---
title: "Onshore transfer commission ban in Australia: what agents can still be paid, and who funds onshore students now"
description: "Can agents still get commission for onshore students in Australia? The 31 March 2026 ban's carve-outs, the government's own modelling, and who pays now."
date: "2026-07-03"
updated: "2026-07-08"
category: "Business strategy"
keywords: "Business strategy"
author: "Raphael Arias"
lang: "en"
wordCount: 3776
url: https://qualyhq.com/blog/onshore-transfer-commission-ban-australia
---
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# Onshore transfer commission ban in Australia: what agents can still be paid, and who funds onshore students now

> Can agents still get commission for onshore students in Australia? The 31 March 2026 ban's carve-outs, the government's own modelling, and who pays now.

Mostly no. Since 31 March 2026, Australian providers can't pay agents any commission — cash or benefit — for an onshore student who transfers without completing their course. Commission survives for offshore recruitment, packaged courses, and completed-course progression. The deeper shift: transfer commission quietly funded onshore student servicing, and someone else has to pay for that now.

The trade press covered the announcement to death in January, so let's skip the recap and start with the part nobody priced in. The commission an agent earned for moving an onshore student was never really payment for the move. It was the retainer that funded everything else the onshore desk did: the course-change advice at week six, the panicked visa-condition call at 9pm, the welfare check when a student stopped showing up to class. None of that work was ever billable. It didn't need to be — every so often one of those students transferred, a commission landed, and the maths of the whole service operation worked out.

Since 31 March 2026, that commission is illegal. And so the interesting question, three months in, isn't "what are the rules" — it's **who pays for onshore student servicing now that the cross-subsidy is gone**. The ban didn't just delete a revenue line. It repriced the onshore student from an asset on the agency's book to a cost on it. Everything that happens to onshore-focused agencies over the next two years follows from that repricing.

## The rule, precisely: what's banned and what still pays

One paragraph of law, because the carve-outs are where the business models live. The [National Code amendment (Education Agent Commissions) Instrument 2026](https://www.education.gov.au/higher-education/resources/ban-payment-agent-commissions-onshore-transfers), signed in January under the ESOS integrity reforms that received Royal Assent on 4 December 2025, prohibits a receiving provider from paying — or offering to pay — an agent commission for recruiting an overseas student who has already commenced study onshore with another provider and hasn't completed their course. **An onshore transfer is a move between providers without completing the course**; that includes withdrawals, enrolment cancellations, and jumping between packaged courses after commencement. "Commission" is defined broadly enough to catch bonuses, gifts, service fees and discounted anything, and it captures casual contractors doing agent-like work — though not permanent employees, a carve-out we'll come back to.

Here's the full map of what still pays:

| Scenario | Commission from the provider? |
| --- | --- |
| Student recruited offshore | Yes — unchanged |
| Onshore transfer, course not completed | No — banned since 31 Mar 2026 |
| Student accepted for enrolment on or before 31 Mar 2026 | Yes — even if they commence later |
| Progression through packaged courses on the original visa's CoEs | Yes — not a transfer |
| Student completes their principal course, enrols in a new qualification elsewhere | Yes — not a transfer |
| Student withdrawn or cancelled, re-recruited before completing | No |
| Student pays the agent directly for transfer help | Allowed — it's a service fee, not a commission |

*Verified July 2026 against the Department of Education fact sheet and the Instrument; treat as a map, not legal advice — we're a payments company, not your lawyer.*

Note what the ban doesn't touch: offshore recruitment commission — [the rates, census-date triggers and gross-vs-net mechanics](/blog/how-education-agent-commissions-work.md) — carries on exactly as before. Then read the table as a strategist rather than a compliance officer, and three doors are visibly left open: the student's own wallet, the provider's payroll, and the word "completed". Hold those three; they're the rest of this article.

## The revenue that funded work nobody was billing for

Start with what the money actually was. In the Department of Education's own modelling for the ban, the **average commission on an onshore transfer was assumed at just $511 per student** — half its $1,021 average for offshore recruitment, and $341 for the VET-heavy providers most exposed. Meanwhile, media reporting that fed the same policy process described providers offering commissions **as high as 50% of a year's tuition** — on the average VET fee in the modelling, more like $6,700. Both numbers are real; they describe different ends of the same market. The department's average is dragged down by thousands of small, ordinary transfers; the headlines were made by the poaching end, where a handful of providers effectively bought enrolments wholesale.

