Where Section 1 examined the accuracy of marketing information, Section 2 examines who delivers that information and how their conduct is controlled.

Under the NVR Standards, RTOs remain responsible for the actions of their education agents and third-party representatives.

Outsourcing recruitment does not outsource accountability.

If an agent misrepresents a course, provides outdated information, or fails to disclose third-party involvement, regulatory responsibility remains with the RTO.

Agent management is therefore not just a relationship function.
It is a governance control obligation.

What the Standard Requires

RTOs must ensure:

Governance Standards (4.1 and 4.2) require oversight systems to ensure third-party risk is actively managed.

Appointing an agent is not sufficient — performance must be supervised and reviewed.

Where Operational Gaps Arise

Common weaknesses include:

Strong relationships do not replace structured oversight.

Auditors assess documented control, not verbal assurance.

Auditor Lens

Auditors typically:

They assess whether:

The focus is governance maturity and risk control.