Providers and partners

Information for education agents for schools

Managing and monitoring education agents

It is important that New Zealand provides international school learners with a quality education through an experience that meets and exceeds their expectations.

Education agents play a key role in achieving this goal. They are often the first point of contact with international learners and families.

Schools play a vital role by effectively managing and monitoring their education agents, a responsibility outlined in Outcome 14 of the Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021 (the Code).

Schools who enrol international school learners must be signatories to the Code and meet Code requirements.

The information below outlines the minimum process requirements for Code signatory schools for managing and monitoring their education agents.

It also recommends some good practice that may assist a signatory school to meet or exceed the overarching Code outcome.

Requirements for managing and monitoring education agents

Under the Code, signatory schools must meet the following minimum process requirements:

carry out and record reference checks on potential education agents
enter into a written contract with each education agent
terminate contracts if there is evidence suggesting poor or non-compliant education agent conduct (as defined in Clause 59 (d)(a) and (b) of the Code)
ensure that education agents have up-to-date information relevant to their duties.

Recommendations for good practice

Further to the minimum process requirements listed above, each Code signatory school will need to consider what, if any, additional activity is necessary for their organisation to meet or exceed the overall Code outcome for managing and monitoring education agents.

There is no one size fits all.

This is where it becomes important to tailor practice to meet the needs of your particular learners, in your particular organisational context.

'Good practice' may look different in each school, depending on the markets, education agents, and learners involved.

Below are some recommendations for practice that may assist your school to meet or exceed Outcome 14 of the Code.

These recommendations are not requirements, but suggestions for practice gathered from a range of provider types across different sectors.

It may not be necessary or practicable for your school to adopt some of these recommendations, or there may be other practices not listed here that your school decides it needs to do to meet the outcome 14 requirements.

Once you have complied with the minimum process requirements, you should assess what you need to do to be confident that your education agents are providing quality advice to international learners, and acting with integrity and professionalism.

Understand the intent of this outcome

Outcome 14: managing and monitoring education agents, states:

Signatories must effectively manage and monitor their education agents to ensure that those education agents –

(a) provide international school learners with reliable information and advice about studying, working, and living in New Zealand; and

(b) act with integrity and professionalism towards prospective international school learners; and

(c) do not breach the law or jeopardise the signatory’s compliance with this code.

The intent of this outcome is:

The intent of this outcome is to ensure that education agents always act with the utmost integrity and are clear about their obligations, and that you have robust management and monitoring procedures that ensure education agents provide international school learners and their families with the best possible information and support.

This means that your policies and processes must include education agent monitoring activities as well as the appropriate interim actions you will take should you discover misconduct by an education agent that is not serious enough to warrant contract termination, but nonetheless still requires management and a remedial response.

It is important to keep the intent of the outcome in mind when contracting, supporting, and monitoring your education agents.

Understand the role of education agents

Understand how an education agent is defined in the Code

An education agent is defined in the Code as a person, body, or organisation acting on behalf of a signatory in relation to any aspect of their international learners' enrolment and study, including accommodation, and includes a subcontracted agent.

Know that there are different types of education agents

Education agents work in international student recruitment. They may work offshore or offshore.

Immigration advisors provide immigration advice. They may also be education agents.

Anyone who gives New Zealand immigration advice must be licensed, unless they are exempt.

Find out who is exempt from being licensed

Be aware of the key services that education agents may provide

Information on living and studying in New Zealand
Assistance with applications to education providers
Advice on visa options and/or assistance with visa applications (see education agents' legal obligations for information about giving immigration advice)
Promotion and marketing of education providers
Market intelligence
Translation services.

Understand the motivations of education agents

Most education agents act in the best interest of the learner.
Education agents make money through commission-based sales.
Commission is paid by the school, usually in the form of a percentage of the tuition fees the learner pays.
Some education agents also charge the learner fees for different services they offer, over and above any tuition fees the learner pays.

Remember the benefits of working with education agents

Education agents are a valuable channel for schools seeking to recruit international school learners and remain competitive in the market.
Education agents extend the "reach" of schools in offshore markets.
Education agents can assist schools with knowledge of the learner’s language, cultural values and contacts.
Education agents can provide useful guidance and support to learners and their families in decision-making, before, during and after the student arrives.

Be mindful of the challenges of working with education agents

Working effectively with education agents requires sustained investment of funds, time and effort from schools.
There may be a disconnect between the priorities, policies and values of the school and the education agent.
The risks of this disconnect and not integrating education agent management in business practice include: poor outcomes for learners and their families and reputational damage to your school and the New Zealand education system.

Understand your education agents' legal obligations

Under the London Statement of Principles, education agents are required to:

practice responsible business ethics
provide current, accurate and honest information in an ethical manner
develop transparent business relationships with learners and signatories through the use of written agreements
protect the interests of minors
provide up-to-date information that enables international learners to make informed choices when selecting which education agent or consultant to employ
act professionally.

Learn more about the London Statement of Principles

Under the Immigration Advisers Licensing Act 2007 (the Act)

People who give New Zealand immigration advice must be licensed, unless they are exempt.

