New Strict Responsibilities implemented for Migrant Student Recruitment Agents and Sponsors

LONDON April 30: Licensed student sponsors must now meet updated Home Office requirements regarding the education agents they use to recruit international students. These changes introduce stricter record-keeping and reporting obligations, along with an expectation that sponsors demonstrate responsible management of recruitment practices. The reforms reflect concerns that some agents have been facilitating applications from non-genuine students.

Effective from 7 April 2026, sponsors have new duties when working with agents or third parties. A key requirement is that sponsors must now include agent details when assigning a Confirmation of Acceptance for Studies (CAS) to any prospective student recruited through an agent.

Concerns about the role of recruitment agents were first highlighted in May 2024 by the Migration Advisory Committee (MAC) during its review of the Graduate Visa route. The MAC recommended tighter oversight to address poor and misleading practices. This was followed by the Immigration White Paper, which proposed that all sponsors using recruitment agents sign up to the Agent Quality Framework (AQF), a sector-led initiative promoting best practice and quality assurance in international student recruitment.

Updated Student Sponsor Guidance, published on 7 April 2026, formalised these responsibilities. Alongside earlier FAQs issued in March 2026, it makes clear that sponsors remain fully accountable for how international students are recruited and cannot outsource this responsibility to third parties.

The information that must be provided about agents or third parties to the UKVI is set out in the SMS Guide 4A – Creating a CAS – guide for sponsors

1. New Agent List Requirement
Sponsors must now provide a comprehensive list of all agents and third parties they use, whether based in the UK or overseas. This list must be kept up to date, with any additions, removals, or changes reported within 20 working days. New applicants for a sponsor licence must also submit a full list of intended agents.

Required details include: Company name (legal name, no abbreviations), Primary contact name, Full address (including branch location where relevant)

Agents and third parties

Sponsors must record agent details on the CAS where the sponsor has used an agent in the recruitment of the sponsored student. Further detail on the information which must be provided is set out in SMS Guide 4A – Creating a CAS – guide for Student sponsors.

Sponsors are required to provide agent details on the CAS in any instance where the sponsor has used an agent or third party in the recruitment of that student, even if this is a one-off recruitment and/or the recruitment was done without a formal ongoing contract with the agent or third party. If a sub agent is used, sponsors must provide details of the main agent not the sub agent.

Agent details do not need to be provided on the CAS where advisors have been engaged directly by the student to provide support with their application, if that third party was not used by the sponsor as part of the recruitment process.

The agent details should reflect the agent utilised during the recruitment phase, and who the sponsor attributes the recruitment of the student to (for example but not limited to, who will receive any commission payment). If the agent subsequently changes after the CAS has been assigned, sponsors do not need to report this to UKVI.

Sponsors may use the ‘sponsor note’ field to amend any minor errors in the agent section identified after a CAS has been assigned.

If sponsors identify concerns with an agent or third party following assigning the CAS, either raise via the studyriskteam@homeoffice.gov.uk or, if illegal activity is identified or suspected, report it as an immigration crime via https://www.gov.uk/report-immigration-crime.

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.

All student sponsors using recruitment agents must retain evidence of how they are managing agents in line with the AQF and The National Code of Ethical Practice for UK Education Agents, as applicable to the school, further education, pathway and higher education sectors.

2. Reporting Changes to Agent Lists
Any updates to agent details—such as changes in name, contact, or address—must be reported to UKVI within 20 working days via email. Sponsors should retain records of these submissions for compliance purposes.

3. Mandatory CAS Agent Information
For any CAS issued on or after 7 April 2026, sponsors must include agent details where an agent or third party was involved in recruitment. This applies even in one-off arrangements or informal agreements. The agent recorded should be the one responsible for recruitment, typically the party receiving commission.

Agent details are not required where:
The student applied directly without sponsor involvement from an agent
An agent was used only for post-application support
The student is continuing on the same course or progressing through an established partner institution

4. Commitment to the Agent Quality Framework (AQF)
Sponsors using agents must demonstrate adherence to AQF principles and retain evidence of responsible agent management. This may include due diligence checks, contracts, training records, and internal policies.

Compliance and Oversight
UKVI intends to use agent data to monitor recruitment patterns and identify potential risks, such as links to fraudulent applications. While agent information will not directly determine visa outcomes, it may inform further checks where concerns arise.

Actions for Sponsors
To remain compliant, sponsors should:
Maintain accurate and up-to-date agent records
Integrate agent reporting into compliance processes
Track how each student was recruited
Ensure agent details are included on relevant CAS records
Align internal practices with AQF guidance

Click To Read Sponsorship duties Updated 7 April 2026

All documentation relating to agent management should be centrally stored and readily available for inspection during UKVI compliance visits.