Building Trusted Pathways: Ethical Recruitment Through Agents

For many institutions, education agents have become an established part of international student recruitment. But as governments, institutions, and students call for more transparency and accountability, the conversation around agents is changing in response.

“The question is no longer simply whether institutions use agents,” says Tony Lee, chief visionary officer at ICEF. “The real question is whether those relationships are transparent, well managed, and aligned with student outcomes.”

This shift is playing out against a backdrop of increased scrutiny in several countries. The United Kingdom now requires universities to report information about the agents their applicants work with as part of the Confirmation of Acceptance for Studies (CAS) process, and Australia has introduced increased agent-related reporting requirements. Although the United States has not yet adopted similar regulations, many enrollment management professionals are watching these developments closely.

“The U.S. lags far behind these peer destinations in terms of government-mandated requirements regarding agents,” says Eddie West, assistant vice president for international affairs at California State University-Fresno. “[However,] it’s reasonable to expect this may change in the future.”

As expectations around ethical recruitment continue to evolve, experts say institutions should focus on five key areas for action.

Start with the Right Partners

Ethical recruitment begins long before the first student application arrives, says West. “Ethical recruitment and effective relationships with agencies start with the agent-partner selection process.” Institutions that are just starting to work with agents—or that are expanding existing partnerships—should rely on peer recommendations whenever possible. “We’re fortunate to work in a collegial field, where colleagues at other institutions are often very willing to recommend agents with whom they’ve had positive experiences.”

Sean Gilmore, assistant vice president of global academic partnerships and international student enrollment management at the University of South Florida, agrees. “Check with your colleagues and ask for references from the agency,” he advises. “A good agent should have no problem providing a list of happy partners who can give you honest feedback.”

Institutions should also consider whether they have the internal processes needed to support those partnerships. Gilmore encourages teams to think through the operational implications of working with agents before expanding their network. “How will you track the applications from start through to enrollment?” he asks. “How will you handle invoicing and reconciliation? What does the dispute process look like if two agents claim the same student? How will you provide regular timely feedback on applications to your agent partner? We know we don’t have it quite right yet and are always looking for feedback from our agent partners on how to work together better.”

Another important factor is working with agencies that have participated in recognized training or certification programs. “The question is no longer simply ‘Should institutions use agents?’ but ‘How do we use agents transparently, ethically, and strategically?’” says Cheryl Delk-Le Good, executive director of EnglishUSA. “The latest conversation emphasizes standards, documentation, training, student-centered counseling, and accountability.”

However, she recommends that institutions should be cautious: “Don’t make assumptions that all agents have gone through the vetting, training, [and so on] offered by companies like ICEF [or] StudyTravel,” Delk-Le Good says.

Treat Training as an Ongoing Responsibility

Selecting the right partners is only the beginning. “Training of agents is another must,” says West. “If you want to compete on something more than commission incentives, then it’s important [that] agencies—especially their frontline student advisers—understand your unique value proposition.” In fact, West sees a lack of interest in training as a warning sign: “If a newly onboarded agent doesn’t ask for training, that’s a red flag.”

For Delk-Le Good, institutions that invest in regular communication tend to have the strongest partnerships. “[English language programs] that have regular, consistent training and updates with their agents are most likely to succeed,” she says. Regular updates about program changes, admissions requirements, and policy developments ensure students receive accurate information. “Following up and giving agents the most updated information and being on top of any training [are] key.”

That communication becomes especially important as policies and regulations change. “We need to remember that [agents] are dealing with multiple target markets, just like us,” Delk-Le Good adds.

Measure Quality, Not Just Volume

One of the biggest changes in recent years has been a shift away from viewing agents primarily as enrollment generators. “The biggest shift is that international student recruitment is moving from a high-volume marketplace to a higher-trust marketplace,” Lee says.

For institutions, that shift means they should evaluate agent performance through a broader lens. “Institutions need to review agents by quality, not only by volume,” Lee says. “Are students well matched? Do they understand the program? Are they academically and financially prepared?”

The same principle applies internally. Gilmore worries that some institutions focus too heavily on enrollment growth without considering broader institutional goals. “I worry about how many conversations I’ve [recently] had with colleagues around the U.S. … about budget and revenue streams without the context of a campus globalization plan,” he says. “How will an uptick of international students change the face of your campus? Will some portion of that tuition be reinvested in supporting international students?” The most effective agent strategies, he says, are tied to a larger vision for internationalization rather than enrollment targets alone.

Build Accountability and Feedback Loops

Experts consistently identify accountability as one of the most important elements of ethical recruitment. “The central test is student fit,” Lee says. “Every part of the recruitment chain should be asking the same question: Is this the right student, for the right institution, advised by the right agent, for the right reasons?”

To answer that question, institutions need systems that allow them to monitor outcomes and identify issues early. At the University of South Florida, Gilmore’s team conducts regular check-ins and uses software to monitor application quality and how the university is represented in agent marketing materials and other public communications.

West encourages institutions to gather feedback directly from students. “Talk to your students about their experiences working with an agent and at their destination university,” he says. “In a win-win, truly student-centered partnership, stakeholders will make the time to solicit input—whether good or bad.”

These feedback loops not only improve student experience but also help institutions make course corrections when needed.

Prioritize Transparency

In conversations with experts, it’s clear that for recruitment to be effective, it must be ethical—and ethical recruitment depends on transparency. “Trust can no longer simply be claimed; it has to be demonstrated,” Lee says. To satisfy this need, institutions must maintain accurate public agent lists, document training activities, track performance, and ensure they know exactly who is representing them in market.

West is particularly concerned about accountability within some aggregator models. “Accountability and anonymity rarely go hand in hand,” he says. “Some agent aggregators conceal their sub-agent networks. What good is it to publish an agent aggregator as a recruitment partner on a university website if the vast, unaccountable sub-agent network that is the actual engine of that network is shrouded in secrecy?”

Lee offers a simple test for institutions evaluating their current practices: “If a regulator, journalist, student, parent, or senior leader asked tomorrow how agents are selected, trained, listed, reviewed, and removed, could the institution answer clearly and [provide evidence for] the answer?” If not, he says, that is a warning sign.

Ultimately, experts agree that agent-based recruitment has entered a new era, one defined less by numbers-focused goals and more by investment in relationships and qualitative markers. “The next phase of international education will not be defined by who can recruit the most students,” Lee says. “It will be defined by who can build the most trusted pathways.” •