Can an under-18 student transfer between Australian providers in 2026?
Yes — an under-18 student can move from one Australian provider to another in 2026, but the transfer is not a routine release. Under Standard 7 (Overseas student transfers) of the National Code 2018 as published on the Australian Federal Register of Legislation, as of September 2026, a transfer involving a student under 18 additionally requires written confirmation that the student's parent or legal guardian supports the transfer, and, where the student is not being cared for in Australia by a parent or suitable nominated relative, the receiving provider must confirm it accepts responsibility for approving the student's accommodation, support and general welfare arrangements under Standard 5 (Younger overseas students).
What does the six-month rule actually require?
Standard 7.1 sets the baseline: a registered provider must not knowingly enrol an overseas student seeking to transfer from another registered provider's course before the student has completed six months of their principal course. For the school sector the same restriction runs until after the first six months of the first registered school sector course.
A transfer inside that restricted period is only possible where one of four situations applies:
- the releasing provider, or the course the student is enrolled in, has ceased to be registered (7.1.1);
- the releasing provider has had a sanction imposed on its registration by the ESOS agency that prevents the student from continuing the course there (7.1.2);
- the releasing provider has agreed to the student's release and recorded the date of effect and the reason for release in PRISMS (7.1.3);
- any government sponsor of the student considers the change to be in the student's best interests and has provided written support for the change (7.1.4).
What changes specifically because the student is under 18?
Standard 7.3 adds two conditions on top of the release rules above. First, the provider must hold written confirmation that the student's parent or legal guardian supports the transfer. Second, where the student is not being cared for in Australia by a parent or suitable nominated relative, the receiving provider must confirm it accepts responsibility for approving the student's accommodation, support and general welfare arrangements in line with Standard 5.
Accepting that responsibility is not a formality. Under Standard 5.3, a provider that takes on responsibility for approving welfare arrangements under the Migration Regulations must nominate the dates for which it accepts that responsibility and advise Immigration of those dates in the required form; ensure adults involved in providing accommodation and welfare hold the working with children clearances appropriate to the jurisdiction; verify that the accommodation is appropriate to the student's age and needs before approval and at least every six months afterwards; keep up-to-date contact details for the student's parents, legal guardian or the adult responsible for welfare; and have documented processes for selecting, screening and monitoring any third party it engages to organise or assess those arrangements. Standard 5.3 also makes clear that this responsibility covers accommodation, support and general welfare but not guardianship, which is a legal relationship a provider cannot create.
| Stage of the transfer | Releasing provider | Receiving provider |
|---|---|---|
| Before the release | Assess the written transfer request against its documented policy and, if granted, record the date of effect and reason in PRISMS | Hold written confirmation that a parent or legal guardian supports the transfer |
| Where the student is not with a parent or suitable nominated relative | Where Standard 5.3 applies and it suspends or cancels the enrolment, continue approving welfare until one of the four situations in Standard 5.6 applies | Confirm it accepts responsibility for accommodation, support and general welfare under Standard 5 |
| On the transfer date | Negotiate the welfare transfer date to ensure there is no gap | Negotiate the welfare transfer date and inform the student of the visa obligation to maintain current arrangements until that date |
| If the provider can no longer approve welfare | Notify Immigration within 24 hours and make all reasonable efforts to notify parents or legal guardians immediately | — |
Can there be a gap in welfare arrangements between the two providers?
No. Where a receiving provider enrols a student under 18 whose welfare arrangements are approved by another registered provider, Standard 5.7.1 requires it to negotiate the transfer date for welfare arrangements with the releasing provider to ensure there is no gap. Under Standard 5.7.2 it must also inform the student of their visa obligation to maintain their current welfare arrangements until the transfer date, or to have alternate welfare arrangements approved or return to their home country until the new approved welfare arrangements take effect.
The safety net works from the other side too. Under Standard 5.6, if the releasing provider suspends or cancels the student's enrolment, it must continue approving welfare arrangements until one of four things happens: the student has alternative welfare arrangements approved by another registered provider; care by a parent or nominated relative is approved by Immigration; the student leaves Australia; or the provider has notified Immigration that it is no longer able to approve welfare arrangements, or has taken the required action after being unable to contact the student.
