The CRICOS 12-month transfer rule stops registered providers from knowingly enrolling an international student who has not completed 12 months of their principal course with another provider. It applies from 2 October 2026 to 30 June 2027 (inclusive). From 1 July 2027, the restriction returns to six months.
However, this is not an absolute ban. Exceptions under Standard 7 of the National Code still apply, and a release from the current provider can still unlock a transfer.
The rule has caught many providers off guard. A student who had completed seven months of study on 1 October was free to transfer. On 2 October, that same student became restricted again.
Therefore, every provider with transfer-in or transfer-out activity needs to recheck its offers, policies and agent arrangements. This guide explains what changed, who is affected, how the process works, and what to do next.
What is the CRICOS 12-month transfer rule?
The CRICOS 12-month transfer rule is a temporary change to Standard 7 of the National Code. It extends the transfer restriction period for most international students from six months to 12 months.
Here are the key terms, defined on first use:
- CRICOS is the Commonwealth Register of Institutions and Courses for Overseas Students. It lists every provider and course that can legally enrol students on a student visa.
- ESOS Act is the Education Services for Overseas Students Act 2000. It protects international students and regulates their providers.
- National Code is the National Code of Practice for Providers of Education and Training to Overseas Students 2018. Standard 7 covers student transfers between registered providers.
- Principal course is the main course a student is enrolled in. The restriction period is measured from its commencement.
- PRISMS is the Provider Registration and International Student Management System. Providers use it to record releases and report enrolments.
- A letter of release is the written approval from a student’s current provider that allows them to move to another provider.
In short: from 2 October 2026 to 30 June 2027, a registered provider must not knowingly enrol a transferring student who has not completed 12 months of their principal course, unless an exception applies.
Why does the CRICOS 12-month transfer rule matter?
The rule matters because it changes enrolment decisions overnight. Providers that recruit transfer students now carry real compliance risk if they enrol someone too early.
In addition, the change is part of a wider integrity push by the Australian Government. The Assistant Minister for International Education, Julian Hill, made the amendment. The Government describes it as a transitional setting ahead of broader reforms scheduled for 1 July 2027.
For students, the stakes are just as high. A student who accepts an offer without a valid release may find the new provider cannot enrol them. As a result, they risk delays, lost fees and visa complications.
When does the CRICOS 12-month transfer rule start and end?
The amendment commenced the day after it was registered on the Federal Register of Legislation. Registration happened on 1 October 2026, so the rule took effect on 2 October 2026.
| Period | Transfer restriction for non-school students |
|---|---|
| Before 2 October 2026 | 6 months |
| 2 October 2026 to 30 June 2027 | 12 months |
| From 1 July 2027 | 6 months (plus a new visa transfer stream for onshore changes) |
Importantly, the 12 months is measured from the start of the principal course. It is not an extra 12 months counted from 2 October. A student who started in January 2026 will reach 12 months in January 2027.
Who does the 12-month transfer rule apply to?
The rule applies to international students other than school students. It covers students in higher education, vocational education and training (VET), ELICOS (English language) and other non-school courses.
The key groups are as follows:
- Students with less than six months completed: They were already restricted. The restriction now simply lasts longer.
- Students with six to 12 months completed on 2 October 2026: They were free to transfer before the change. They are now restricted until they reach 12 months.
- Students with 12 months or more completed: They are not affected, because they have already satisfied the requirement.
- Students recruited but not yet accepted: Providers must assess them against the new 12-month rule.
- School students: The six-month restriction for the school sector remains in place.
For example, a student who commenced a diploma in March 2026 had six months completed in September. Under the old rule, they could move freely in October. Under the new rule, they must wait until March 2027 or qualify for an exception.
How does the transfer process work under the new rule?
The process follows the same basic steps as before. However, the timing and the decision points have changed.
Check the student's start date
Confirm when the principal course commenced and how many months the student has completed.
Check the 12-month threshold
If the student has completed 12 months, they can transfer without needing an exception.
Look for an applicable exception
Assess whether an exception under Standard 7 applies, such as a provider ceasing to deliver the course.
Obtain a valid unconditional offer
The student needs a valid offer from another CRICOS-registered provider before requesting a release.
Request the release
Many providers require students to lodge the request through their student management system.
Record the outcome in PRISMS
The releasing provider records the date of effect and the reason for release.
Update the Confirmation of Enrolment (CoE)
The new provider issues a new CoE, which is the document confirming the student's enrolment in a specified course.
Additionally, the new provider must keep records of its assessment. Strong record-keeping protects your registration if ASQA (the Australian Skills Quality Authority) or another regulator audits your transfer decisions.
