Chartered Accountants Australia and New Zealand (CA ANZ) has made a submission to the Australian Department of Education in response to the Draft International Education and Skills Strategic Framework (the Draft Framework).

Our comments focus on Objective 2 of the Draft Framework: A Managed System to Deliver Sustainable Growth Over Time.

CA ANZ supports strengthening the sustainability, quality and integrity of Australia's international education sector but remains concerned that the planned cap on student numbers will exacerbate the national shortage of accounting and audit professionals.

Our main concerns with the government’s proposed approach relate to:

• the impacts of the limits on total international student enrolments, which will likely have negative flow on effects for Australia’s education providers, skills assessing authorities, business, the economy and jobs.
• the limits on enrolments in specific courses, which may include higher education programs of commerce, management and accounting which are already in decline.
• the limits on enrolments in specific locations, which may direct more students to regional areas which is not where most of them want to study. The result will likely be less enrolments than the number of capped places.

With the accounting profession already facing a declining graduate pipeline, ongoing shortages, and global competition for talent, it is in Australia's interests to provide a destination of choice for international students.

It is important the government consults carefully and widely to manage these complex policy settings and planning required to balance public confidence in the migration intake with housing affordability and cost of living pressures.

The hard cap on total international student numbers also needs to be considered in the context of the changes to student visas and rules which have already been made by the government.

We caution the government against regulatory overreach and unintended consequences for Australia’s $48 billion international education sector, the economy, community, employers and organisations like CA ANZ – a professional accrediting body and TEQSA registered provider of higher education.