ISANA’s Response to MD111: Call for Transparency, Fairness, and Collaboration

ISANA welcomes efforts to bring transparency and structure to student visa processing through Ministerial Direction 111 (MD111). However, we acknowledge that the implementation has raised significant concerns among education providers, students, and other sector stakeholders.

Key Issues & Concerns:

  1. Clarity & Transparency – The sector requires clearer guidelines on the calculation of the 80% threshold and the New Overseas Student Commencements (NOSC) allocations. Many providers are struggling to understand how these numbers are determined and applied. We urge the government to engage in open and meaningful discussions with all education providers to ensure fairness in the allocation process.
  2. Unintended Consequences on Student Choice & Recruitment – The prioritization system may create imbalances between institutions, with students potentially choosing providers based on visa processing speeds rather than academic fit or career aspirations. This could disrupt strategic planning for institutions and complicate international recruitment.
  3. Impact on Brand Australia & Student Confidence – Frequent policy shifts and visa uncertainties are damaging Australia’s reputation as a stable and welcoming destination for international students. We encourage the government to provide long-term policy certainty to rebuild confidence among students, education providers, and recruitment partners.
  4. Onshore Visa Processing & Student Welfare – Delays in onshore visa processing remain a pressing concern. Some students have been waiting extended periods on bridging visas, which creates financial and emotional stress. ISANA urges the government to ensure timely processing for onshore applicants and prioritize student welfare.

A Call for Collaboration:
ISANA calls on the government to work closely with the education sector to address these challenges. We support any measures that enhance the integrity of Australia’s international education system while ensuring fairness, transparency, and a positive student experience.

We look forward to ongoing dialogue with policymakers to refine MD111 in a way that supports both education providers and international students, who are vital to Australia’s economic and cultural fabric.