What Changed in 2025
The Australian education agency sector is now operating under its most significant compliance shift in a decade. Three interconnected changes define the new environment.
The Education Legislation Amendment (Integrity and Other Measures) Act 2025, passed 28 November 2025, sharpens the statutory definition of "education agent" and "agent commission," extends fit-and-proper person tests to more categories of agent, and explicitly empowers the Department of Education to collect and publish commission data. Commission reporting is no longer a best-practice recommendation - it is a mandatory obligation.
Ministerial Directions 107 and 111 reshaped the student visa landscape before the Act, with MD107 introducing risk-based prioritisation that significantly reduced offshore ELICOS visa grants. Agencies relying on high offshore volumes experienced material enrolment contraction through 2024 and into 2025. The commission records that survive this period are the ones that will matter to auditors.
The National Code amendment banning commissions on onshore student transfers takes effect 31 March 2026. Agencies that operated onshore transfer pipelines need clear, dated records demonstrating when commission-eligible activity ceased and when it did not.
Taken together: the record your agency kept in a spreadsheet is no longer a sufficient audit artefact. The record a regulator expects is timestamped, role-scoped, and exportable on demand.
Sources: Department of Education - ESOS framework · Federal Register of Legislation
What Auditable Commission Records Look Like
There is no prescriptive format mandated by the Act, but the kind of commission records that withstand scrutiny share common characteristics. Based on the obligations created by the 2025 Act and standard ATO expectations for GST-registered entities:
- Timestamped status transitions - every invoice should record when it moved from created to sent to approved to paid, and who performed each action
- Role-scoped access - commission data should be accessible only to the roles that require it; a subagent should not be able to view the agency's commission rate or another subagent's records
- Immutable history - paid invoices should not be editable; the record of what was invoiced, what was paid, and when must not be alterable after the fact
- Exportable audit trail - the full commission history should be exportable in a standard format (PDF, CSV, or Excel) without manual assembly
- GST treatment explicit on every invoice - offshore vs onshore classification must be clear, and the GST-free or GST-inclusive treatment must be visible on the face of each document
- Data residency in Australia - for agencies with any concern about data sovereignty, commission records should be stored on Australian infrastructure
None of the above requires a specialist compliance tool. But a general invoicing tool not built for the commission chain will require manual workarounds for most of them.
How EduBill Handles Each Requirement
| Requirement | How EduBill handles it |
|---|---|
| Timestamped commission history | Every invoice status transition is written to an append-only audit log with timestamp, user, and action. The log cannot be modified by any user role, including AgentAdmin. |
| Role-scoped access to commission data | Row-Level Security is enforced at the database layer, not in the UI. Subagents can query only their own commission records - the agency's commission rate and course fees are outside their data scope entirely. |
| Immutable invoice history | Paid invoices cannot be edited or reversed. Status transitions are unidirectional: Created → Sent → Approved → Paid. There is no backward transition available to any role. |
| Exportable audit trail | Commission history exports as PDF, Excel, or CSV from the reporting view. No manual assembly required. |
| GST treatment on every invoice | Each invoice carries explicit GST treatment. Offshore student commissions are marked GST-free. Onshore commissions (where applicable before 31 March 2026) are marked GST-inclusive. |
| Subagent confidentiality | Subagent commission invoices never include the course fee or the agency's commission rate. This is enforced at the data layer - the subagent's account cannot query those fields. |
| Data residency | All data is stored in Supabase ap-southeast-2 - the AWS Sydney region. No data leaves Australia. |
GST Treatment
Australia's GST rules treat education agent commissions differently depending on where the student is located at the time the supply is made.
Commissions earned for enrolling offshore students - students who are outside Australia when the agency service is supplied - are GST-free under the exported services provisions of the GST Act. The invoice to the school does not include GST, and the agency does not collect or remit GST on that commission.
Commissions earned for enrolling onshore students - students already in Australia at the time of supply - are standard-rated supplies that attract 10% GST. The invoice to the school includes GST, which the school pays and the agency remits to the ATO.
Subagent commissions paid by the agency carry 10% GST by default. The GST paid to subagents is an input tax credit for the agency, offsetting the GST collected from schools. EduBill calculates the net GST position across both sides automatically.
From 31 March 2026, the National Code amendment removes the ability to earn commission on onshore student transfers entirely. This does not affect commissions on new onshore enrolments where that activity remains permitted.
EduBill applies GST treatment at the invoice boundary. If you are uncertain how a specific commission arrangement should be classified, seek advice from a registered tax agent.
Data Residency and Security
| Data location | Supabase ap-southeast-2 - AWS Sydney region. All commission records, student data, and invoice history stored in Australia. |
| Access control | Row-Level Security enforced at the PostgreSQL layer. No cross-organisation data visibility is possible - each agency's data is isolated at the database level. |
| Encryption | Encrypted in transit (TLS) and at rest. |
| Backups | Daily automated backups via Supabase. Point-in-time recovery available. |
| Multi-tenancy | Each agency is a separate tenant. SuperAdmin access is platform-level only and cannot view individual agency commission or student data. |