WEEKEND READING: The Agent Quality Framework and the optics of compliance

This blog was kindly authored by Pii-Tuulia Nikula, Associate Professor at EIT, New Zealand and Vincenzo Raimo, an independent international higher education consultant.

For many international students, education agents help navigate unfamiliar admissions and visa systems. For universities, they are an important part of the recruitment model, providing reach, volume and local market knowledge. But in the UK and beyond, concerns remain both about agent behaviour and how higher education institutions manage these partnerships.

In response to these concerns, the British Universities’ International Liaison Association (BUILA), Universities UK International (UUKi), the UK Council for International Student Affairs (UKCISA), and the British Council introduced the UK Agent Quality Framework (AQF) Pledge in December 2023. The Pledge enabled higher education institutions to make a public “commitment to quality assurance in agent management practices within their institutions”.

The AQF is built around four principles, including student choice, good governance, ethical practice and transparency. On 7 April 2026, a mention of the AQF was included in the Home Office Student Sponsor Guidance, stating that:

All student sponsors using recruitment agents must have committed to adhering to the key principles of the Agent Quality Framework (AQF) as stated at: https://www.aqf.info/. As part of these commitments, student sponsors may want to consider the recommended actions and best practices set out on the AQF webpage.

The inclusion of the AQF in the Home Office sponsor guidance gives the framework new weight. What began as a voluntary, sector-led commitment has now moved closer to the compliance environment in which licensed student sponsors operate. Yet signing the AQF Pledge is only the starting point. If the framework is to mean more than a public statement of intent, prospective international students should be able to see how universities are putting transparency and accountability principles into practice.

To test this, we reviewed the websites of a sample of universities that had made the AQF Pledge by August 2024, representing around 40 per cent of the 135 pledging institutions. We asked what a prospective international student could reasonably find out: whether institutions published agent lists, signposted guidance, explained the university–agent relationship, provided a complaints route, and disclosed whether agents are paid by the university.

The visible bits are mostly there

The easiest elements of compliance are, in most cases, present: most of the universities in the sample had some form of agent listing. Many also linked to the British Council’s A student and parent guide to choosing an education agent. The architecture of compliance is becoming more common: an agent page, a guide link, a country page, an email address somewhere.

But universities varied considerably in how they presented information about their appointed agents. Some provided little more than the name of an agent and a web link. Others included full contact details, office locations and information about multiple branches. Some institutions kept agent information on a single central page, while others scattered it across a range of pages. In several cases, we were left wondering whether the list shown was in fact complete.

One particular area where transparency remains underdeveloped concerns sub-agents. Some universities explain that their agents may work with other companies or individuals, and some advise students to use only the agents listed on the university website. But the implications are often unclear. If a student is dealing with someone who is not directly contracted by the university, they need to know whether that person is authorised, whether the university has any oversight, and  whether the same complaints or support routes apply.

Honesty about the relationship

Many universities make clear that they have some form of relationship with the agents listed on their websites. Some refer to “approved”, “official” or “authorised” representatives; others say that they “work with” agents or that their representatives “can help” prospective students.  The language is not necessarily inaccurate, but it often stops short of explaining the nature of the relationship. It may tell students that an agent is known to the university but not whether the agent has been formally appointed, authorised or contracted to recruit on the institution’s behalf.

A prospective student should not have to infer the nature of the relationship from euphemisms. If an institution has signed a contract with an agent to recruit students on its behalf, it should say so.

That brings us to the next weakness: commercial transparency. While most universities mentioned commission payments for students who enroll, around one-third of the websites we reviewed did not explain how agents are compensated. The issue is not that universities fail to disclose their use of agents or the existence of commission. A majority do. The concern is that the disclosure is often partial, uneven or framed in ways that minimise the commercial nature of the relationship.

There are, to be fair, examples of good practice. The University of Bedfordshire, in particular stood out for being notably more explicit than most in explaining that:

 agents are paid by the university on a commission basis once you enrol. Commissions are made on the net fee (the fee the student actually pays) – it is important to understand this, as it may influence how they advise you.

That is exactly the sort of plain-English transparency prospective students need.

