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GERSA White Paper Series Part Two of Four

Failing to prevent fraud
is now a corporate offence
of its own.

The Economic Crime and Corporate Transparency Act 2023 introduces a strict liability offence for large organisations that fail to prevent fraud committed by associates. For UK Higher Education Institutions, that risk sits squarely inside the international agent networks used to recruit students abroad. This is the second paper in GERSA's compliance series, featured on the MSM Unify Global Education Intelligence platform.

Download the Full White Paper See what is inside

Authored and owned by GERSA, The Global Education Recruitment Standards Authority. Hosted in partnership with MSM Unify.

Author GERSA — Global Education Recruitment Standards Authority

Featured by MSM Unify, Global Education Intelligence

Published December 2025

The Economic Crime and Corporate Transparency Act 2023, commonly known as ECCTA, marks a fundamental shift in how UK law treats corporate responsibility for fraud. Where previous frameworks required proof that senior management had knowledge of wrongdoing, ECCTA introduces a strict liability offence that applies simply because fraud happened, and the organisation failed to stop it.

For UK Higher Education Institutions, the implications are immediate and specific. International recruitment relies on networks of agents and sub-agents operating in markets far from any UK campus. If one of those associates commits fraud intending to benefit the institution, whether through falsified documentation, misrepresented qualifications, or fabricated financial records, the institution itself can now be held criminally liable, regardless of what senior leadership knew or intended.

The Economic Crime and Corporate Transparency Act 2023 introduces a strict liability offence for large organisations that fail to prevent fraud committed by associates. For UK Higher Education Institutions, this includes risks arising from contracting with international education agents who recruit students abroad.

GERSA, Executive Summary, December 2025

Why higher education is exposed

The offence is strict.
The exposure runs through your agents.

A new strict liability standard

Unlike earlier fraud law, ECCTA does not require proof that directors knew about or directed the wrongdoing. Fraud committed by an associate for the organisation's benefit is enough to trigger liability.

Agents count as associates

International recruitment agents, sub-agents and partner organisations contracted to recruit students abroad fall within the scope of who counts as an associate under the Act.

Large organisation thresholds

The offence applies to large organisations meeting specific size criteria, a threshold that captures the majority of UK Higher Education Institutions operating international recruitment functions.

Fraud, not just bribery

Where the Bribery Act addresses corrupt payments, ECCTA targets a far wider category of fraud, including falsified applications, misrepresented documents and fabricated financial records used to secure admission or funding.

Corporate transparency is no longer a compliance department's afterthought. Under ECCTA, it is a direct test of institutional liability.

Inside the white paper

Four questions every institution should be able to answer

I.

The scope of ECCTA

What the fail to prevent fraud offence actually covers, how ‘associate’ is defined, and how the large organisation threshold applies to universities.
II.

Where the risk sits in recruitment

How fraud committed by an international agent, from falsified transcripts to fabricated funding evidence, can expose the contracting institution.
III.

Reasonable prevention procedures

What a defensible fraud prevention framework looks like in practice, and how it differs from existing anti-bribery procedures.
IV.

Practical measures for institutions

Concrete steps GERSA recommends institutions take now, building on the governance groundwork covered in paper one.

Read the Full Analysis

Every agent agreement a university signs now carries a question ECCTA makes unavoidable: what happens if this partner commits fraud on our behalf?

About the author

GERSA

The Global Education Recruitment Standards Authority

GERSA is an independent authority dedicated to raising standards, transparency and accountability across international education recruitment. This white paper is authored and owned by GERSA. It reflects GERSA's independent research and analysis.

MSM Unify is proud to feature this research as a content partner, hosting it on the MSM Unify Global Education Intelligence platform in partnership with GERSA. MSM Unify is not the author of this paper and makes no claim to its authorship or its conclusions.

A connected series

Four papers. One compliance landscape.

This is the second of four white papers GERSA is sharing through the MSM Unify Global Education Intelligence platform. Each paper stands alone. Together, they build a fuller picture of the legal and regulatory pressures shaping international education recruitment.

Part 01 · Available now

The Impact of the UK Bribery Act 2010 on UK Higher Education Institutions

How section 7's strict liability offence applies to global recruitment networks, and what ‘adequate procedures’ should look like for a university.

Read the paper

Part 02 · Available now

The Impact of the Economic Crime and Corporate Transparency Act 2023 on UK Higher Education Institutions

How the fail to prevent fraud offence extends institutional liability into international agent networks, and what reasonable prevention procedures should include.

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Part 03 · Coming soon

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The next paper in the GERSA series will be shared on this platform shortly.

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Which Country Is Best for International Students in 2026?

How to Get Your First 10 Students as a New Education Consultant

Failing to prevent fraud is now a corporate offence of its own.

The offence is strict.The exposure runs through your agents.

A new strict liability standard

Agents count as associates

Large organisation thresholds

Fraud, not just bribery

Four questions every institution should be able to answer

The scope of ECCTA

Where the risk sits in recruitment

Reasonable prevention procedures

Practical measures for institutions

GERSA

Four papers. One compliance landscape.

The Impact of the UK Bribery Act 2010 on UK Higher Education Institutions

The Impact of the Economic Crime and Corporate Transparency Act 2023 on UK Higher Education Institutions

Topic to be announced

Topic to be announced

Read the full GERSA analysis, and hear about the next paper in this series first.

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Failing to prevent fraud
is now a corporate offence
of its own.

The offence is strict.
The exposure runs through your agents.