Standard 7 has changed: what does 12 months mean in practice?

From 2 October 2026, the transfer restriction period under Standard 7 of the National Code increased from six months to 12 months for most overseas students.

The change is temporary. It applies until 30 June 2027, with the restriction due to revert to six months from 1 July 2027. School students remain subject to the existing six-month restriction.

The change is part of a broader package of student visa integrity reforms and is intended as a transition measure ahead of a new Student visa transfer stream from 1 July 2027.

At one level, the compliance change is straightforward.

But changing “six months” to “12 months” in a policy is probably the easy part.

For providers, the more important question is what the change means operationally.

What has changed?

For non-school students, a receiving provider must not knowingly enrol a student seeking to transfer from another registered provider until the student has completed at least 12 months of their principal course, unless an exception under Standard 7 applies.

The Department’s guidance also makes clear that the new restriction can affect students who had already completed six months under the previous settings but had not yet completed 12 months when the amendment commenced.

That creates an immediate transition issue for both releasing and receiving providers.

Providers therefore need to be clear about:

• which students are now within the restricted period;

• how existing transfer requests are being handled;

• whether students had already been accepted before 2 October;

• whether admissions staff are checking previous study before issuing new offers or CoEs; and

• how students are being advised where the new rule changes their position.

More students may now require formal release decisions

The practical impact of extending the restriction period is that more transfer requests may need to be considered under a provider’s formal release process.

That potentially means:

• more case assessment;

• more supporting documentation;

• more judgement around compassionate or compelling circumstances;

• more correspondence with students;

• and potentially more internal reviews or appeals.

The Department’s guidance confirms that providers should assess relevant circumstances on a case-by-case basis, exercise professional judgement and retain supporting evidence on the student file.

That raises a practical resourcing question.

Has the institution considered whether the team responsible for transfer requests can absorb a larger volume of decisions over a longer restricted period?

This may be particularly relevant where transfer decisions currently sit with a relatively small international compliance, admissions or student services team.

Policies and procedures may need more than a wording change

Providers should obviously review policies, procedures, templates and student information that still refer to a six-month restriction.

But this should not be treated as a find-and-replace exercise.

A provider may also need to ask:

• Does the existing process still work effectively over a 12-month period?

• Are decision-making responsibilities and delegations clear?

• Are staff applying the same criteria consistently?

• Is there clear guidance on what evidence should be requested?

• Are decision reasons being properly recorded?

• Are students being advised of review or appeal options where relevant?

• Are receiving-provider checks built into admissions workflows?

• Are education agents receiving accurate and consistent information?

The longer restriction period creates more opportunity for inconsistency if decision-making arrangements are not clear.

Systems will help, but they do not replace provider controls

PRISMS has been updated to support the new transfer settings.

That is useful, but system controls do not remove the need for providers to understand the student’s circumstances before progressing an enrolment.

Receiving providers should still take reasonable steps to establish whether a student has commenced with another provider and whether the transfer restriction applies.

The same applies internally.

Admissions, international compliance, student services and agent management functions need to be working from the same rules and escalation points.

Agent commission controls remain separate

The January 2026 prohibition on education agent commissions for certain onshore transfers remains relevant.

That prohibition is separate from whether a student is entitled to transfer or has been released.

In other words, a provider should not assume that because a release has been approved, an agent commission may necessarily be paid.

That separation between transfer eligibility, release decision-making and agent remuneration is worth reinforcing with staff and agents.

The broader policy direction also matters

The Government has described the 12-month restriction as a transition measure ahead of a new Student visa transfer stream commencing from 1 July 2027.

Under the announced visa settings, students seeking to change providers will need to obtain the new visa before commencing with the new provider. The Government has also announced restrictions on certain downward transfers, including movement from higher education to VET.

Those future migration settings are not the same thing as the current Standard 7 requirement.

But they do explain why providers should see the 12-month change as part of a broader shift in the regulation of onshore student transfers rather than an isolated National Code amendment.

What should providers be considering now?

At a minimum, providers may wish to check:

• whether policies, procedures and student information reflect the 12-month restriction;

• whether transition cases have been identified;

• whether staff and agents understand the change;

• whether receiving-provider admissions checks are operating effectively;

• whether release decision-makers are appropriately delegated and trained;

• whether evidence and decision reasons are being retained consistently;

• whether current resourcing is sufficient if transfer requests increase;

• whether appeal pathways can accommodate any increase in volume; and

• whether agent commission controls remain clearly separated from release decisions.

The compliance requirement is relatively simple.

The implementation is not necessarily.

For providers, the real question is whether the change has been translated into workable processes, clear decision-making, adequate resourcing and reliable evidence.

That is where compliance starts to become implementation.

Official sources

Department of Education — Extension of the overseas student transfer restriction period to 12 months — For providers

Federal Register of Legislation — National Code of Practice for Providers of Education and Training to Overseas Students Amendment (Overseas Student Transfers) Instrument 2026

Minister's Media Release — Student visa integrity reforms take effect today

Disclaimer: This publication provides general information and commentary only and does not constitute legal, regulatory or institution-specific advice. Providers should consider the relevant legislative and regulatory requirements, their particular circumstances and obtain appropriate professional or legal advice where required. Information is current as at the date of publication.