Unpacking the international student caps for each provider

Usually when I grab an image for these articles there’s a stock picture available that more than adequately sums up the content of the article. Today I’ve added myself to the image because I needed a representation of how much my head is hurting after trying to untangle the allocation of international student caps at the provider level…

Let me also add at the start of this piece that given what I have identified – there will be some readers who will respond that officials have done their best working to extremely tight deadlines. As a former public servant I have enormous respect for many of the officials who will have worked on this policy initiative – but tight deadlines do not excuse all of the errors identified here. Many of them would have easily been avoided if officials engaged regularly (across departments and with the sector’s regulators: ASQA and TEQSA).

So before I unpack ‘who got what’ and how the 2025 indicative international student caps for each provider compare with their current and prior year new enrolments, here are some of the anomalies that have my brain exploding:

1. Why are there 10 VET providers whose 2025 new overseas student commencements (their 2025 cap) are greater than the total number of international students they are able to enrol (their CRICOS cap)?
2. Given that some of these 10 providers have explicitly stated on their CRICOS entries that they offer very short qualifications (just 4 week and 8 week Certificates II and III qualifications in some cases) is it appropriate that they appear to be being rewarded for their shorter course duration by having a higher volume of students? Certificate II qualifications are supposed to run for 6-12 months, and Certificate III qualifications for 1-2 years. I would note that I make no judgements about these providers, they are not known to me and they could be delivering excellent quality training to highly skilled international students with lots of relevant prior experience and hence the very short courses, but it would be good to understand from ASQA why they are comfortable with such short courses being available for providers to deliver to international students, or if these might be the kinds of providers and courses ASQA identified in July 2024 in their 2024-25 Risk Priorities when they warned that shortened course duration “can result in insufficient skill development and knowledge retention, leading to graduates being ill-prepared for the workforce. This poses a significant safety risk to graduates, others in the workplace, and the wider community” and went on to say that they (ie ASQA) “have a low tolerance for providers that prioritise cost efficiency over training quality and student outcomes by reducing volume of learning or shortening training delivery timeframes, particularly in higher risk occupations, and we are using a range of compliance monitoring activities with targeted providers”. I would also note that not all the providers who received a 2025 cap above their CRICOS cap offer short courses – as the following examples demonstrate:
3. The leadership of NIDA (the National Institute of Dramatic Art) a dual sector provider registered with ASQA and TEQSA will be wondering quite how their caps were calculated? That is because although they are CRICOS registered with 16 qualifications they currently have no VET qualifications listed with CRICOS approval and yet they received a cap of 10 international higher education students and a cap of 30 international VET students despite having zero CRICOS approved VET qualifications they can enrol them in. Adding presumably to their (and certainly my) confusion is the fact that NIDA’s collective cap of 40 students for 2025  is twice as many as they can enrol in any given year (ie their total CRICOS cap is just 20 students) and all of their courses run for longer than a year except a six-month non-AQF study abroad qualification which might be exempt from them student caps entirely (when the exemptions are finalised)
4. The Queensland School of Film and TV (EduPro Australia Pty Ltd) was granted a cap of 30 for their only CRICOS qualification, the Diploma of Screen and Media, which they teach over 67 weeks. It seems impossible to me that they will be able to squeeze 30 international students in – when their total CRICOS cap is just 20 students in any given year…There are more anomalies in the details of the providers granted a higher 2025 cap than their overall CRICOS cap but I won’t list them all here – because sadly there are other anomalies to unpack…
5. How did the Anglican Schools Commission get included in the list of higher education providers (with their proposed caps for 2025)? Fortunately for other higher education providers, the Anglican Schools were granted a 2025 cap of zero international higher education students (noting that school students are not included in the caps) so no cap places will need to be reallocated to fix this error. But the Anglican Schools Commission is not now, and has never been, registered with TEQSA – so how were they included in the list of higher education providers…? My guess is that this might be because the Anglican Schools Commission (WA) has a “Western Australian Universities Foundation Program” on their CRICOS scope. This is a non-AQF qualification and hence does not require a provider to be a registered higher education provider to deliver it. It also therefore falls outside the definition of the courses which are in scope for the student caps – but I suspect the use of the term ‘universities’ in the course name might have been what triggered its inclusion on the list of caps for higher education providers. It definitely does not belong there and a simple cross check with the list of higher education providers with CRICOS approval either through liaising with TEQSA or by drawing down details from the CRICOS database would have identified the anomaly
6. A private dual-sector provider, Kontea Institute Pty Ltd, had its CRICOS approval suspended by TEQSA on 28 August 2024. The details released by the Department in response to the Senate’s Order for the Production of Documents shows that Kontea was given a cap of 10 higher education students for 2025 – with a footnote stating that “Since providers were advised of their indicative allocations, a delegate of TEQSA has suspended the ESOS registration of Kontea. A provider limit will not be able to be used where the suspension prevents the provider from recruiting and enrolling new students.” TEQSA suspended Kontea Institute’s CRICOS registration because of “concerns about financial viability and corporate governance” and four days later ASQA moved to cancel their RTO registration, effective 7 October 2024 (no details are provided on the reasons for the cancellation decision). Despite this Kontea has been allocated a cap of 33 new international VET students in 2025 and there are no footnotes to their entry indicating they will not be able to use their 2025 cap.
7. The following VET providers are appealing ASQA decisions to cancel, suspend or not renew their RTO registration in the Administrative Appeals Tribunal. (These providers may well be successful with their AAT appeals and therefore be allowed to continue to trade but, unlike the Kontea example in the higher education sector above, I have not been able to find any footnotes in the VET data indicating that they will not be able to use their caps if they are suspended from enrolling new students. Often when the AAT hears an appeals the provider is granted a stay of the ASQA sanction, subject to them not enrolling new students. This information used to be included by ASQA on their website, it should now be included on the national training database (www.training.gov.au) but this does not always appears to be the case on every provider record). The providers which the national database shows have current appeals underway in the AAT to cancel, suspend or not renew their registration as an RTO, and have been given caps for 2025 are:

Here’s the list of the public universities and how their 2025 caps sit alongside their 2019 new international student enrolments (pre-pandemic), their 2023 new enrolments (post-pandemic) and their estimated 2024 new enrolments. It highlights the very different experiences of different universities this year as Ministerial Direction (MD) 106 and MD 107 took effect – prioritising processing student visa applications for low-immigration risk institutions and putting more scrutiny on visa applications for students from higher risk countries through the new Genuine Student test.

I have also analysed the VET and private university and non-university higher education provider (NUHEP) caps.

There is data available on 957 VET providers and I do not intend to reproduce my analysis here.  Instead I am including the details of the VET providers with the 2025 caps which are the highest relative to their CRICOS cap.

I am also including the details for all of the 155 private universities and NUHEPs. The impact the caps will have on different NUHEPs will be more evident when the providers are analysed according to ownership (eg some entities own multiple providers) and when the VET and higher education caps are considered for dual-sector providers (public and private). My intent is to post this additional analysis later this week…