Australia continues its path towards “managed growth” of international student enrolments with Ministerial Direction 115

A year ago, the Australian government introduced a policy called Ministerial Direction 111 (MD111) with the stated goals of restricting the number of new international students arriving in Australia and improving the integrity of the country’s international education sector. Ministerial Directions are not laws per se, but they are legally binding for the sector or government agencies they are intended to influence.

MD111 is not a formal cap on new student visas. Its design relies heavily on prioritising visa applications from “low-risk” origin countries (i.e., in which students are more likely to be “genuine” and not using the student visa route to enter the labour force) and for institutions with proven capacity to handle more students. It has had the effect, however, of establishing a “soft” enrolment cap by limiting visa processing for individual institutions once they have exceeded an allocated number of new student spaces. This was enough to exert significant downward pressure on new international enrolments. Student applications have fallen by over 26% as of 2025, and commencements are down by 16% compared with 2024.

The government is pleased with this evidence of what it calls “managed growth,” with the Hon Julian Hill, Assistant Minister for International Education and Assistant Minister for Citizenship, Customs and Multicultural Affairs saying, “Throughout 2025 we have seen the positive effect of a managed growth approach across the sector – returning student numbers to a more sustainable level.”

A wider “slow lane” for visa processing

Now, there is Ministerial Direction MD115, which on 14 November 2025 will replace MD111. MD115 is intended to further the goals of MD111 and to reinforce the government’s 2026 National Planning Level (NPL) for international student places announced in August 2025.

The NPL sets a recommended total allocation of 295,000 seats for new international students in 2026, up moderately from 270,000 in 2025. Two thirds of the 2026 total goes to public universities. Each provider, across sectors, has a set number of allocations (called New Overseas Student Commencements, or NOSCs) for new international students. Providers have been told they will receive at least as many allocations for 2026 as they did in 2025.

Together, the NPL and MD115 will:

• Further disincentivise providers from going beyond mandated capacity limits, because when a provider meets or exceeds 80% of their NOSC allocation, visa applications from students hoping to enrol with them are processed more slowly than those under the 80% mark, with medium and high-risk markets affected first;

• Disadvantage providers exceeding 115% of their NOSC allocation by assigning them to the lowest priority for visa processing;


• Make things easier for those furthest away from meeting capacity limits by processing their applications from students faster than students applying to other providers; 

• Push even those providers that are under their 80% allocation to the slow lane if they are linked to a high level of visa refusals or suspected fraud;
• Reward public universities that align with the NPL’s new priorities for 2026: prioritising the Southeast Asian region for recruitment, providing higher-than-average student accommodation supply; and investing in TNE provision.

The capacity milestones used to determine visa processing speed are:

• Priority 1 (fastest, typically 1-4 weeks): Less than 80% of allocation
• Priority 2 (middle speed, typically 5-8 weeks): Between 80%–115% of allocation
• Priority 3 (slowest, typically 8–12 weeks): 115% above allocation

How can visa processing speed controls act as “soft caps”?

Uncertainty about how fast their visa applications will be processed has a profound effect on international student applicants. Students encountering delays on visa decisions can be disrupted in many ways, including:

• Upsetting travel planning and potentially adding travel costs since flights are more expensive when booked closer to programme start dates;
• Missing orientation events and not feeling ready for the academic year;
• Failing to meet enrolment deadlines when visas have not been approved in time.

Slower visa processes also affect the operations of institutions. They can make enrolment management even more challenging, weakening the ability of admissions staff to estimate numbers of (1) visas that will be granted, (2) prospects who get frustrated and choose another destination, and (3) students who will defer because their visa decision has not happened in time for their programme start date.

Suffice to say, the difference between knowing your visa will likely be approved within three weeks versus three months is massive for many international students. Timing is so influential in terms of students’ ability to prepare for and finance study abroad, and it is equally consequential for institutions attempting to manage capacity and programme mix.

As a result, the Australian government’s leverage of visa processing times is proving effective in terms of encouraging compliance within the international education sector. If the goal is improving the integrity of the system as much as it is controlling international student volumes, stratifying visa processing times is likely as effective as the fixed “hard caps” we see in place in Canada. It is a “carrot and stick” approach that rewards institutions for aligning with government guidance and that disadvantages those that do not.

For additional background, please see:

• “Australia introduces new integrity measures through proposed amendments to the ESOS Act”
• “Australia: With ELICOS under pressure, peak bodies push for reduction in 'extortionate' visa fees”
• “How have changes in policy settings impacted international student recruitment at Australian universities?”