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Non-genuine providers and bad faith operators
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Key focus for priority
- Non-genuine providers and border integrity breaches
- Fraudulent issuance of qualifications
- Funding fraud
- Phoenixing
- Infiltration of serious organised crime and bad faith operators into genuine RTOs

Risk overview
Non-genuine providers and bad faith operators pose a critical risk to the integrity of Australian vocational education and training (VET), undermining education quality, damaging the sector’s reputation, and creating serious regulatory, financial and security risks. These entities deliberately exploit the VET system for financial gain, migration fraud and the manipulation of government funding programs.
Allegations of non-genuine provider behaviour are a recurring theme in tip-off data and reports from stakeholders, indicating practices that compromise education quality, lead to student dissatisfaction and non-completion, and often represent a loss of investment of student time and money in training that was not delivered as expected.
Key points from research
- Some Registered Training Organisations (RTOs) operate as ‘visa mills’ and ‘ghost colleges’, fraudulently facilitating student visa applications by enrolling students into VET without the genuine intention of delivering education. These providers fail to enforce attendance, academic progression, or assessment integrity, allowing students to bypass study requirements and breach visa conditions.
- Some RTOs issue VET qualifications to students who have not completed legitimate study or demonstrated competency. This undermines the credibility of Australian qualifications, facilitates visa fraud, and enables unqualified individuals to enter high-risk industries, posing serious public safety concerns.
- Non-genuine RTOs facilitate the misuse of government funds, through fraudulently claiming training funds themselves or issuing fraudulent qualifications necessary for others to access funding schemes.
- Phoenix activity occurs when operators of cancelled RTOs re-emerge under new business identities to evade regulatory scrutiny while continuing unethical practices.
- Individuals previously linked to fraudulent or unethical RTO operations may integrate into legitimate providers assuming roles such as owners, executives, trainers, assessors, consultants, or legal and financial advisors.
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