What exceptions still apply to the 12-month transfer rule?
Exceptions under Standard 7 still apply during the temporary period. The exact wording sits in the amended National Code, so providers should always check the current text.
Historically, the main grounds for a transfer before the restriction period ends have included:
- The releasing provider has agreed to the student’s release and recorded it in PRISMS.
- The releasing provider, or the course, has ceased to be delivered.
- The provider’s registration, or the course registration, has been suspended or cancelled, or sanctions have been imposed.
- A government sponsor has determined the transfer is in the student’s best interests and has given written support.
Furthermore, extra safeguards apply to students under 18. Standard 7 and Standard 5 (younger overseas students) require appropriate welfare arrangements and parent or guardian support.
Note that providers are not obliged to grant every release request. Even so, refusing a release for an unjustifiable reason can create complaint and appeal risks.
What are the benefits of the CRICOS 12-month transfer rule?
The Government’s stated aim is to strengthen the integrity of the international education sector. In practice, the rule offers several potential benefits:
- Fewer opportunistic transfers: Students are less likely to switch providers for non-genuine reasons.
- More stable enrolments: Providers can plan their intakes and resourcing with greater confidence.
- Reduced poaching pressure: The rule makes onshore recruiting of transferring students harder, which supports genuine course completion.
- Clearer compliance lines: A single threshold of 12 months is simple to apply and audit.
- A bridge to future reform: The temporary period gives the sector time to prepare for the new transfer stream from July 2027.
What challenges should you consider?
What are the best practices for the CRICOS 12-month transfer rule?
What should providers do now?
- Update your transfer policy. Reflect the 2026 amendments to Standard 7 and version-control the change.
- Audit pending offers. Check every transfer-in offer issued before 2 October 2026.
- Train admissions and agent teams. Staff must be able to calculate months completed accurately.
- Document every decision. Record the evidence for each release, refusal, and exception.
- Review agent contracts. Remove any payment structure linked to onshore transfers.
- Monitor official updates. Check the Department of Education and ASQA websites regularly.
What should students do before requesting a transfer?
- Confirm your course start date. Count 12 months from commencement, not from 2 October.
- Get the offer first. Obtain a valid unconditional offer from another CRICOS-registered provider.
- Apply for release in writing. Keep copies of every request and response.
- Do not accept an offer yet. Wait until your release is approved.
- Check your visa conditions. A study change can affect your student visa, so confirm with the Department of Home Affairs.
What are the most common mistakes to avoid?
- Assuming that six completed months automatically exempts a student.
- Counting 12 months from 2 October 2026 instead of from the course start date.
- Issuing a CoE before a release is recorded in PRISMS.
- Relying on outdated policies that still refer to a six-month restriction.
- Treating the rule as a visa rule. It is a National Code rule, separate from visa requirements.
- Failing to keep records of the assessment and the evidence reviewed.
- Letting agents promise students a quick transfer without checking eligibility.
What will change after 30 June 2027?
From 1 July 2027, the restriction period reverts to six months. However, students who want to change providers after arriving in Australia will need to apply for a new student visa through a new transfer stream.
Therefore, the temporary 12-month rule is a bridge, not the end of the story. Providers should monitor Department of Home Affairs and Department of Education guidance for the final details.
Frequently asked questions
What is the CRICOS 12-month transfer rule?
It is a temporary change to Standard 7 of the National Code. From 2 October 2026 to 30 June 2027, registered providers cannot knowingly enrol most international students who have not completed 12 months of their principal course elsewhere. Exceptions, including an agreed release, still apply.
When did the 12-month transfer rule start in Australia?
Does the 12-month rule apply to students who already completed six months?
Is the 12 months counted from 2 October 2026?
Does the 12-month transfer rule apply to school students?
Can a student still transfer before 12 months?
Do students need a letter of release to transfer?
What happens to the transfer rule on 1 July 2027?
Conclusion
Summary: The CRICOS 12-month transfer rule temporarily extends the Standard 7 restriction from six to 12 months. It runs from 2 October 2026 to 30 June 2027 and applies to most non-school international students. Exceptions remain, but providers must assess them carefully and record every decision.
Key takeaway: The 12 months is measured from course commencement, and it affects students who have already passed six months. Therefore, never assume a student is free to transfer based on the old rule.
Recommended action: Audit your pending offers and transfer policy this week. Then brief your admissions team and agents on the new threshold. Finally, bookmark the Department of Education and ASQA pages for updates ahead of the July 2027 reforms.