Complaints: often present in form, weak in substance

The AQF refers to complaint processes being explained, although it does not explicitly require this information to appear on university websites. But for transparency, agent-related complaints information should sit alongside agent listings and relationship information. A prospective student should not have to search across multiple pages to work out how to raise a concern about one of the university’s appointed agents.

In our sample, the information on complaints was mixed. We focused on complaints or feedback information that appeared on, or was clearly linked from, the university’s agent pages. Some universities provided a simple email address for feedback. Some had a feedback form. A few offered more meaningful guidance, including when students should complain and what would happen next. The University of Aberdeen was one of the strongest examples explaining when a student might want to complain, how the complaint process works, and possible outcomes.

But in many cases, there was little or nothing on how complaints are processed, who reviews them, how long the process takes, or whether the student’s identity would remain confidential.

The last point is particularly important. An applicant may be understandably reluctant to complain if they fear the agent will know or that the complaint could somehow prejudice the application. Universities should say clearly that complaints are handled confidentially, and ideally provide a simple, accessible form rather than expecting students to navigate a maze of vague pages and generic inboxes.

If we struggled to find it, what chance does a prospective student have?

One of the most striking aspects of our review was not just what was missing, but how difficult some of the information was to find. There were broken links, buried pages and references to guidance that did not take the user anywhere useful. In some cases, even knowing exactly what we were looking for, we still had to work hard to locate it.

If someone familiar with the sector cannot easily find the relevant information, what chance does a prospective international student have, especially when navigating in a second language and with limited knowledge of university admissions?

Transparency is not only about whether information exists. It is also about whether it can be found, understood and used.

Transparency does not map neatly onto tariff

One might assume that higher tariff institutions would show stronger compliance or more mature practice. The sample did not support that. There were good and weak examples in all tariff groups: some higher tariff institutions appeared polished but vague, while some lower tariff institutions were much more direct. This suggests that the issue is not about prestige, selectivity or brand strength, but institutional choice: whether to be explicit or evasive, whether to write for students or for reputational comfort.

A practical transparency checklist for universities using recruitment agents

To support this, we have developed a simple transparency checklist for universities using recruitment agents. It is intended to help institutions test whether prospective students can easily identify who is authorised to represent the university, understand how agents are appointed and paid, know what to expect from them, and raise concerns when things go wrong. The test is whether a prospective student can find, understand and use the information.

Why this matters: things the sector risks forgetting

Prospective international students are not just leads, deposits, conversion funnels and enrolment targets. These are real people. A poor experience with an agent can affect not just an application, but a life decision involving money, trust, family pressure and personal aspiration.

Universities should remember that every vague web page, every buried complaint route, every reluctance to explain that agents are being paid and for what, can make the journey more difficult for prospective international students. There are significant information asymmetries between agents and students, and those asymmetries can lead to poor choices or less favourable outcomes.  One of the key principles of the AQF is that of” empowering student choice and enabling informed decision making”. If universities are serious about the principle, they need to consider all the ways in which they can make the use of agents clearer, safer and more transparent for students.

Beyond the optics of compliance

Most universities now publish a list of their agents, provide at least some information about their relationship with agents, and signpost the British Council guide. That is progress. But many have still not fully adjusted their websites to reflect the AQF’s recommended actions.

Part of the problem is that current wording in the Home Office guidance lacks force. Student sponsors using recruitment agents must commit to the key principles of the AQF, but they only “may want to consider the recommended actions and best practices set out on the AQF webpage”. This creates space for uneven implementation. Without clear expectations and some form of oversight, there is a risk that the AQF may become a symbolic promotional tool for the UK international education sector: a way for universities to signal quality and responsibility without necessarily changing practice.

The AQF’s recommended actions should therefore be seen as a floor, not a ceiling. If the framework’s principles are to shape institutional practice in any meaningful way, universities need to move beyond tick-box compliance. That means aligning agent management practices, website content and student-facing information more closely with the framework’s stated purpose by giving prospective students clear, accessible and honest information about the role of agents and the nature of the relationship between agents and institutions.

Find the referenced transparency checklist here.