That spread matters because it tells you who actually loses. The poaching operators lose a business model, and nobody's mourning. But the ordinary onshore agency — the two-desk operation near the station that lives on its community's trust — wasn't earning $6,700 a student. It was earning a few hundred dollars here and there, on maybe a handful of transfers a term, and using that trickle to justify a standing service desk for every onshore student in its book, transferring or not. Call that funding structure what it was: **the onshore servicing gap** — the difference between what onshore students cost an agency to support and what anyone explicitly pays for that support. Before 31 March, transfer commission filled the gap invisibly. Now the gap is just... open.

This is why "the ban only affects course-hoppers" is the wrong read. An onshore student used to carry option value: some probability of a future transfer, progression or renewal commission. Under the new rules, a student who hasn't completed their course carries none — only the certainty of service requests. **The ban repriced the onshore student from an asset to a cost**, and businesses reorganise around their cost lines far faster than they reorganise around principles. Agents saw this coming: when the policy was first floated, one onshore agent told The PIE News that "many businesses will need to move overseas". Three months into the real thing, the choices are more specific than that — but first, look at what the government itself expects to happen.

## The government's own spreadsheet expects a third of transfers to vanish

Almost nobody in the sector read the [Impact Analysis addendum](https://oia.pmc.gov.au/published-impact-analyses-and-reports/addendum-prohibiting-agent-commissions-onshore-transfers) the Department of Education published with this ban, which is a shame, because it's the closest thing to an official prediction of your future that an agency will ever get. The scale first: departmental PRISMS data shows **student transfers made up roughly 9% of all international student enrolments in 2024**, and were tracking to meet or exceed that in 2025. The modelling assumes 10% of onshore students change providers, 78% of them with an agent — and that **71.6% of agent-facilitated onshore transfers went to VET providers**, against 28.1% to higher education. This was never a university story. It was a VET and private-college story wearing a sector-wide headline.

Then the forecast. The department models three equal groups: a third of transferring students keep transferring with an agent — some now paying the agent a fee directly; a third transfer without an agent; and a third stop transferring altogether. That last third is the quiet earthquake: **the government's own modelling assumes a third of onshore transfers simply stop — redistributing over $450 million in student fees between providers across ten years without a single new student arriving in the country.** Every dollar of that is a student a receiving provider doesn't poach and a losing provider keeps. Retention just became the cheapest acquisition channel in Australian international education.

Two more numbers worth stealing from the appendix. First, 4% of all providers were "transfer-dominant" — more than half their enrolments arriving via agent-facilitated onshore transfers — and **93% of those transfer-dominant providers are VET providers**. Those businesses aren't adjusting a channel mix; they're replacing their primary market or closing. Second, 65% of transfer-dominant *agents* are located onshore: the ban's cost lands almost entirely on the onshore end of the agent ecosystem, exactly the mom-and-pop segment least able to absorb it. And the department knows the whole bet is fragile — its own sensitivity analysis shows that if every student who would have transferred instead gives up and leaves Australia, the policy's $30 million net benefit flips to a $172.6 million net loss. The official case for this ban rests on students staying put unhappily rather than going home. Watch the attrition data with that in mind: first-year attrition among commencing international undergraduates had already climbed to 17.4% in 2023, per Menzies Research Centre analysis, before anyone banned anything.

## Travel agents already ran this experiment — in 1995

If you want to know what happens to a channel when its commission is deleted, you don't need scenarios. You need a calendar set to February 1995, when [Delta capped US domestic travel agent commissions](https://www.washingtonpost.com/archive/business/1995/02/10/delta-cuts-travel-agent-commissions/02fd5a19-1502-46f0-b5c7-4043ec5d1cf9/) at $50 per round trip, every major carrier matched within a week, and the caps escalated — through cuts to 8%, then 5% — until commissions hit zero in 2002. Travel agencies had spent decades being paid by the supplier while presenting themselves to the traveller as free. Then the supplier stopped paying.

