. And even on the migration side, EU competence isn’t unlimited – Article 79 TFEU gives the Union a common immigration policy role, but member states retain control over volumes of admission, and Directive 2016/801 itself preserves that principle. So the most defensible argument isn’t that Brussels could straightforwardly solve this if it wanted, but that there is a plausible legal basis for more coordinated minimum rules on admission-related integrity, information duties, and sponsor controls – provided they’re framed as migration governance rather than regulation of the education system as such.

Consumer protection offers another route. The EU has shared competence under Article 169 TFEU, and several of the practices documented across these countries – misleading marketing, false promises about employment prospects, and hidden commission fees – would plausibly fall within the scope of the unfair commercial practices directive (UCPD) where an EU consumer relationship exists. The UCPD is a business-to-consumer instrument aimed at misleading and aggressive commercial practices that distort consumer decisions – that makes it a plausible route against EU-based institutions making, endorsing, or failing to control misleading recruitment claims directed at prospective students as consumers. But it isn’t a general anti-agent regime, and enforcing it against offshore recruitment intermediaries operating outside EU jurisdiction is substantially harder. It has potential as a partial accountability route for universities and EU-based intermediaries – but nobody seems to have tried it yet.

The UK – now outside the EU – provides a partial comparator. Through the Competition and Markets Authority’s (CMA) application of consumer protection law, students are treated as consumers and universities as traders. And under the Digital Markets, Competition and Consumers Act 2024, institutions can in principle be held responsible for misleading practices carried out on their behalf – including by recruitment agents – where those practices are attributable to them. There is, as yet, little visible enforcement of that framework in the international recruitment context. But it demonstrates that agent behaviour can be regulated indirectly through consumer law, without legislating specifically on education systems.

There’s an implicit contrast worth drawing out. The UK model relies on ex post enforcement against unfair practices – you wait for the misleading claim, then hold the institution accountable. Much of the EU discussion – particularly around Directive 2016/801 – is about ex ante admission conditions and migration controls. That difference in regulatory posture is doing quite a lot of work in explaining why national responses diverge. Countries reaching for migration law are trying to stop students arriving in the first place. Countries reaching for consumer or labour law are trying to hold institutions and intermediaries accountable for what happens once they do.

Labour law is the route the Dutch have already taken. Where “students” are actually performing the work of employees, national labour and migration enforcement can already bite without any new EU education-agent legislation. The Dutch Labour Authority didn’t need new powers to fine institutions €700,000 – it used national employment and migration law it already had. Any EU-law overlay in cases like these would be indirect and sector-specific rather than the main operative basis.

Beyond legislative competence, the Schengen Information System can hold alerts on refusal of entry or stay and return decisions, so it has a role at the enforcement end – and more broadly, existing migration-data infrastructure could support downstream alerting and fraud detection. But these systems weren’t designed as dedicated recruitment-integrity or agent-oversight tools, and the Entry-Exit System applies to short stays rather than to holders of long-stay visas or residence permits, limiting its direct relevance to ordinary student-permit screening.

It’s at least arguable that the EU could issue a non-binding Commission Recommendation on education agent regulation under Article 165’s supporting competence – though the politics and legal design of such an instrument would be considerably harder than that sentence makes it sound. Similarly, it could explore whether Erasmus+ and Horizon Europe programme management offers soft-law levers – guidance, funding-integrity expectations, or reporting requirements – to encourage responsible recruitment practices among participating institutions, though there is no existing bespoke recruitment-integrity condition in those instruments and building one wouldn’t be legally turnkey.

And surely pretty much everyone – including countries outside of the EU but with relationships, like the UK or Switzerland – could agree to surveying students to determine whether what their agents told them was true, publishing results, and taking action where standards of accuracy for a service that markets itself as support falls short.

None of this is happening for now – member states most affected are each responding nationally because they want to control their own migration politics. Those that might benefit from displaced demand when Nordic and Baltic countries tighten up have no incentive to push for EU-wide standards that might constrain their own growing recruitment operations.

Until that changes every country will keep discovering the same variants of the same scandal, expressing the same shock, and passing the same reactive national legislation, while the recruitment industry simply moves on to the next destination with weaker oversight and a more desperate need for fee income.