In August 2023 ApplyBoard publicly announced its ‘Recruitment Partner Blocklist’ in the context of an article on its website setting out its approach to monitoring and managing its recruitment partner network. An article in The PIE described the move as ‘unprecedented’, and in the same article AgentBee welcomed the initiative. ApplyBoard’s website explained that the the creation and publication of the blocklist had two related aims. First to “mitigate the impact of bad actors on the sector“, and second to “ensure trust and transparency in the international education sector“. Over two years on, have those aims been achieved?
What is the Blocklist?
The blocklist page on ApplyBoard’s website states:
The below list consists of recruitment agents who are either no longer part of the ApplyBoard network and/or have been pre-emptively blocked from accessing the platform due to known infractions that were published publicly and/or submitted by a partner institution.
There is a quite bit going on in that sentence, and the potential reputational and business impacts for a listed agent are serious, so precision and clarity are important. Let’s break it down.
(i) Association with ApplyBoard
As it stands, the listed agents are either:
- “agents who are no longer part of the ApplyBoard network” – presumably this means that they were kicked out as a result of the infraction – and/or
- “agents who ApplyBoard has pre-emptively blocked from accessing the platform” – i.e. this could be any agent, whether or not it was ever associated with ApplyBoard.
(ii) What kind of conduct qualifies an agent for listing?
The first threshold for listing is that an agent must be responsible for ‘known infractions’. According to the website, an ‘infraction’ appears to consist of a breach by an agent of “their contractual obligations or our Code of Business Conduct and Ethics”.
(iii) How were the ‘infractions’ detected’
The second threshold for listing is that the ‘known infractions’ must have been:
- published publicly, and/or
- submitted by a partner institution.
This raises an obvious question: what about agent misconduct that ApplyBoard identifies through its own due diligence processes? On the face of it agents in that category would not be listed. A separate page on ApplyBoard’s website clears this up, advising that “in the event that a recruitment partner’s contract is terminated with ApplyBoard on compliance grounds, they are placed on a blocklist.”
The list – who’s on it?
When the blocklist was first published in August 2023 it listed 44 agents. One agent, Nilesh Pandya of Airway Holiday Private Limited, was listed twice, but we have only counted them once. In April 2026, 46 agents were listed. Airway Holiday Private Limited is still listed twice, but again, was only counted once.
The AgentBee team has checked the blocklist regularly since it was published. The image inside the frame below is the blocklist as at 1 April 2026 (click on it to enlarge). We’ve highlighted the additions in green and the added the agents removed in red on the right.
(Click image to enlarge it)
In summary, since publication:
- Four agents have been added to the list.
- Three agents have been removed.
| Added | |
| Tafne Overseas Education | – around July 2024 |
| KumarDirect Pty Ltd | – around July 2024 |
| Divine Hub Education | – around July 2025 |
| Dream International Recruiting Company | – around July 2025 |
| Removed | |
| Emsa Education and Migration Services | – late 2023 |
| Eforbia | – late 2023 |
| Riguna Solutions Private Limited | – late 2023 |
Why so few additions?
It is surprising that ApplyBoard has added only four agents to the list in two and a half years. On face value it means that in ApplyBoard’s judgement only four agents have met the criteria for entry onto the blocklist set out earlier. What could that mean in practice?
Let’s assume that all four agents were previously AgentBee recruitment partners who were expelled for ‘known infractions’. When the blocklist was launched in August 2023, ApplyBoard reported a network of 10,000 sub-agents (aka ‘Recruitment Partners’). That number dropped to 6,500 in early 2024, and in January 2026 it stood at 5,000.
In early 2024, following the reported drop from 10,000 sub-agents to 6,500, we asked ApplyBoard about the link between the decrease in Recruitment Partners and the Blocklist, noting that there had been no agents added to the blocklist (see ApplyBoard cuts 3,500 ‘Recruitment Partners’). An ApplyBoard spokesperson said:
The RP Blocklist is made up of those RPs that have been blocked from accessing the ApplyBoard platform due to malfeasance that would violate our Terms and Conditions that would meet our standards to block them from the platform, and also includes those agents who have never had access to the ApplyBoard platform but have been credibly reported in the media as to have shown unethical recruitment practices that would meet our standards for blocking.