What happened next is the most instructive decade in the history of intermediary businesses. The agencies that survived did one thing above all: **they moved the invoice from the airline to the traveller** — service fees per ticket, then consulting-style fees for complex trips — and discovered which clients actually valued them enough to pay. Most clients didn't. The number of US travel agents roughly halved over the following two decades, from about 132,000 in 1990 to 74,000 by 2014. But the survivors ended up healthier than the commission era ever made them: paid directly, by clients who chose them, for expertise rather than for ticket-printing.

The parallel to onshore education agents isn't decorative; it's structural. Both channels sold advice that was free at the point of use because a supplier paid on conversion. Both had their conversion payment removed by decree rather than by market shift. And both faced the same brutal revealed-preference test the morning after: *will the person you serve pay you what the supplier used to?* The travel industry's answer was "one in two agencies, roughly". Onshore education agencies are now sitting the same exam, with one advantage travel agents never had — the law explicitly blesses charging the student.

## Who pays for onshore servicing now: three candidates, three different winners

So the servicing gap is open and someone has to fund it. There are exactly three candidates, and they're not equally good for you.

**Candidate one: the student pays.** Fee-for-service is explicitly legal — the fact sheet and Study Australia's agent guidance both confirm students may engage agents directly for onshore advice, including transfers. The government's modelling *assumes* some agents convert to this. The economics are honest but hard: you're asking a price-sensitive student to pay a visible service fee for something that was invisible and "free" last year. As in travel, the agencies that clear this bar will be the ones selling genuine expertise — course-change strategy that protects the visa, [documented compliance with the disclosure rules](/blog/education-agent-commission-disclosure-australia.md), welfare navigation — not form-filling. Winners: agencies with real service depth and the nerve to price it. Losers: agencies whose "service" was, on inspection, a transfer pipeline.

**Candidate two: the provider pays — as payroll instead of commission.** Providers keep every dollar of banned commission, and under Standard 6 of the National Code they already carry support obligations to their students; the $450 million retention prize gives them a commercial reason to fund student services properly for the first time. Here's the detail almost nobody has connected: the new agent definitions capture casual contractors doing recruitment work, but **permanent employees are exempt**. The compliant version of the old onshore agent channel is a former agency counselor on a provider's payroll with the title "student success adviser". Expect providers — especially VET colleges and language schools that used to *pay* transfer commissions — to hire exactly the people the ban defunded. If you run an agency, that's your best staff being recruited with your old revenue; we've written before about [what happens when your counselors realise they are the product](/blog/should-agents-fear-their-counselors-will-start-their-own-education-agency.md), and this ban just gave them a legal, salaried exit.

**Candidate three: nobody pays — and the work routes through the loophole.** Commission is still payable when a student *completes* a course and progresses. So the grey-zone play is obvious: park students in short, cheap, completable courses, wait for "completed", then move them for a lawful commission. Call it **churn-to-completion** — course-hopping with a graduation certificate as the reset button. The Instrument's drafters clearly saw circumvention coming (the commission definition is deliberately broad), but the completion pathway isn't circumvention — it's the exemption working as written, at industrial scale. Which leads to a falsifiable prediction: **within two to three years, "completed the course" becomes the most audited phrase in the National Code** — regulators will be forced to define completion quality, minimum durations, and genuine-progression tests, the same way they've had to define what counts as a commission at all (a fight we covered in [when marketing support reads as commission](/blog/marketing-budget-education-agent-commission-australia.md)). And the detection layer is already funded: per-agent onshore transfer counts are among the data every school will soon see through [PRISMS agent data sharing](/blog/prisms-agent-data-sharing-australia/), so completion-timed churn will surface on the same screen schools and colleges use to pick their agents.

## The bifurcation: pick your side before the market picks it for you

Put the three candidates together and the two-year forecast writes itself. **Onshore-focused agencies bifurcate.** One branch goes fee-for-service: charges students transparently, builds a service book instead of a transfer book, and starts to look like the surviving half of the travel industry — smaller, better paid, chosen. The other branch chases whatever commission remains payable: completed-course progression, packaged pathways, and completion-timed moves — a strategy that works right up until the audits arrive, and one that keeps your revenue hostage to a definition the regulator can tighten in a single instrument. There isn't a durable third branch. "Wait and see" is the second branch with worse timing.

