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If an agent misrepresents a course, provides outdated information, or fails to disclose third-party involvement, regulatory responsibility remains with the RTO.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:
- Third-party arrangements are clearly documented
- Roles and responsibilities are defined
- Agents are provided with accurate, current information
- Monitoring and corrective actions occur where required
- Students are informed when a third party is involved
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:
- Informal agent onboarding
- No structured performance review process
- Agents retaining outdated materials
- No documented monitoring activity
- Complaints not linked back to agent performance
- Reliance on trust rather than documented control
Strong relationships do not replace structured oversight.
Auditors assess documented control, not verbal assurance.
Auditor Lens
Auditors typically:
- Request third-party agreements
- Review agent contracts
- Examine monitoring records
- Test whether corrective action has occurred
- Interview staff about oversight processes
They assess whether:
- The RTO actively monitors its agents
- Evidence exists of review and corrective action
- Students are aware of third-party involvement
The focus is governance maturity and risk control.
