Who decides about quality? Education agents and the question of increased regulation

There has been a surge in international student mobility since the pandemic, and that rapid growth has tested many of the quality assurance measures in place across the international education sector. Student services have struggled to keep pace, the global stock of student housing has been overstretched, and several models for recruiting and teaching international students have come under greater scrutiny.

Viewing all of that through a student lens, we have to acknowledge as a sector that in tandem with the recent surge in international student mobility, there has been an increase in reports of students having had a negative experience of study abroad. Those reports are grounded in a variety of issues, including shortages of affordable student housing, mental health concerns, poor integration into local communities, difficulty accessing support services, poor programme delivery, and sub-par graduation and career outcomes for some students.

Those reports have led to growing calls for better regulation of the sector, and they have prompted a wave of new policy settings brought forth by several national governments. New settings include enrolment caps in a number of countries – notably the Netherlands, Canada, and Australia – and a variety of new restrictions and requirements for visiting students.

Parallel to that pattern of tightened rules around international students has been a call for increased regulation of education agents. It is well established that agents play a critical role in student recruitment, and in providing invaluable support for students, parents, and institutional partners. But the education agent space is largely unregulated, operates at a considerable scale (with an estimated 22,000+ agencies worldwide), and offers few barriers for new entrants, especially in an era of aggregated agent networks and remote work.

Partly because the agent space is so large, varied, and lacking serious barriers to entry or to the expansion of agent networks, it has also been highly resistant to regulation. In practical terms, a given national government has little influence over an agency abroad that can quickly rebrand or restructure, or just as quickly shift its recruiting activity from one sector to another or from one country to another.

For all those reasons, there is a broad consensus that self-regulation – that is, measures that come from the industry itself – represents the best path forward for creating and implementing effective quality assurance measures for education agents.

The building blocks

Resistant to regulation as the agent space may be, there has, in fact, been a lot of great work done to strengthen standards of practice for education agents, and to advance the professional qualifications of agency-based student counsellors.

This work has largely occurred in three key areas: codes of conduct, agent training, and agency accreditation. There are a swirl of terms in this space, including “certification,” “accreditation,” and more. Codes of conduct, agent training, and agency training are sometimes conflated with one another, but it’s important to specify exactly what is being referred to. Each of these three components is quite distinct from – but highly complementary to – the others, and an effective self-regulation regime will combine all three.

Standards of practice

A number of codes of conduct and best practice guidelines are in place today, both pertaining to agent conduct and to the professional practices of institutions engaged with agents. Examples include the London Statement (formally, The Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants); the National Association for College Admission Counselling's (NACAC) Guide to International Student Recruitment Agencies; the British Universities' International Liaison Association's (BUILA) National Code of Ethical Practice for UK Education Agents; the Australian Agent Code of Ethics (ACE); the Association of International Enrollment Management's (AIRC) Best Practice Guidelines for Institutional Members; the Association of Language Travel Organisations' (ALTO) Best Practice Guidelines for Education Providers and Agents; and the ICEF Code of Conduct for the Ethical Recruitment of International Students.

Some codes of conduct are more oriented to one or more education sectors or to a given destination. If we were to put them side by side, however, we would find that they almost universally advance a common set of core principles, including transparency, accountability, integrity, fair dealing, and a commitment to high standards of student service on the part of education agents and also their institutional partners.

Any effort to strengthen quality standards for education agents – that is, any serious effort of self-regulation – rests in part on a clearly framed code of conduct, the standard of practice that it reflects, and a global mechanism for enforcing those standards.

An expanding field of training options

Put yourself in the shoes of a student counsellor working in an education agency. She may have studied abroad herself, or, through fam tours or other visits, have gained a firsthand experience of one or more destination countries. Alongside her knowledge of a study destination, its student visa programmes, and other relevant regulations, she also has to be an expert in any number of institutions and schools, their respective policies, and the many programmes and services they provide.

By any reckoning, that is a tremendous base of knowledge for any counsellor to establish and maintain, especially given that those programme offerings, policies, and other key points of information are changing all the time.

That explains the high demand for training among agency-based counsellors, both on best practices in recruitment and student services as well as training on advising students to study in one country or another, and of course ongoing training on individual institutions or schools.

It explains as well why many institutions invest heavily in counsellor training in support of their agent-partners, and why there is an expanding emphasis on agent training across the international education sector.

Agent training, for example, is embedded in the UK's Agent Quality Framework (AQF), a package of measures that includes specialised training courses for agency-based counsellors advising on study in the United Kingdom. And there are other specialised platforms, including TrainHub, which provides a hosted solution that institutions and schools can use to deliver training for agent counsellors, and ICEF Academy, which provides a growing portfolio of destination-focused courses along with other professional development options and qualifications for counsellors.