How does a provider decide whether the transfer is in the student's best interests?
Standard 7.2 requires providers to have and implement a documented policy and process for assessing transfer requests made before the six-month point, and to make that policy available to staff and students. The policy must set out the steps for lodging a written request, including the requirement to provide a valid enrolment offer from another registered provider (7.2.1), the circumstances in which the provider will grant the request, the grounds it considers reasonable for refusing (7.2.3), and a reasonable timeframe for assessing and replying to requests having regard to the restriction period (7.2.4).
The listed circumstances where a transfer is treated as being in the student's best interests include cases where the student will be reported for being unable to achieve satisfactory course progress even after engaging with the provider's intervention strategy under Standard 8; where there is evidence of compassionate or compelling circumstances; where the provider fails to deliver the course as outlined in the written agreement; where there is evidence that the student's reasonable expectations about the current course are not being met; where the student was misled by the provider or an education or migration agent about the provider or its course and the course is therefore unsuitable to their needs or study objectives; and where an internal or external appeal on another matter results in a decision or recommendation to release the student.
Suppose a student under 18 applies to transfer three months into a principal course because the timetable delivered differs from the written agreement. The releasing provider assesses that request under its own documented policy, and if the student is under 18 the transfer cannot proceed without the parent or guardian's written support and, where relevant, the receiving provider's confirmation of welfare responsibility.
What happens if the request is refused, and does it cost anything?
If a release is granted, Standard 7.4 requires it to be at no cost to the student, and the releasing provider must advise the student to seek advice from Immigration on whether a new student visa is required. If a provider intends to refuse, Standard 7.5 requires it to inform the student in writing of the reasons for the refusal and of the student's right to access the provider's complaints and appeals process under Standard 10 within 20 working days. Under Standard 7.6, the provider must not finalise the student's refusal status in PRISMS until the appeal finds in favour of the provider, the student chooses not to access the complaints and appeals processes within that 20-working-day period, or the student withdraws from the process. Providers must keep records of all release requests, assessments and decisions for two years after the student ceases to be an accepted student (7.7).
Transfer, welfare and visa outcomes depend on the facts of each enrolment, so this overview is general information about how the published rules work and not an assessment of any individual case; the official text and a qualified adviser remain the reference points for a specific situation.
Frequently Asked Questions
Does the six-month restriction work the same way for school students?
Standard 7.1 applies the restriction to the principal course generally, and for the school sector to the first six months of the first registered school sector course. The under-18 conditions in Standard 7.3 sit on top of that restriction rather than replacing it.
Who has to hold the parent's or guardian's written support?
Standard 7.3.1 requires the registered provider to have written confirmation that the student's parent or legal guardian supports the transfer. The text states the provider must hold that confirmation without specifying which of the two providers must collect it.
Is a welfare confirmation needed if the student lives with a parent in Australia?
Standard 7.3.2 applies only where the student is not being cared for in Australia by a parent or suitable nominated relative. Separately, Standard 5.3.6.1 requires the provider to advise Immigration as soon as practicable where the student will be cared for by a parent or nominated relative approved by Immigration and a Confirmation of Appropriate Accommodation and Welfare (CAAW) is no longer required.
Can the student simply stop the old welfare arrangement on the day classes start at the new provider?
No. Standard 5.7.1 requires the receiving provider to negotiate the transfer date so there is no gap, and Standard 5.7.2 requires the student to be told of the visa obligation to maintain current welfare arrangements until that date, or to have alternative arrangements approved or return home until the new arrangements take effect.
Is there a charge for being released?
Standard 7.4 states that a release, when granted, must be at no cost to the student.
What if the student is under 18 and cannot be contacted?
Standard 5.5 requires the provider to make all reasonable efforts to locate the student, including notifying the police and any other relevant Commonwealth, state or territory agencies as soon as practicable, where it is unable to contact the student and has concerns for their welfare.