EDUCATION Independent Schools Adobestock 234479909 LR

Working with pupil recruitment agents: new requirement to comply with the 'Agent Quality Framework'

07 Jul 2025

Home Office guidance for sponsors is to be updated on 1 September, requiring holders of student sponsor licences who use agents to recruit international students to be signed up to the Agent Quality Framework.


Schools will need to familiarise themselves with the Agent Quality Framework, and update their contracts with agents to ensure that they remain compliant with Home Office guidance.

The Agent Quality Framework focuses on four key principles: empowering students to make informed choices, ensuring agents operate professionally, promoting ethical practices, and encouraging transparency. It’s backed by tools like a National Code of Ethical Practice, and good practice guides for both schools and agents, and requires agents to undergo periodic certified training.

Many schools and agents already comply with much of the good practice contained in the Agent Quality Framework. However, to reinforce that good practice, it is anticipated that schools will be required to sign up to the Agent Quality Framework 'Pledge'. That Pledge, in turn, requires schools to impose certain obligations on their agents through schools' agent contracts.

Connected to this is the recent addition of non-mandatory agent fields on the CAS. Completing these fields will become a sponsor duty in the future. However, UKVI recognises that technical work is required before that becomes mandatory, and is working with sector bodies to determine appropriate timescales for implementation.

This is all part of the continued focus of UKVI on the use of student recruitment agents, in order to improve the experience for international students, and maintain the UK’s reputation as a world-class study destination. 


If you need support in updating your agent contracts, or in navigating UKVI compliance in this area more generally, please contact Ed Rimmell in our Commercial Contracts team or Tom Brett-Young in our Immigration team.

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