Whichever side you pick, the plumbing changes. A fee-for-service agency is suddenly a business that invoices students directly — quoting fees, taking deposits, offering instalments to people who just learned your advice costs money — and its remaining school-side income arrives through fewer, more scrutinised channels, where every payment needs a clean paper trail and [the split with any sub-agents](/blog/master-agent-sub-agent-commission-splits.md) documented to survive a records request. That's the boring, load-bearing layer Qualy exists for: collect service fees and tuition from students on flexible plans, split and pay out commissions the moment funds clear with [the accounting trail generated automatically](/features/automatic-accounting-for-ed-agents.md), for a flat fee per payment rather than a percentage of your shrinking margin. The strategy question — which branch you take — is yours. Making either branch operationally survivable is ours.

The commission for onshore transfers is gone and it isn't coming back; the assistant minister who signed the instrument had been calling commissions "out of control" since before the bill was drafted, and the political wind is all one direction. But the work the commission paid for hasn't gone anywhere. Students still change their minds, visas still throw errors, someone still has to answer the 9pm call. For thirty years the industry pretended that work was free. The only question the ban really asks is the one travel agents answered a generation ago: now that everyone can see the price tag, who's willing to pay it — and are you good enough to be worth it?

## Sources

- [Department of Education — Ban on the payment of agent commissions for onshore transfers](https://www.education.gov.au/higher-education/resources/ban-payment-agent-commissions-onshore-transfers): the fact sheet defining transfers, exemptions and the commission definition.
- [Ministers' Media Centre — Protecting international students by banning agent commission payments for transfers](https://ministers.education.gov.au/hill/protecting-international-students-banning-agent-commission-payments-transfers): the January 2026 announcement.
- [Office of Impact Analysis — Addendum: Prohibiting agent commissions for onshore transfers](https://oia.pmc.gov.au/published-impact-analyses-and-reports/addendum-prohibiting-agent-commissions-onshore-transfers): all modelling figures cited — 9% transfer share, sector splits, $511/$1,021 commission assumptions, the three-group student response, the $450m fee redistribution, net-benefit and sensitivity scenarios.
- [The Koala News — Government clarifies onshore transfer commission ban with fact sheet](https://thekoalanews.com/government-clarifies-onshore-transfer-commission-ban-with-fact-sheet/): transfer vs progression distinctions and the acceptance-date exemption.
- [ICEF Monitor — Australia introduces new rules restricting agent commissions for onshore student transfers](https://monitor.icef.com/2026/01/australia-introduces-new-rules-restricting-agent-commissions-for-onshore-student-transfers/): rule summary and completed-course carve-out.
- [Study Australia — New rules on agent commissions for onshore student transfers](https://www.studyaustralia.gov.au/en/Agent-Hub/agent-news-index/new-rules-on-agent-commissions-for-onshore-student-transfers): official agent-facing guidance, including the legality of student-paid services.
- [CAQA Compliance — Closing the commission loophole](https://caqa.com.au/blogs/news/closing-the-commission-loophole-australia-bans-education-agent-commissions-for-international-student-transfers-as-new-data-reveals-the-scale-of-course-hopping-and-visa-exploitation): instrument details, the broad commission and agent definitions, and the Menzies Research Centre attrition figures.
- [The PIE News — Australian MP defends onshore commission ban as agents voice concerns](https://thepienews.com/news/mp-defends-onshore-commission-ban/): the "out of control" quote and onshore agents' reactions.
- [The Washington Post — Delta cuts travel agent commissions (February 1995)](https://www.washingtonpost.com/archive/business/1995/02/10/delta-cuts-travel-agent-commissions/02fd5a19-1502-46f0-b5c7-4043ec5d1cf9/): the commission-cap event the travel parallel is built on.
- [Travel Weekly — A history of airline commissions](https://www.travelweekly.com/Mark-Pestronk/Getting-your-share-of-airline-commissions): the escalation from caps to zero commission by 2002.
- [Vice — Why are travel agents still a thing?](https://www.vice.com/en/article/why-are-travel-agents-still-a-thing-internet-airlines-agencies/): the decline from ~132,000 US travel agents in 1990 to ~74,000 by 2014.

## Frequently asked questions

### Can education agents still get commission for onshore students in Australia?

Only in specific cases. Since 31 March 2026, providers can't pay agents any commission — money or other benefits — for a student who transfers onshore without completing their course. Commission is still payable for offshore recruitment, for progression through a packaged set of courses on the student's original visa, for students who completed their principal course and enrol in a new qualification, and for students accepted for enrolment on or before 31 March 2026. Agents may also charge students directly for services.

