Every six months OMARA publishes a Migration Agent Activity Report. The latest, covering 1 July to 31 December 2025, is short and worth reading in full. Most coverage focused on the four cancellations, which involved false documents, undeclared assistance and agents working before registration. Those cases are not about software, and no system fixes them.
The three cautions and the barring are different. They read like a list of ordinary bad weeks: a deadline nobody tracked, a phone call nobody wrote down, an agreement nobody countersigned. That is the part of the report every registered agent should take personally, because it describes failures that happen to careful people who are busy.
The numbers
| Measure, 1 July to 31 December 2025 | Count |
|---|---|
| Registered migration agents at 31 December 2025 | 5,400 |
| Complaints finalised | 135 |
| Complaints that led to a sanction decision | 13 |
| Addressed with the agent (education and reminders) | 41 |
| Suspected breach notices | 8 |
| Agents cancelled | 4 |
| Agents suspended | 2 |
| Agents cautioned | 3 |
| Former agents barred | 1 |
The 41 complaints “addressed with agent” are the quiet number. OMARA describes them as less serious conduct where it reminds the agent of their obligations. Answering a complaint still takes time, even when it ends there.
What the cautions were actually for
Reading the case summaries side by side, the findings that led to cautions and the barring fall into four groups.
Deadlines. One agent was cautioned for six months after failing to be aware of the time by which a client’s application had to be made, and failing to have regard to the consequences of missing it. Another failed to submit documentation to meet statutory deadlines. Both map to section 33(d) and (e) of the Code of Conduct, which require you to know when an application or response is due and to weigh what happens if it is not made in time.
Records. The same six-month caution cites a failure to keep written records of oral communications (section 55) and to maintain the client file (section 56). A second caution lists a failure to maintain proper records.
Keeping the client informed. Not giving the client a copy of the application is a breach of section 39(b). Failing to keep clients informed about their matters appears in another caution. Section 39 also requires you to tell the client in writing when you lodge, and to tell them promptly about material developments.
Agreements and money. One caution cites the lack of a service agreement signed by all parties. Another cites a failure to meet financial duties, and the invoice and receipt rules in section 49.
The barring, two years for a former agent, rested on sections 13, 33 and 40: not acting competently and diligently, and causing unnecessary expense or delay.
None of these agents was accused of fraud. Each finding describes a system that relied on memory.
Why this matters more in 2026
Three things changed the odds of a lapse being noticed.
- OMARA now monitors without waiting for a complaint. A dedicated Compliance and Monitoring Section was set up in October 2025, and from 1 November 2025 OMARA began reporting how often it uses its powers to monitor Code compliance. A file that would only have been seen after a complaint can now be requested as part of monitoring.
- The Migration Agents Regulations 2026 started on 1 April 2026, with stricter CPD rules and an infringement notice scheme. We cover the detail in what changed under the 2026 Regulations.
- The government has signalled more. At the National Migration Conference on 2 October 2026, Assistant Minister Julian Hill said, as reported, that a dedicated team is now pursuing fake and scam agents, that the competency standards for agents are being refreshed, and that the Department has been asked to look at options for applications lodged without merit. The merit proposal is not law and has no timeline, but the direction is clear.
The four habits that would have prevented most of it
You do not need software for any of this. You need a habit that does not depend on remembering, and software is simply the cheapest way to make a habit automatic.
1. Every matter has its dates written down the day it opens. Lodgement windows, request response dates, visa expiry, and the expiry of the evidence you are relying on: English results, skills assessments, health checks, police certificates. Then something has to remind you before each one, not on the day. We go deeper in tracking the deadlines that become complaints.
2. Every phone call ends with a note. Section 55 asks for a contemporaneous written record of oral instructions and oral advice. Three lines, dated, on the client file, typed before the next call starts.
3. Lodgement triggers a message to the client. A written notice that you have lodged, a copy of what was lodged, and a message when anything material happens. If you send it the same way every time, it stops being a thing to remember.
4. No money moves before a signed agreement, and every payment gets an invoice and a receipt. We set out the money rules in client money for solo agents.
How Centrio handles each one
We build Centrio, so weigh this section accordingly. It describes what the product does today.
- Deadlines. When a matter is marked lodged, granted or refused, Centrio creates the follow-on deadlines from a rule list. When you upload an English result, skills assessment, health or police document, it reads the expiry date and proposes a deadline for you to confirm. A daily digest lists what is due in the next 14 days, and items still overdue after three days are escalated to the account owner. Log a request for information on the matter and the response date is created with a reminder at the halfway point to chase the client.
- Records. File notes are typed as phone call, meeting, email or in person and sit on the matter with the date and author. Every change is in an audit log you can open per matter and export.
- Keeping clients informed. Stage changes can send the client an email or SMS from templates you write once. The client portal holds their checklist, questionnaire and signed documents.
- Agreements and money. The service agreement is generated during onboarding and signed in the portal with a recorded signature. Each matter has its own client account with deposits, fees, disbursements and refunds, itemised invoices with GST, and a firm-wide reconciliation page.
Centrio will not record a fee or disbursement receipt on a matter until its service agreement is signed, so the order in section 51 is enforced rather than remembered.
Where to start this week
Pull your five oldest open matters. For each one, check that you can find, in under a minute: the signed agreement, the date the Consumer Guide was given, the next deadline, the last note of a phone call, and the written notice of lodgement. Any gap you find in five files is in the rest.
If you would rather that check run itself, Centrio’s Solo plan is free for one agent with up to 10 clients.
This is general information, not migration or legal advice. Section numbers are from the Migration (Migration Agents Code of Conduct) Regulations 2021 and should be checked against the current compilation.
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