Find out who is exempt from being licensed

Immigration advice does not include providing information from a publicly available source or clerical work.

Education agents are exempt to advise on student visas, but only when offshore. They are not exempt to advise on any other immigration matter. Onshore education agents must be licensed to provide any immigration advice, including on student visas.

See the Immigration Advisers Licensing Act 2007

The Immigration Advisers Authority has information on what is immigration advice, including factsheets for education providers and education agents.

See the Immigration Advisers Authority website

Integrate education agent management into business practice

Key starting points

Include costs of managing and monitoring education agents in your organisation's annual budget.

Designate staff for the ongoing identification, recruitment, training, management, and review of your organisation's education agent network.

Develop the information systems required for the ongoing monitoring and record keeping involved in managing education agents.

Develop a policy stipulating:

criteria for education agent selection
appointment and review process
support for education agents through access to information, regular contact and training
commission for recruitment
investigation process for learner complaints regarding education agent's conduct
the process to terminate an education agent's contract in case of misbehaviour by the education agent.

If you have the resources, develop an education agent information portal as the main communication channel.

The portal can include:

education agent training initiatives
programmes of study your school wishes to promote to international learners
any relevant fees
policy on recognition of prior learning
international scholarships
marketing initiatives, events and exhibitions
online application submission and tracking facilities
information on the city where your school is located, such as average cost for student accommodation, food and transport
a copy of the Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021.

Download a copy of the Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021 (PDF, 925KB)

Set and monitor key education agent performance indicators (KPIs)

An expected conversion rate for offers of place and monitor the conversion rate:

How many of the offers of place issued to the agent result in a visa application?

The agent's visa approval rate:

How many of the visa applications submitted result in an approval?

Use different sources of information

Contact local Business Council, Study Group and education agents’ associations.

Contact providers with experience in managing and monitoring education agents.

Education New Zealand (ENZ) Skills Lab has four training modules on education agents to assist providers.

Visit relevant websites:

ICEF

FPP.

Choose good agents

Be in the driver’s seat

Ensure the education agent is a fluent communicator in English as well as the home country language.

Look for education agents in line with your school's international strategy and priority markets.

Be aware of differences between regions of priority markets in terms of risks and opportunities. Not all regions of one country are the same.

Ensure the education agent has knowledge of New Zealand and its education system, and/or is actively interested in developing this.

The ENZ Recognised Agency directory lists agents who have completed training about learning, living and working in New Zealand.

Check the ENZ Recognised Agency directory

The Immigration Advisers Authority (IAA) website has a directory of licensed immigration advisers.

Go to the Immigration Advisers Authority (IAA) website

On the INZ website you can check the agency’s student visa application approval rates (for agencies based in India, Philippines and Viet Nam only).

Check the approval rates of the agents' student visa applications

Develop a waiver/obtain the permission of the education agent for your school to check performance with INZ.

Seek advice and references from international education professionals/providers who have used that education agent.

Google the prospective education agent/agency.

Attend agents and student recruitment fairs to meet education agents interested in New Zealand.

Check the ENZ website for their events list

Remember it is at your school's discretion to choose to offer a contract.

Undertake due diligence

Develop a robust education agent application form.

See each section for a sample of questions you could include in the form.

Contact details

Registered agency name and trading name
Owner/director and main contact person
Street and postal address
Telephone/email/website/skype/zoom/wechat/facetime/whatsapp, etc.

Business background

When was the agency formed?
What is the main purpose of the agency? (student recruitment, travel and tourism, immigration, other – please specify)
Does the agency have offices that operate independently from head office?
Is the agency GST registered in New Zealand? If so, please provide GST number.
Does the agency have membership to any professional organisation linked to the education industry?
Is the agency registered officially in its home country? If so, please provide details.
Are agency staff members licensed immigration advisers with New Zealand’s Immigration Advisers Authority?

Is the agency an ENZ Recognised Agency?

Check if the agency is a Recognised Agency

Have the education agents completed ENZ’s Online Training Programme?

Find out about ENZ's Online Training Programme

International learner recruitment experience

How many student counsellors/advisers does the agency employ?
Have the education agents had experience as international learners? (If so, which providers and countries?)
Does the agency publish a company prospectus or brochure in English? If so, please include a copy.
What are the nationalities of the learners the agency recruits?
Which countries does the agency send most international learners to?
What education levels does the agency recruit most learners for (e.g. English school, primary, secondary, foundation, undergraduate, postgraduate)?
In addition to the commission received from providers, does the agency charge learner clients any type of additional fee at any stage? If so, provide details.
How many learners did the agency recruit last year in total? How many for New Zealand providers?

Knowledge of New Zealand, school and relevant requirements

Does the agency have a representative in New Zealand?
Does the agency have current working arrangements with any other providers/schools in New Zealand?
Does the agency assist international learners with travel and immigration requirements?
What systems does the agency have in place for checking that learners have the required English language proficiency and other academic entry requirements?
What systems does the agency have in place to ensure international learners meet immigration requirements (if applicable)?
Does the agency have a protocol for dealing with international learners?
Are the education agents aware of the New Zealand Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021?
How many international learners does the agency anticipate sending to New Zealand and to [school’s name] per year?
Is the agency interested in undertaking further training to learn more about New Zealand, [school’s name] and relevant requirements?