Within the AQF, the UK Agent and Counsellor Training Course was developed and is administered by the British Council, and it is also delivered in partnership with ICEF Academy. To date, 23,000 counsellors have registered for the course and nearly 10,000 have completed it and also endorsed the AQF's code of conduct. "Until recently, the AQF was a voluntary framework where UK universities pledged to meet the standards set to evidence their good conduct," says Jacqui Jenkins, the Global Lead for International Student Mobility at the British Council. "To the best of my knowledge almost all UK providers pledged to the AQF by the time the government made it mandatory [in spring 2024]. Independently, agents have also made public statements about their support of the AQF. Since the pledge was launched the number of agents registered for the [UK course] has increased from 8,000 in December 2023 to more than 26,000 in June 2024."

Agent training is similarly embedded in the quality assurance standards in Australia, where agent-counsellors referring students to Australian institutions can complete the Education Agent Training Course (EATC) in order to earn a Qualified Education Agent Counsellor (QEAC) designation. The EATC is a long-established course, now delivered by ICEF Academy, with more than 13,000 graduates. "The EATC is a perfect example of how training can become part of an industry standard," says ICEF Academy Director Stacey Crosskill. "It provides counsellors with a strong foundation for effective student advising, and it allows individual institutions and schools to concentrate their own training efforts on their respective programmes and services."

Alongside the British Council course for the UK and the EATC for Australia, ICEF Academy provides specialised courses for counsellors advising students on study in Canada, the United States, France, Ireland, and, as of this week, New Zealand. All told, those courses have registered more than 127,000 learners and conferred professional qualifications to more than 19,000 agents in 130 countries who have successfully completed the course requirements.

Aside from the huge demand for training on the part of agency-based counsellors, perhaps the biggest takeaway from this review is that training courses can form an important part of a larger quality assurance mechanism, especially where they are explicitly incorporated into national or international models for quality assurance.

Validating and vetting the agency

If codes of conduct set a threshold of professional standards for both agencies and individual counsellors, and training advances the qualifications and professional development of agency-based counsellors, the last piece of the self-regulatory puzzle would appear to be verifying the bona fides, good practices, and compliance of the agency itself. This is where agency accreditation comes in.

There are lots of different mechanisms in the marketplace to screen or check agency qualifications. These especially include the requirements of the 14 national agency associations that comprise the supranational agent body Felca (Federation of Education and Language Consultant Associations). They also include the vetting that occurs within the agent networks maintained by pathway providers, such as INTO University Partnerships or Navitas. Similarly, event organisers, such as ICEF or ST Alphe, pre-screen agents that join their networking events. And of course many institutions or schools will conduct their own vetting of agent partners.

Against that varied backdrop, there are only two fully articulated agency accreditation programmes globally. One is administered by the Association of International Enrollment Management (AIRC), and the other is the ICEF Agency Status (IAS) programme. (Please note that in the United States, where AIRC is based, the term “certification” is more commonly used than is “accreditation.”)

AIRC has been certifying agencies since 2009. Its process is extensive, encompassing five broad areas of agency operation and a combined 40 requirements that agent-applicants must satisfy in order to earn the AIRC Certification seal. To date, 163 agencies have been certified and 107 are active-certified members. The process typically takes nine months, sometimes more or less. Agencies are initially accredited for a five-year term and, pending a successful reassessment in year five, may be renewed for subsequent ten-year terms.

Reflecting on the role of such accreditations, AIRC's Director of Operations and Certification Jennifer Wright says, "They are designed to provide a full vetting of the agency company and recruiting operations and can be wholly accepted as a qualification for institutions to partner with an agency, or they may complement an individual institution's agency vetting efforts. I've had institutions send staff to our reviewer training at AIRC with no intention of working on agency reviews for us. But they are going to use those skills in their own due diligence work in evaluating new agencies or agency performance, and the AIRC certification gives them a running start on their own engagement with the agency."

Meanwhile, the IAS, says Nick Golding, ICEF's VP Government Relations and Strategic Partnerships, has become the de facto global standard for agency quality assurance and represents the "the highest common denominator of good agency practice in all of the major study destinations."

The programme reached an important milestone earlier this month with the accreditation of its 2,000th agency across 125 countries. Another 1,000 agencies are currently in the midst of a comprehensive vetting process that includes reference checks, operational audits, and extensive document verification.

Agencies are reassessed annually, and agent compliance with accreditation requirements, including the ICEF Code of Conduct, is overseen by ICEF's global agent team, which currently numbers 26 staff across 16 countries.

"In order to be a true standard for the industry, any accreditation scheme needs to be credible, accessible by a wide variety of agencies, and administered by a market-neutral organisation with global reach and expertise," adds Nick Golding. "These are the core ingredients of IAS, and it's why we are seeing such rapid adoption of this accreditation model by agents and industry stakeholders alike."

For additional background, please see:

• "ICEF announces new agent code of conduct"
• "Australia expands regulatory oversight of education agents and announces new integrity measures for VET"
• "Global agent survey finds a strong growth outlook for 2024; provides new insights on agency operations"