CoE creation in PRISMS in 2026: what agents must never do

A CoE can only be created in PRISMS by the registered provider — the education provider registered on CRICOS to deliver that course at that location. Under the National Code of Practice for Providers of Education and Training for Overseas Students 2018, as published on the Federal Register of Legislation and checked as at September 2026, a Confirmation of Enrolment is "a document, provided electronically, which is issued by the registered provider," and PRISMS is "the system used to process information given to the Secretary of DET by registered providers." An agent's role sits upstream of both: the Code defines recruitment as the pre-enrolment work of engaging and assisting a student to apply for a place, expressly including "assistance with administrative issues and the issuing of a CoE for an application for a student visa." Assisting is not issuing. The line an agent must never cross is creating the PRISMS record, or getting a provider to create one that does not match a real acceptance.

What follows is general information about how these obligations are allocated, not advice on any individual enrolment or visa case; anyone dealing with a specific CoE or PRISMS problem should work from the official text and from qualified professional advice.

Who is actually allowed to create a CoE in PRISMS?

The registered provider, and only the registered provider for that course at that location. The Code defines a registered provider by reference to section 5 of the ESOS Act: a provider registered to provide the course at the location. CRICOS — the Commonwealth Register of Institutions and Courses for Overseas Students — is the register prescribed under section 14A of that Act. Registration on CRICOS is what gives a provider standing to issue a CoE, because the CoE is the provider's own confirmation that a particular student is eligible to enrol in a particular course of that provider.

A migration agent is defined separately, as a person registered as a migration agent under section 286 of the Migration Act 1958. That registration governs immigration assistance; it does not confer access to PRISMS. PRISMS, on the Code's own definition, processes information given by registered providers. Nothing in the Code makes an agent a user of it. So when an agency is handed a provider's PRISMS login, or is asked to "just generate the CoE" because the provider is busy, the request is asking the agent to perform an act the National Code assigns to the registered provider — and the record created is one the provider will be answerable for.

What does a CoE actually confirm?

It confirms "the overseas student's eligibility to enrol in the particular course of the registered provider," and it "must accompany their application for a student visa." Two things follow from that wording. The confirmation is course-specific, not provider-specific: it attaches to a particular CRICOS course, not to a general relationship with a school or college. And it is the document the visa application rests on, which means its accuracy is not a private matter between the agent and the provider.

This is why a CoE created for a student who has not actually been accepted into that particular course is not a paperwork shortcut. Where there is no acceptance to confirm, the electronic document ceases to be a confirmation of anything, and the provider has told the Commonwealth something about its own enrolment that is not true. An agent who recruits the student and then asks for the CoE anyway is the person who created the demand for that record.

Where exactly is the line between assisting and creating?

Step in the chain	Who the National Code assigns it to	What an agent must never do
Confirming eligibility to enrol in the particular course	The registered provider, which issues the CoE electronically	Ask for a CoE for a student the provider has not accepted into that course
Entering the record in PRISMS	Registered providers, whose information PRISMS processes for the Secretary of DET	Use a provider's PRISMS access or credentials to create a CoE
Setting the course duration on the CoE	The provider, which must issue the CoE only for the reduced duration where credit shortens the course	Request the pre-credit duration so the student's covered period looks longer
Recording a transfer release	The releasing provider, which records the date of effect and the reason in PRISMS	Treat a CoE or any other PRISMS entry as a release the releasing provider has not recorded
Finalising a refused transfer	The provider, and only after the appeal outcome, the 20-working-day window, or withdrawal	Push for refusal status to be finalised while an appeal is still live

Can an agent ask for a longer CoE when course credit shortens the course?

No. Standard 2 requires the provider to have and implement a documented policy and process for assessing whether a student's English language proficiency, educational qualifications or work experience are sufficient to enter the course, and — if it grants recognition of prior learning or course credit — a documented policy for assessing and recording that decision. Where credit is granted and it "reduces the overseas student's course length," the provider must inform the student of the reduced duration and "ensure the confirmation of enrolment (CoE) is issued only for the reduced duration of the course." If the credit is granted after the visa is granted, the provider must also report the change in course duration in PRISMS.

Suppose a recruited student is granted credit that shortens the enrolled course. The CoE has to reflect the shortened course, not the course as originally marketed. An agent who asks for the original duration is asking the provider to enter a course length in PRISMS that the student will not be studying, and the post-visa reporting obligation means the discrepancy is one the provider is separately required to disclose.

Can PRISMS be used to block, or to force, a transfer?

PRISMS records the decision; it does not replace it. Standard 7 provides that a registered provider must not knowingly enrol an overseas student seeking to transfer from another provider's course before the student has completed six months of their principal course — or, in the school sector, the first six months of the first registered school sector course — unless an exception applies. Those exceptions are: the releasing provider or the course has ceased to be registered; the releasing provider has had a sanction imposed on its registration by the ESOS agency that prevents the student from continuing; the releasing provider has agreed to the release and recorded the date of effect and the reason in PRISMS; or the student's government sponsor considers the change to be in the student's best interests and has provided written support.

