New Stringent Duties Introduced for Migrant Student Recruitment Agents and Sponsors
Licensed student sponsors are now required to meet new Home Office regulations for the education agents they utilise to recruit international students. These modifications impose stronger record-keeping and reporting requirements and require sponsors to show responsible management of recruitment activities. The revisions are a response to concerns that certain agents have been helping applications from non-genuine students.
From 7 April 2026, sponsors will have new responsibilities when working with agents or other parties. One major change is that sponsors will be required to include agency details when assigning a Confirmation of Acceptance for Studies (CAS) to any prospective student they acquire through an agent.
Recruitment agents have been a concern for some time. In May 2024, the Migration Advisory Committee (MAC) raised this concern in its review of the Graduate Visa route. The MAC called for stronger oversight to combat improper and misleading practices. This was followed by the Immigration White Paper which proposed that all sponsors employing recruitment agents should sign up to the Agent Quality Framework (AQF), a sector-led initiative to promote best practice and quality assurance in international student recruitment.
These responsibilities were established in the updated Student Sponsor Guidance published on 7 April 2026 . This and previous FAQs produced in March 2026 clarify that sponsors remain entirely responsible for the recruitment of international students and cannot contract out that responsibility to third parties.
The information that needs to be given concerning agents or third parties to the UKVI is set out in the SMS Guide 4A – Creating a CAS – guide for sponsors
- New Agent List Requirement
Sponsors are now have to disclose a full list of all agencies and third parties they engage, wherever they are located in the UK or elsewhere. The list will be kept current and any additions, removals or modifications will be reported within 20 working days. Applicants for a new sponsor licence must also provide a comprehensive list of proposed agents.
Required details: Company name (legal name, no abbreviation) Primary contact name Full Address (including branch location where necessary)
Third Parties and Agents
Sponsors must record data of agents on the CAS where the sponsor has used an agency in recruiting the sponsored student. You may get further details about what information to include in SMS guidance 4A – Creating a CAS – guidance for Student sponsors.
If a sponsor has utilised an agent or third party to recruit that student, the sponsor must give details about the agent on the CAS, even if it is a one-off recruitment and/or recruitment has been done without a formal ongoing relationship with the agent or third party. If a sub agent is utilised, sponsors must submit details about the main agency and not the sub agent.
Where advisers have been engaged directly by the student to provide support with their application, and that third party was not used by the sponsor as part of the recruitment process, there is no requirement to submit agent details on the CAS.
The agent data should be for the agent used for the recruitment phase and the agent that the sponsor assigns the recruitment of the student to (for example but not limited to, who will receive any commission payment). If the agent then changes following the assignment of the CAS, sponsors do not need to mention this to UKVI.
Sponsors may use the ‘sponsor note’ box to correct minor inaccuracies found in the agent section after a CAS has been assigned.
If there are problems about an agent or third party after the CAS has been assigned they should be raised via studyriskteam@homeoffice.gov.uk or if unlawful activity is detected or suspected report as an immigration crime at https://www.gov.uk/report-immigration-crime. Student sponsors utilising recruitment agents must have agreed to be bound by the core principles of the Agent Quality Framework (AQF) as outlined at: https://www.aqf.info/. Student sponsors may wish to explore the recommended steps and best practice outlined on the AQF webpage as part of their commitments.
All sponsors that use student recruiting agents must keep proof of how they are managing their agents in conformity with the AQF and The National Code of Ethical Practice for UK Education Agents as applicable to the school, further education, route and higher education sectors.
- Reporting Changes to Agent Lists
Any changes to the details of an agent, including their name, contact or address, must be notified to the UKVI by email within 20 working days. Sponsors should keep records of such submissions to ensure compliance.
- Required CAS Agent Data
Sponsors must provide the details of the agent where an agent or third party has been used for recruitment for any CAS issued on or after 7 April 2026. This includes ad hoc arrangements or loose commitments. The agent recorded should be the one responsible for recruitment and usually the party getting commission.
Where you do not need to provide agent details
Student applied independently without any agent sponsorship participation
Post-application support was provided by an agent exclusively
The student is continuing in the same course or progressing within an established partner institution
- Commitment to the Agent Quality Framework (AQF)
Sponsors that use agents must show that they are following the AQF guidelines and keep documentation that they are managing their agents responsibly. This could include due diligence checks, contracts, training documents and organisational policies.
Compliance and Monitoring
The UKVI plans to use data from agents to track recruiting patterns and to detect potential hazards, such as linkages to fake applications. The information on the agent will not be immediately relevant to the decision-making process for the visa, but may be used to guide further checks if concerns are raised.
Sponsor Actions
To stay compliant, sponsors should:
Keep agent records accurate and up to date.
Compliance process agent reporting
Keep track of how each student was recruited.
Ensure agent details are on appropriate CAS records
Align internal processes with AQF guidance
Click To Read Sponsorship responsibilities Update 7 April 2026
All documentation on the management of agents should be held centrally and ready for inspection at the time of a UKVI compliance visit.