12/11/2025
We would like to inform you of an important policy update regarding Australiaโs Ministerial Direction 115 (MD115), which will be effective from 14 November 2025.
Australia has introduced Ministerial Direction 115 (MD115), a new policy that significantly changes how offshore Subclass 500 (Student) visas are processed. This direction is part of the governmentโs broader โmanaged growthโ strategy, designed to ensure sustainable, high-quality and fair international education across the country.
Key Features of MD115
1. Annual Allocations for Providers
Each Australian education provider is assigned an โindicative annual allocationโ โ the recommended number of new international students they can enrol in a year, called New Overseas Student Commencements (NOSCs).
Providers staying below 80% of their allocation have fast visa processing.
Providers between 80%โ115% of their allocation receive moderate processing.
Providers exceeding 115% will fall into Priority 3, meaning longer visa processing times (8โ12+ weeks).
2. Managed Growth Approach
The government aims to balance student distribution across both metropolitan and regional institutions.
Over-enrolment or high-risk providers are discouraged through slower processing.
Providers following compliance, integrity, and capacity guidelines are rewarded with faster visa processing.
3. Priority Levels for Visa Processing
Priority 1 (Fastest, 1โ4 weeks): Providers under 80% allocation
Priority 2 (Medium, 5โ8 weeks): Providers 80โ115% allocation
Priority 3 (Slowest, 8โ12+ weeks): Providers over 115% allocation
Implications for Students
Visa delays can impact travel plans, accommodation, orientation and course start dates.
Students applying to over-capacity providers may face 2โ3 month delays, affecting preparation and finances.
Early application planning and advising students about potential delays are now critical for smooth study abroad preparation.
Implications for Education Providers
Slower processing complicates student enrollment management.
Providers exceeding capacity risk losing students to other institutions or causing deferrals.
Maintaining accurate documentation, integrity and compliance is now mandatory.
Action Steps for ECAN Members โ MD115 Compliance and Best Practices
1. Check Provider Allocations Carefully
Verify the indicative annual allocation (NOSC) of every education provider before submitting student applications.
Understand whether the provider is under, near, or over their allocation to anticipate processing priority.
2. Inform Students Transparently About Potential Delays
Advise students that visa processing times may vary depending on the providerโs allocation and compliance status.
Ensure students understand that delays are outside the control of the consultant and may affect travel and course start dates.
3. Submit Complete and Accurate Documentation
Ensure all student applications include correct and complete information to avoid unnecessary delays or visa refusals.
Double-check enrolment letters, financial proofs and academic records before submission.
4. Partner Only with Compliant Providers
Work with providers who adhere to Australian regulations, maintain high integrity and have a proven record of responsible student enrolment management.
Avoid providers with a history of over-enrolment, fraud, or visa refusals.
5. Avoid Promising Fast Visa Outcomes
Emphasize that visa processing speed depends on allocation limits, compliance and government priorities.
Do not give students unrealistic guarantees, as this could damage your credibility.
6. Monitor Allocation Changes Throughout the Year
Some providersโ allocations may change; stay updated to provide accurate guidance to students.
Use the PRISMS system or official provider notifications to track allocation and capacity changes.
7. Focus on Genuine Students
Prioritize students with strong academic records, complete financial documentation and a clear study plan.
Avoid assisting students with incomplete or questionable documentation that could jeopardize their visa approval.
8. Plan Applications in Advance
Encourage early applications to avoid delays, especially for providers approaching or exceeding their allocation limits.
Early submission allows students more time for travel, orientation and settling in.
9. Maintain Professional Records and Communication
Keep clear records of all student communications, application documents and provider allocations.
Transparent documentation ensures accountability and protects your consultancy from disputes or complaints.
10. Educate Students About the โSoft Capโ System
Explain that MD115 uses processing speed as a soft cap, not a limit on visa numbers.
Help students understand why providers under capacity get faster processing and why exceeding allocations can slow visa approval.
Bigger Picture: Soft Caps and Compliance
MD115, together with the 2026 National Planning Level (NPL), introduces a soft-cap system.
The total number of visas is not limited, but processing speed is used to encourage responsible enrollment management.
Providers following rules are rewarded, while non-compliant or over-capacity providers face slower visa processing.
This system ensures quality, fairness and sustainability in Australian international education.
Summary for ECAN Members
MD115 affects all offshore Subclass 500 visa applications starting 14 November 2025.
Compliance with provider allocations, integrity and documentation is now more important than ever.
The Australian Government will introduce a new ministerial direction to strengthen and balance distribution of international students across education providers in regional and metropolitan locations. Throughout 2025 we have seen the positive effect of a managed growth approach across the sector - r...