The third exception is the one agents most often mishandle. A release exists when the releasing provider has agreed to it and recorded the date of effect and reason in PRISMS. A CoE from the receiving provider is not that record. Creating a receiving-side CoE before the releasing provider has recorded the release puts the receiving provider in the position Standard 7 prohibits.

The timing rules run the other way too. If a provider intends to refuse a transfer request, it must inform the student in writing of the reasons and of the right to access its complaints and appeals process within 20 working days. It must not finalise the student's refusal status in PRISMS until the appeal finds in favour of the provider, the student has chosen not to access the complaints and appeals process within that 20-working-day period, or the student withdraws from the process. Any release that is granted must be at no cost to the student. An agent pressing a provider to close out a refusal while an appeal is pending is pressing for a PRISMS step the Standard forbids.

What changed in 2026 that agents should be reading?

The National Code is not frozen at its 2018 text. The compiled instrument was registered on 13 September 2017 (F2017L01182) and commenced on 1 January 2018. It was then amended by the National Code of Practice for Providers of Education and Training to Overseas Students Amendment (Education Agent Commissions) Instrument 2026, registered on 20 January 2026 (F2026L00033) and commencing on 21 January 2026. That instrument added Standard 4.7 and Standard 4.8 and amended the Definitions section.

The instrument's own title signals what it is about — education agent commissions — and it is the clearest reason to treat "we have always done it this way since 2018" as an unsafe answer in 2026. The operative text is the current compilation, including Standards 4.7 and 4.8, and any question about what a provider must do about an agent's conduct has to be read against that compilation rather than against the version that commenced in 2018.

What happens if an agent misleads a student about the course?

It becomes grounds for the student to be released. Under Standard 7, a provider's transfer policy must set out the circumstances in which it will grant a transfer because the transfer is in the student's best interests, and those circumstances expressly include "evidence that the overseas student was misled by the registered provider or an education or migration agent regarding the registered provider or its course and the course is therefore unsuitable to their needs and/or study objectives." The same list covers evidence that the student's reasonable expectations about the current course are not being met.

That list has a direct link back to Standard 2. Before accepting a student for enrolment, the provider must make available comprehensive, current and plain English information on entry requirements and minimum English proficiency, the CRICOS course code and course content, modes of study, course duration and holiday breaks, the qualification or outcome, campus locations and facilities, any arrangements with another provider who will deliver part of the course, indicative tuition and non-tuition fees with advice on the potential for fee changes and the cancellation and refund policies, and the grounds on which enrolment may be deferred, suspended or cancelled. An agent who recruits on claims those disclosures do not support is building the evidentiary basis for a later transfer release — and the provider must keep records of all release requests and its assessment and decision for two years after the student ceases to be an accepted student.

Frequently Asked Questions

Can an education or migration agent create a CoE in PRISMS?

No. A CoE is issued electronically by the registered provider, and PRISMS is the system used to process information given to the Secretary of DET by registered providers. An agent's recognised role is recruitment — assisting a student up to formal enrolment, including assistance with issuing a CoE — which is not the same as creating the record.

Is a CoE the same as an offer of a place or a student visa?

No. A CoE is the registered provider's confirmation that the student is eligible to enrol in a particular course, and it is the document that must accompany the student visa application. It is neither the provider's admission decision itself nor any decision on the visa.

Does a CoE have to change if the student is granted course credit?

Yes, where the credit reduces the course length. The provider must inform the student of the reduced duration and ensure the CoE is issued only for the reduced duration; if credit is granted after the visa is granted, the change in course duration must also be reported in PRISMS.

Can a receiving provider rely on a CoE instead of a recorded release?

No. A transfer before the student completes six months of the principal course is permitted, among other exceptions, where the releasing provider has agreed to the release and recorded the date of effect and reason in PRISMS. A CoE issued by the receiving provider is not that record.

When can a provider finalise a student's refusal status in PRISMS?

Only after the appeal finds in favour of the provider, after the student has chosen not to access the complaints and appeals process within the 20-working-day period, or after the student withdraws from the process. Finalising earlier than that is not permitted under Standard 7.

Did the National Code change for agents in 2026?

Yes. An amendment instrument on education agent commissions was registered on 20 January 2026 (F2026L00033) and commenced on 21 January 2026, adding Standard 4.7 and Standard 4.8 and amending the Definitions. The current compilation is the text to read, not the version that commenced on 1 January 2018.

What if a student says an agent misled them about the course?

That is a listed circumstance in which a provider's transfer policy must allow a release because the transfer is in the student's best interests, where the course is unsuitable to the student's needs or study objectives as a result. The same Standard requires a release, once granted, to be at no cost to the student.