Visa Processing Eases Under MD 111 – VET Providers Still Left Behind

What’s Happening?

Australia’s new student visa directive, Ministerial Direction 111 (MD 111), is being seen as an improvement in visa processing stability compared to last year. However, the Vocational Education and Training (VET) sector is struggling to keep pace with higher education institutions.

Background: MD 111 Replaces MD 107

• MD 107 (old directive) was unpredictable and arbitrary in decision-making.
• MD 111 (new directive, introduced in Dec 2024)prioritises visa processing for providers up to 80% of their cap allocation (NOSC – Net Overseas Student Commencements).
• This system gives universities and higher education providers more predictable outcomes.

Positive Impact on Higher Education

• Processing times have improved and are back to pre-2023 levels.
• Many universities now report more consistent approvals.
• Regional universities (e.g., Charles Sturt University) see this as a big improvement over last year.

VET Sector Left Behind

• TAFE and VET providers are not fully benefiting from MD 111.
• Demand from countries like India for TAFE has “almost gone away.”
• Data (as of August 1, 2025):
  • Higher Education NOSCs: 83% of target.
  • VET NOSCs: only 60% of target.
  • Pipeline numbers show higher education at 105%, VET at 79%.

Visa Refusals Still a Concern

• Stakeholders report continued high refusal rates.
• Migration agents say refusals often lack “rhyme or reason.”
• VET students especially face misunderstanding about career pathways (e.g., doing a vocational course after a degree).

Upcoming Policy Changes

• New ESOS legislation expected soon.
• Will not include the hard student caps (blocked in 2024).
• Could include a ban on onshore agent commissions to prevent “course-hopping.”

Concerns Over Agent Commission Ban

• Many argue an outright ban could hurt students and regional universities.
• Onshore agents often help students relocate from big cities to regional areas, boosting diversity and opportunities.
• Fears that banning commissions may push some providers to offer unofficial rewards instead.

Key Takeaway

• MD 111 brings stability to visa processing for universities.
• VET sector continues to lag, with weaker enrolments and lower approvals.
• High refusal rates remain an unresolved issue.
• Future policy on agent commissions could create new challenges if not carefully managed.

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