The decrease in our recruitment partner numbers and the blocklist are not related. Some RPs no longer are in the business and some we have simply parted ways with. This does not mean any of them have violated our Terms and Conditions or our ethical standards that would result in the RP being blocked from accessing the platform.
Putting this all together, it seems that when ApplyBoard reduced its sub-agent network from 10,000 to 6,500 in 2023-24, the number of sub-agents expelled for misconduct was zero. That is remarkable.
Let’s stay with the assumption that all four agents added to the list since its publication were previously AgentBee recruitment partners who were expelled for ‘known infractions’. It follows from ApplyBoard’s advice that they must have have been included in the 6,500 sub-agents reported by ApplyBoard in early 2024. Using 6,500 as the baseline, it means that just 0.06% of ApplyBoard’s sub-agents have been expelled from its network for misconduct since early 2024.
However in answer to a question for this article about the relationship between the reduction in sub-agent numbers and the blocklist, ApplyBoard confirmed its position:
We are highly selective about who we work with. The reduction in partner numbers is a reflection of our strict standards regarding application quality and conversion rates. We regularly choose not to work with agencies that do not meet these standards, which is entirely separate from the blocklist.
That means that when ApplyBoard reduced its sub-agent network from 10,000 to 5,000 over a period of several years, quite possibly not one of those agents was expelled for misconduct. Again, remarkable.
Noting ApplyBoard’s advice, let’s make an alternative assumption – that all four agents added were “pre-emptively blocked from accessing the platform” for ‘known infractions’ of ApplyBoard’s Code of Conduct and Business Ethics. As ApplyBoard explained to us in early 2024, this “includes those agents who have never had access to the ApplyBoard platform but have been credibly reported in the media as to have shown unethical recruitment practices that would meet our standards for blocking.”
When drafting this post we asked ApplyBoard if it believed that four additions to the blocklist in two and a half years accurately reflects the level of agent misconduct in the market over that period. In reply a spokesperson said:
The published blocklist is just one public-facing element of our broader vetting process. We reject approximately 40% of prospective agents right from the start. We simply do not work with those that don’t meet our expectations, filtering them out before they ever gain access to our platform.
The question remains: when considering the the ‘pre-emptive blocking’ ground for listing is ApplyBoard really only aware of four matters in two and a half years that meet that ground for listing?
The strange case of EMSA Education and Migration Services
Reporting for The PIE on the launch of the blocklist in September 2023, Nicholas Cuthbert noted:
Included in the blocklist is Brijesh Mishra from agency emsa, who was arrested in Canada after allegedly scamming over 700 students by giving them fake admissions letters.
Originally the website stated that “the [blocklist] list includes all former recruitment partners who are no longer part of our network. Applyboard has fully removed their access to the platform.”
However ApplyBoard have since amended the website and clarified to The PIE saying “our published blocklist is made up of agents and agencies who may or may not have worked with ApplyBoard.
“Brijesh Mishra, nor any agency he worked with, was ever part of the ApplyBoard platform.”
The listing for Mishra was removed some time between mid September and early December 2023. Mishra was sentenced to three years in prison in Canada for his offences. Clearly he meets ApplyBoard’s listing criteria of having committed a ‘ ‘known infractions’ of its Code of Conduct and Business Ethics. In response to our question as to why Mishra was removed, ApplyBoard said:
We do not comment publicly on the specifics of individual administrative updates. Our compliance team manages all updates to the list based on ongoing internal reviews.
Mission accomplished?
The discussion above raises the question as to whether the blocklist has achieved the goals it stated at launch — namely, to “mitigate the impact of bad actors on the sector” and to “ensure trust and transparency in the international education sector”. We put that question to ApplyBoard, who advised:
Yes. The blocklist serves as an important tool for transparency. It highlights individuals or entities that have engaged in severe misconduct, often based on information provided directly by our partner institutions, public cases, or the news. It is one of many ways we help protect the sector.
Blocklist – what’s next
We asked ApplyBoard a number of questions when drafting this post, and they provided a very prompt response on 1 April. In addition they advised that “they anticipate having our blocklist updated later this week”.
Sources: The PIE, ApplyBoard
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