Business credentials

Please provide two education providers to act as referees (preferably from New Zealand or Australia).

Sample of reference check questions

How long have you [referee] worked with this education agent?
Is the education agent reliable and professional?
Are you [referee] aware of any incidence of fraud or unethical behaviour?
Has this agency submitted successful international learner applications (converted to offers of place) within the past 12 months?
Please comment on the quality of the learners referred by this education agent.
Any comments or feedback on this education agent’s knowledge, skills or ability to produce outcomes?
How would you [referee] describe the education agent’s knowledge of New Zealand, such as education system, immigration policies, etc.?
Do you [referee] recommend this education agent?
Any other relevant information you [referee] would like to provide?

Develop a robust education agent contract

Seek independent legal advice on your education agent contract before you use it.

Outline expectations of education agent behaviour in the education agent’s contract

These may include but are not limited to:

interviewing prospective international learners and their families
the use of subcontracted agents (whether as a school you allow this or not)
no commission paid to learners selected when already on pathway to study at [provider’s name] (this will discourage poaching practices)
agreement to commission schedule structure
no learner funds are held by the education agent, payments must be forwarded and must be in gross.

Clearly define the roles and responsibilities the education agent will hold

Promotion and marketing, such as advertising in shop front, the education agent representing your school at events, advertising campaigns, etc.
Market research, such as informing your school of upcoming trends, demands and market conditions.
Orientation before the student departs.
Support and counselling after the student departs.

Request declarations

Request declarations of:

potential conflicts of interest
act in accordance with the New Zealand’s Immigration Advisers Licensing Act 2007
act in accordance with the New Zealand Education (Pastoral Care of Tertiary and International Learners) Code of Practice 2021.
adherence to ethical standards (attach the London Statement of Principles for ethical international student recruitment)
any material translated by the education agent must be consistent with the English version.

Request key information

Ask for:

vetting waiver authorising INZ to provide all relevant data regarding the education agent's conversion rate of offers of place (e.g. expectation of 20% of offers issued by your school result in successful student visa applications)
a copy of all visa decline letters that the education agent receives
robust verification of international learner documentation before the agent submits it to the provider and/or INZ.

Support your education agents

The school-education agent relationship is two-way.

Schools can support education agents

To support education agents, schools can:

offer ongoing training to enable education agents to provide up-to-date and useful information to learners
request feedback from education agents to assess how to better enable positive outcomes for your school, learners, and education agents
keep education agents informed of any changes to government education or immigration policy.

Sample of education agent survey questions

How satisfied are you [education agent] with the services provided by [school name]?

What can [school name] do to improve its relationship with you [education agent]?

Have you [education agent] kept in contact with learners after they started studying at [school name]?

Are you [education agent] confident you have the support needed to maintain your contract? Would you like further training?

How easy is it to access [school name]’s information needed to keep learners informed?

How satisfied are you [education agent] with [school name]’s:

length of time to process enquiries
length of time to process applications
quality of information received
accuracy of information received.

Manage risk

Manage the risk to your school, learners and the reputation of the international education sector

You can manage any risk by:

consolidating the number of contracted education agents so that they can be actively managed and monitored by your school
including the education agent name in the offer of place whenever possible
if education agents use subcontracted agents, including both the primary education agent and subcontracted education agents’ names on the offer of place
if your school does not allow subcontracted agents, stating on the offer of place that it is invalid if submitted to INZ by anyone other than the education agent named on the offer
measure the percentage of learners enrolled through education agents to assess your school's dependency on education agents
developing an education agent-focused webpage for all relevant information
regularly checking education agents’ marketing (including immigration related statements), such as on their websites and social media pages
visiting offshore education agents when possible, to get a first-hand understanding of how they operate
surveying international learners and families for their experiences dealing with your school's education agents
translating surveys into different languages to access families’ feedback.

Sample of learner/family survey questions

Describe your overall level of satisfaction with [education agent name]'s performance.

Describe [education agent name]'s level of knowledge about [school name]’s:

programmes of study
entry requirements (such as English language proficiency)
learner support
refund policy
facilities
accommodation options
International School Learner Handbook
other relevant information

Did the education agent charge a service fee? If so, how much?

How well did the education agent prepare you [international learner] for your arrival in New Zealand?

Do you [international learner] have any suggestions on how [school’s name] can help education agents to improve the service to our learners?

Any other comments on the service from received from your education agent?

Risk analysis and follow-up action

Look for trigger points and trends in the education agents’ KPIs and surveys that lead to poor outcomes for learners.

Assess education agent engagement with your school to determine future partnership (e.g. following process, responding in a timely manner, etc.).

Where risk is identified, send information to the learner, the education agent and relevant government agency:

NZQA	code.enquiries@nzqa.govt.nz
INZ	educationproviders@mbie.govt.nz
ENZ	agenthelp@enz.govt.nz
IAA	info@iaa.govt.nz

Further information

If you have any questions or concerns email the Code team.

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