### What counts as an onshore transfer under the new rules?

A transfer is when an overseas student moves from one registered provider to another without completing their course. The government's fact sheet confirms this includes students who withdraw, students whose enrolment is cancelled, and students who move between courses in a package after commencing study. In all those cases, the receiving provider is prohibited from paying an agent commission. Moving to further study after completing a principal course is progression, not a transfer, and remains commissionable.

### When did the onshore transfer commission ban start?

The ban has applied since 31 March 2026. It comes from the National Code amendment (Education Agent Commissions) Instrument 2026, signed in January 2026 under the ESOS integrity reforms that received Royal Assent on 4 December 2025. The obligation sits on the receiving provider — it is the provider, not the agent or student, that is prohibited from paying or offering the commission. ASQA and TEQSA enforce it in their respective sectors.

### Are there exemptions to the onshore commission ban?

Three. First, transitional: students accepted for enrolment by their new provider on or before 31 March 2026 are exempt, even if they commence later, so existing contracts can be honoured. Second, packaged courses: commission can be paid as a student progresses through the courses listed on the Confirmations of Enrolment for which their visa was granted. Third, completion: a student who has completed their principal course and enrols elsewhere is not transferring, so commission is payable.

### Can agents charge students directly for help with an onshore transfer?

Yes. The ban only prohibits the receiving provider from paying the agent. Students keep their right to transfer under Standard 7 of the National Code and may engage an agent for advice or assistance on a fee-for-service basis. The government's own impact analysis anticipates some agents converting transfer support into a student-paid service. Practically, that means quoting fees transparently and invoicing the student — a business-model shift, not a workaround.

### Does the ban cover bonuses, gifts and perks, or just cash commission?

Everything of value. The ESOS reforms define an agent commission broadly: direct payments, per-student fees, bonuses, service fees, gifts, discounted services and other non-monetary benefits are all captured, precisely to prevent circumvention through creative payment structures. The agent definition also extends to casual and fixed-term contractors performing agent-like recruitment work — though permanent employees of a provider are exempt, which is why in-house student advisory roles are a growing response to the ban.

### Can a provider pay commission when a student finishes one course and starts another?

Yes. Completing the principal course and then enrolling in a new qualification — say, finishing a bachelor degree and starting a master's at a different university — is academic progression, not an onshore transfer, and the new provider can lawfully pay the agent a commission. This completed-course carve-out is the most commercially significant exemption, and the most likely to attract audit attention if short, cheap courses start being used as commission reset buttons.

### How big was the onshore transfer market before the ban?

Bigger than most people assumed. Departmental PRISMS data cited in the government's impact analysis shows transfers made up roughly 9% of all international student enrolments in 2024, with 2025 tracking at or above that. About 78% of transferring students used an agent, 71.6% of agent-facilitated transfers went to VET providers, and 4% of all providers were transfer-dominant — deriving over half their enrolments from onshore transfers. Of those transfer-dominant providers, 93% were VET providers.

### What happens to commissions agreed before 31 March 2026?

They can still be paid, if the student was accepted for enrolment by the new provider on or before 31 March 2026. Acceptance is the test, not commencement — a student accepted in March who starts in July remains within the exemption, and providers can honour existing agent contracts including future commission instalments for those students. For any student accepted after that date who hasn't completed their course, no commission may be paid regardless of when the agreement was signed.

### Will providers hire agents in-house instead of paying commissions?

It's the logical move, and the rules permit it: the new agent definition captures casual contractors doing recruitment work but exempts permanent employees. Providers keep every dollar of banned transfer commission and now have roughly $450 million of at-risk student fees over ten years — the government's own estimate of transfers that stop — to protect through retention. Expect VET colleges and language schools to hire experienced onshore counselors into salaried student-success roles, often from the very agencies the ban defunded.

## Related articles

- [How education agent commissions work: rates, gross vs net, and getting paid on time](/blog/how-education-agent-commissions-work.md)
- [Agent 'marketing support' now reads as a commission — unless you can show otherwise](/blog/marketing-budget-education-agent-commission-australia.md)
- [Should Agents Be Afraid That Their Counselors Will Start Their Own Agency?](/blog/should-agents-fear-their-counselors-will-start-their-own-education-agency.md)

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