Where is the bar set on sub-agent due diligence?

In January 2023 we published what has since become one of our most read posts, Into temptation: the rise of education agent aggregators and sub-agent risk. A key point was the importance of educational institutions holding aggregators to account on the professionalism of their sub-agent networks, which commonly number in the thousands. This requires an institution to look past the standard aggregator marketing pitch that their sub-agents are ‘vetted’, ‘carefully checked’ or ‘trusted’, and ask what due diligence and assurance measures the aggregator has in place to ensure that sub-agents act professionally and honestly. The post suggested five questions as a framework to support the accountability discussion between an institution and an agent aggregator that it is working with.

Since the post was published the risks associated with unprofessional and dishonest agent education agents have continued to challenge the international education sector, particularly in Canada and Australia. Governments in both countries are considering regulatory options.

Against this backdrop, ApplyBoard – one of the biggest education agent aggregators in the business – appears to have made a concerted effort to strengthen its sub-agent due diligence process and, importantly, to be transparent on exactly how it goes about it. Information published on the company’s website, sets out a multi-faceted approach to sub-agent due diligence, including an initial vetting process and ongoing due diligence. ApplyBoard has also published a ‘Recruitment Partner Blocklist‘, which it describes as a list 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.” ApplyBoard has created video content explaining the approach:

ApplyBoard’s move to better process and increased transparency around its sub-agent due diligence process is positive, but questions remain. The main issue goes to policy vs implementation. High minded policies and well produced videos are one thing but they don’t count for much if they are not backed by diligent implementation. And implementation requires a commitment of financial and human resources. In ApplyBoard’s case that commitment is significant given that it must apply its multi-layered due diligence approach to its network of over 10,000 sub-agents. Perhaps ApplyBoard is well positioned to apply and sustain the required effort given its scale and financial resources. Time will tell.

If ApplyBoard has set the bar for sub-agent due diligence – at least on paper – several questions follow. What does it mean for other agent aggregators who lack ApplyBoard’s resources? More importantly, what does it mean for educational institutions who are working with those aggregators? Should an institution work with an aggregator if its approach to sub-agent due diligence involves fewer controls than what ApplyBoard has come up with? If so, what is the minimum standard? If another aggregator purports to match or exceed ApplyBoard’s approach, how confident can an institution be that the stated policy and process is actually implemented in practice, noting that even the smaller aggregators have sub-agent networks numbering in the thousands?

Each of those questions should inform consideration by an institution of the utility both of working with agent aggregators generally, and also of whether or not to work with a particular agent aggregator. All aggregators will promise increased global exposure and international student enrollments, and often they will deliver. Those benefits should be weighed against the risks that come with the aggregator business model that relies on thousands of referring sub-agents in an international education market where misconduct by education agents – and the consequent victimisation of students and their families – remains too frequent.

Working with education education agents?

AgentBee’s education agent due diligence solution supports educational institutions to implement best practice education agent due diligence processes.

Educational institutions can use it to:

protect students – conduct initial and ongoing due diligence checks on education agents.
protect your brand – detect cases of unauthorised agents using your institution’s name, logo or other IP without permission.