Most “best migration agent software” lists compare feature grids. That is the wrong starting point. For a registered agent the question is narrower: will this system help me meet the Code of Conduct, or will I be meeting it in spreadsheets next to the software?

This checklist works from the Code outward. The section numbers refer to the Migration (Migration Agents Code of Conduct) Regulations 2021.

The ten checks

# Check Why it matters Code of Conduct
1 Can it hold client money apart from your own? Client money must go into a financial institution account that holds nothing else, and can leave it only for listed purposes s 50
2 Does it block receipts before a service agreement is in force? You cannot take an amount for immigration assistance without one s 51
3 Is the service agreement generated from the file? Scope and fees on the agreement should match what the file says s 42
4 Does it keep a dated record of oral advice? Phone and meeting advice needs a contemporaneous written record s 55
5 Does it retain files for seven years after the last action? Including when a client leaves or a matter closes s 56
6 Are client documents stored securely, with per-person access? A former client’s documents are still covered s 53
7 Does it flag conflicts of interest before you proceed? Written notice and consent are expected s 34
8 Is there an audit trail of who changed what? It turns a regulator request into a search, not a rebuild Good practice
9 Can it log CPD against the calendar? CPD rules tightened from 1 April 2026 Regulations 2026
10 Can you export everything, in a usable form? Seven years of retention means you may outlive the vendor relationship s 56

Check ten is the one agents skip. A system that cannot hand your client files back in a readable format does not meet check five in practice.

Client money is the dividing line

Section 50 lets client money out of the account only for the agent’s fees, payments to the Department or a review authority, disbursements, refunds to the client, and transfers to another registered agent on the client’s instruction. Section 51 stops you taking money before a service agreement is in force.

That has a design consequence. If the software treats a payment as a field on a CRM record, you are doing the reconciliation somewhere else. The test is simple: ask the vendor to show a receipt, a disbursement and a refund on one client file, then the reconciliation that includes them.

Records and files

Sections 55 and 56 are the ones agents underestimate. A note of what you told a client on the phone is an obligation, and the file has to survive seven years. Ask where a note typed on a Thursday is stored on Monday, who can edit it afterwards, and whether the edit is visible.

For the day a regulator asks, we cover what changed with the Migration Agents Regulations 2026 in a separate post.

What to ask about ImmiAccount

Lodgement is where vendors differ most and where claims are hardest to compare. Ask three things: which forms it fills, whether you review the completed form before anything is lodged, and what happens when Home Affairs changes a form. “Integrates with ImmiAccount” can mean anything from a link to a reviewed, pre-filled application.

If you also run an education desk

Agents who place students have a second set of records. Since 31 March 2026 providers cannot pay commission for onshore transfers made after that date, as we set out in the education agent commission ban. Your records need to show, for each paid placement, whether it was an initial enrolment or progression within a package, because those are the categories that remain commissionable.

Software that runs a migration desk and an education desk over one client record saves entering the same person twice. It also lets a student’s visa file and enrolment file be read together.

Price and the free-plan question

Compare on what the plan includes, not the headline price:

  • Number of users and clients.
  • Whether client accounting is included or an add-on.
  • Whether the audit trail and role-based access are on every plan.
  • Per-message costs for email and SMS.

For reference, Centrio’s pricing is a free Solo plan for one agent and a flat A$99 a month Practice plan with unlimited users and clients, excluding GST. Email and SMS are pay as you go. Hold every other vendor to the same list. We have done that for nine Australian options in our migration agent software comparison.

Five questions for any demo

  1. Show me a receipt, a disbursement and a refund on one client, then the reconciliation.
  2. Try to take a payment on a matter with no service agreement.
  3. Show me a note of oral advice, edit it, and show me the history.
  4. Export one client’s full file.
  5. Show me what a junior staff member can and cannot see.

If the answer to any is “that is on the roadmap”, you have found the place the spreadsheet will live.

This is general information, not migration or legal advice. The Code of Conduct is the authority on your duties. Section numbers are from the 2021 Regulations as compiled at 11 April 2024 and should be checked against the current compilation before you rely on them.

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