The UK Home Office has updated its Student Sponsor Guidance in a way that is directly relevant to UK institutions using education agents. In the April 2026 update to Document 2: Sponsorship Duties, the Home Office amended the existing agent details requirement, added a new section titled “Agents and third parties”, and updated related reporting obligations.
The updated guidance states that sponsors must provide details of any agent or third party, in the UK or overseas, that they have used in the recruitment of a sponsored student. Those details are to be recorded through the CAS process in line with the relevant SMS requirements.
The requirement is not limited to traditional contracted agent arrangements. The guidance states that agent details must still be provided where the recruitment was a one-off or where there was no formal ongoing contract with the relevant party.
The guidance also addresses sub-agent arrangements. It states that where a sub-agent is used the sponsor must provide details of the main agent, not the sub-agent. Sponsors must record the agent used during the recruitment phase and the one to which the sponsor attributes the recruitment, including, for example, the party that would receive commission.
The Home Office also sets out an exception. Sponsors do not need to enter agent details on the CAS where an adviser was engaged directly by the student and was not used by the sponsor as part of the recruitment process.
AQF Compliance
The updated guidance links agent oversight more clearly to sector standards. It states that all student sponsors using recruitment agents must have committed to adhering to the key principles of the Agent Quality Framework. It also states that sponsors must retain evidence showing how they manage agents in line with the AQF and the National Code of Ethical Practice for UK Education Agents, as applicable to their sector.
The British Council states that the AQF applies to UK education providers on the register of licensed Student sponsors that use international student recruitment agents, and describes it as the framework setting out the standards by which those providers are expected to manage agents.
Taken together, the April 2026 update makes the Home Office’s expectations more explicit in three areas: recording agent involvement in student recruitment, identifying the correct party in more complex recruitment arrangements, and retaining evidence of agent oversight in line with the AQF and the National Code.
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