ASQA Risk priorities 2025-26

Key focus for priority

• Provider viability
• Market manipulation
• Misleading marketing practices
• Offshoring services
• Unregulated education agents.

Risk overview

The delivery of training to international students introduces unique risks to providers operating under the Education Services for Overseas Students (ESOS) framework that do not typically apply to domestic vocational education and training (VET). The integrity and quality of international VET and English Language Intensive Courses for Overseas Students (ELICOS) are influenced by complex global and local political, economic, and social factors.

Challenges such as provider dependence on visa settings for financial stability, market manipulation and unethical recruitment practices create vulnerabilities within the sector. These risks are interconnected, with disruptions in the international student market having potential flow-on effects across the broader VET sector.

Many ESOS providers rely on education agents to attract and recruit international students. However, some agents pressure providers and threaten to withdraw their business if the provider refuses to accommodate non-genuine student enrolments. This heightens the risk of genuine providers compromising their compliance to maintain student flow and viability, undermining the integrity of VET and enabling visa fraud.

The presence of non-genuine students also contributes to regulatory non-compliance and diminishes educational quality, undermining confidence in Australian VET and displacing legitimate international students from accessing educational opportunities.

Key points from research

• Economic pressures and visa policy changes are expected to reduce the number of onshore international students, creating financial and operational challenges for ESOS providers.
• Some providers may adopt high-risk strategies to remain viable, including engaging in unethical recruitment practices, lowering the quality of training and student support, or shifting components of delivery offshore such as assessment or back-office services to stabilise financial health.
• More ESOS providers are joining forces — either by being bought by other companies or by working together in informal groups. Which in some cases might conceal ownership or control.
• Some providers and third-party agents engage in deceptive marketing, misrepresenting training quality, resources and costs, as well as migration outcomes.
• In response to financial and migration policy pressures, some providers are reconsidering their operational models, moving components of their business offshore. Reporting indicates that providers are outsourcing elements of onshore training and assessment to offshore third parties, which introduces risks to the quality, currency and consistency of education and increases the complexity of effective regulatory oversight.
• Complex education and migration networks, often with undisclosed cross-ownership or financial ties, enable collusive behaviours that undermine ethical student recruitment.   

Key focus for priority

• Academic cheating
• Contracting cheating services (CCS)
• Provider enabled dishonesty.

Risk overview

Academic integrity is fundamental to the credibility and quality of education delivered by the vocational education and training (VET) system and essential for sustaining workforce skills and job readiness. However, the sector is increasingly facing risks related to academic dishonesty from students and provider staff who engage in unauthorised collaboration, plagiarism, or use third parties to undertake student assessments, or altering student assessments after submission.

Facilitating academic cheating is essential to the operations of non-genuine providers, making it an integrity risk to the sector. While legislation has disrupted operations for some commercial cheating services, they often continue their engagement with the sector by reappearing under new identities and marketing techniques. Academic dishonesty is a gateway for unscrupulous operators to enter the sector and facilitates the presence of non-genuine students. Furthermore, it erodes trust in qualifications and undermines the integrity of Australia's VET and visa systems, compromising national workforce competencies.

Key points from research

• Academic cheating remains a concern within the VET sector. Increased workload pressures on academic staff, unsecured learning platforms, sustained growth in online delivery, aggressive marketing by contract cheating services and rapid advancement of artificial intelligence (AI) technology are factors likely to broaden the scope of this threat.
• Contract cheating services have increased their reach into the VET system through aggressive marketing to students directly through AI-driven apps, social media, peer introduction and even provider learning platforms.
• There are reports of contract cheating services extorting students who use their services and threatening violence against institutions and individuals who attempt to block or restrict their operations.
• Some providers are actively facilitating academic dishonesty among students and staff, allowing, or encouraging cheating behaviours to support financial gain or operational convenience.

Key focus for priority

• Unethical marketing of recognition of prior learning (RPL)
• Inadequate assessment practices
• Issuance of fraudulent qualifications
• Under-reporting of RPL data.

Risk overview

RPL is a legitimate part of the VET sector and the Australian education system. Performed well, it recognises skills built from experience and provides a robust framework to ensure people can have their skills recognised.

Individual competency-based assessment must be undertaken by qualified assessors including to identify training required to fill gaps in a person’s knowledge and skills to meet the requirements specified in a training package. ASQA has ongoing concerns about the inadequate RPL practices of some providers who exploit vulnerable students and compromise the integrity of qualifications.

Students who gain qualifications through RPL, yet lack the required competency or knowledge, compromise the confidence that students, industry, governments, employers and the community have in national qualifications. Inadequate assessment practices and business models that are cutting corners in issuing RPL allow unqualified persons entry into critical roles, which poses a risk to themselves and others in the workplace and adversely impacts community safety.

The issuing of qualifications through RPL without appropriate assessment is an enduring and growing risk in the VET sector. Unethical RTOs, some operating within sophisticated networks, are functioning as ‘RPL mills’, using high-volume, low-quality assessment models to target mandatory qualifications for government funded job roles, areas of skills shortages and migration pathways.

These bad-faith operators distort the VET market by undermining the value of genuine RPL and displacing quality RTOs from the market. Fraudulent RPL qualifications pose a serious threat to the integrity of Australia’s VET and migration systems, compromises student work readiness, and introduces risk into workplace settings.

