FOI_25-270 Education agent commission clauses

Date of response: 06 October 2025

We have now considered your request of 13 September 2025 for the following information:

Question 1. The current UEA policy, guidance, or contract clauses that govern education agent commission where a student changes their recruiter mid-application (i.e., after an initial application is submitted but before CAS issuance/enrolment).

Our response:

The current UEA International Student Recruitment Agreement does not include specific reference to students changing agent/recruiter mid-application. However, when processing commission claims the following Agreement clauses would be applicable in such cases:

• Proof that the Agency claiming commission counselled and/or supported and advised the student to study at the University

• In cases where the student already has an offer at the point that the Agency starts to provide support, and the Agency assists with the visa application and/or any other subsequent and additional support, a maximum of £[redacted] may be paid in commission as a standalone payment. Assistance under these circumstances can, but is not limited to, include help with the visa application process and any further assistance reasonably required by the University or the student for the student to successfully register for a course at the University. The Agency will provide all details and evidence as requested by the University.

• In the case of any dispute over commission payments (e.g., where more than one agent claims for the same student), the situation will be examined by the University on a case-by-case basis. In the event that there is a legitimate claim by more than one agent, commission may be divided at the discretion of the University. In all cases the University reserves the right to make the final decision.

On the occasion that an applicant contacts the University to advise that they wish to change their agent mid-way through the application process, and they do not provide sufficient information to evidence their reason for changing agent, they are asked to complete an Agent Change Authorisation form (attached) issued by the UEA Global team. Students are required to complete the form and return it to agents@uea.ac.uk from their personal email account. The University will not accept an agent change request received from an agency unless it is clear that they are acting on the student’s behalf (for example the student has been cc’d into their email request or there is evidence of communication between the student and agent pertaining to the change of agent request) and/or the University has received express consent from the student. Internal records are kept of all agents that have been linked to an applicant/application with evidence of communications/timelines relating to change of agent requests.

Internal guidance notes relating to the Change of Agent Process state the following:

“On occasion students may wish to transfer from one agency to another. Should these cases arise we follow a set process and converse with all parties involved where possible.

A change of agent form is essential unless we have already been provided with all essential information.

This information is then passed to the relevant recruitment member of staff for review and a decision to take place. Usually, one of four decisions will be made:

• Full commission to one agent

• Commission split between two agencies

• Commission paid to original agent with visa assistance to new agent

• Visa assistance only - Where an agent is appointed for the first time late in the applicant journey”

Question 2. Any standard operating procedures or agent handbook sections that define:
a) how application ownership is determined for commission purposes,

Our response:

Clause from current UEA International Student Recruitment Agreement:

“Commission will be subject to the following:

• The Agency will send a list of students who they have referred to the University within eight weeks of the course start date, allowing for the University census to be completed. Commission claims received after this deadline will be paid at the University’s discretion. A list of students should be sent to agents@uea.ac.uk. The International Office at the University will make checks and inform the Agency which of the students have registered at which point the Agency will send a detailed invoice.

• Proof that the Agency claiming commission counselled and/or supported and advised the student to study at the University from the commencement of the application process. This should be indicated on the online form for postgraduate applications. For undergraduates this can be indicated to the University if the application has been made through the Agency’s registered UCAS centre ID or through a specific notification to agents@uea.ac.uk. For the avoidance of doubt, student attendance at an agency fair is not by itself a qualifying criterion for commission.”

Commission will only be paid where there is clear evidence of a link between the agent and the applicant (in the addition to the above, see also response to Question 1).

b) whether split commission is applied, including any flat-fee amounts (e.g., a reduced flat commission for the final/tagged recruiter) and the residual amount payable to the original recruiter,

Our response:

Clauses from current UEA International Student Recruitment Agreement:

c) any exceptions where the initial recruiter is not paid (e.g., upon a written student request or compliance concerns).

Our response:

Clauses from current UEA International Student Recruitment Agreement:

• Poaching of students from competitor organisations is strictly forbidden as a contravention of Standard 2.3 of the BUILA National Code. If the Agency is, or any of its Agents are, suspected of engaging in poaching behaviours, commission payments and refunds will be suspended until an investigation is complete.

• No commission will be payable to the Agency by the University for any students registering for any course commencing after the end of the second Academic Year

• No commission shall be payable for any student who withdraws from the University within their first semester. The Agency shall repay to the University, on demand, any commission paid to them with respect to any such student.

All commission claims are dealt with on a case-by-case basis. Should a student expressly ask that an agent be removed from their record in its entirety then this would be noted and actioned on UEA admissions systems. Should an agency later claim commission for the student, the case would be referred to and senior staff within the UEA Global team for a final decision on whether or not commission can be paid.