Key points from research

• Third-party RPL brokers play a facilitatory role in the issuing of non-genuine RPL qualifications. This presents jurisdictional challenges as brokers are not regulated.
• Networks of unethical operators, comprising primarily of RPL brokers, migration agents, labour hire organisations and registered training organisations (RTOs), are colluding to aggressively market RPL. Their tactics mislead students by promoting qualifications as easily obtainable without study or genuine assessment.
• Some RTOs operate high-volume, low-quality assessment business models, issuing VET qualifications through RPL to individuals without adequately verifying their competencies.
• The use of fraudulent qualifications poses significant risks to community safety, particularly in sectors most susceptible to exploitation by unethical operators, such as aged care, individual support, childcare, security and trade occupations.
• Providers are almost certainly under-reporting RPL in Total VET Activity (TVA) data to avoid regulatory scrutiny, attract higher levels of VET funding, and for other exploitation purposes.

RPL advice under the 2025 Standards

The 2025 Standards came into full regulatory effect on 1 July 2025, and we have published the RPL & Credit Transfer Practice Guide.

The Practice Guide sets out obligations for providers in relation to RPL and provides guidance on how providers may achieve compliance with these obligations – including examples of activities that may demonstrate compliance, risks to quality outcomes, and assurance questions providers may wish to consider in assessing their performance and readiness.

Providers are encouraged to review their systems, policies and practices as they relate to RPL to identify any gaps and implement plans to address these.

This is particularly important considering ASQA’s ongoing and heightened regulatory focus on RPL. We continue to monitor provider compliance, targeting inadequate assessment practices, false or misleading marketing of RPL, gap training unavailability and the issuance of fraudulent qualifications. We have and will continue to take action against providers with non-compliant assessment or RPL practices, including removing providers from the sector who are found to have fraudulently issued qualifications and taking regulatory action that may result in cancelling the qualifications issued.

Unregistered third-party brokers and agents are often critical to the process and facilitate issuing non-genuine qualifications, purporting to deliver an RPL process. Brokers and agents often use hostile and unethical marketing practices in a market where there is high demand for quick qualifications. These practices are unacceptable and, in some cases, fraudulent.

For more information on the 2025 Standards, including access to the full suite of Practice Guides, visit our 2025 Standards for RTOs webpage. You can also learn more about the 2025 Standards on the DEWR website. 

Key focus for priority

• Misleading marketing practices
• Inadequate assessment of learner needs
• Insufficient training delivery
• Inadequate online training
• Loss of industry confidence

Risk overview

The delivery of training within timeframes shorter than those indicated by the training package or qualification level pose risks to the quality and reputation of vocational education and training (VET) qualifications and present a barrier to career outcomes for some students. There are concerns across the sector that training is being delivered over increasingly shorter time periods, without ensuring students have demonstrated competencies.

The shortening of course durations is achieved by accelerating delivery through high-intensity training or restricting content by reducing the volume of learning and training. Short delivery RTOs are shifting the training focus primarily to assessment rather than comprehensive skill and knowledge development, compromising student learning outcomes. This is particularly prevalent in online delivery contexts.

Widespread adoption of shorter than expected course durations is contributing to concerns from industry stakeholders regarding the validity of qualifications issued under shortened timeframes. This has broader implications for the credibility and reputation of the entire sector.

Key points from research

• Marketing qualifications with unrealistically short course durations that fall well below Australian Qualifications Framework (AQF) volume of learning recommendations undermine public confidence in VET. This practice misrepresents the actual time needed to achieve competency, influencing student choice of RTO, and distorting the market as quality-focused providers struggle to compete against those offering minimal training.
• Providers delivering shortened courses often fail to assess and adjust training to meet individual learner needs. This leads to students being under prepared for the workforce, increasing risks to workplace safety, work quality, and broader industry standards.
• Some RTOs strip the training components from courses to reduce duration, leaving only assessment, severely limiting student competency.
• Many fully online courses offer shorter training durations than face-to-face modes, often at the expense of education quality and practical skill development. Some online platforms allow students to bypass learning activities and proceed directly to assessment, reducing the depth and breadth of exposure to learning. Limited trainer engagement and minimal interactive support for online students further hinders learning.
• Both accelerated delivery (high-intensity learning) and shortened delivery (low-volume learning) may compromise the depth and quality of education offered to students. 

Key focus for priority

• Enrolment-focused providers
• Difficulty securing placements
• Falsification of placement records
• Inadequate workplace assessment
• Remote delivery

Risk overview

Student work placement continues to be a high risk in the sector. Poor provider management of work placements remains a strong concern for many stakeholders. Over-enrolment relative to available placements, inadequate placement support for students and employers, and failure to conduct mandated workplace assessments threaten student education and job-readiness.

Poor quality placements may also expose students to safety or wellbeing risks and leave graduates lacking the practical skills and experience needed for workforce readiness. Emerging issues such as wage theft and labour exploitation associated with placements further threaten the integrity of vocational education and training (VET).

For example, allegations have been received of providers charging students additional fees for work placement, with some payments forwarded to the student’s employer as reimbursement for legitimately earned wages.

Key points from research

• Some providers prioritise increasing enrolments without securing sufficient quality placements for their students or ensuring they can manage the placement effectively.
• Responsibility for securing work placements is increasingly being shifted on to students, often leading to progression delays or non-completion. Many students are unaware of this responsibility prior to enrolment or do not have the industry connections or knowledge to secure suitable placements. Students studying online or in rural and regional areas are particularly disadvantaged due to limited placement opportunities.
• Certain student groups face additional barriers to securing and completing work placements including international students, individuals with disabilities, those from disadvantaged socio-economic backgrounds, and students with limited work experience.
• Instances of students, providers and employers falsifying work placement records have been reported.
• Some providers fail to conduct required workplace assessments, replacing direct, on-site observation by a qualified assessor with simulated environments, limited supervisor feedback, or student generated digital recordings.
• International students on temporary migration visas are particularly vulnerable to exploitation due to power imbalances.