Pre-lodgement review is usually run as proofreading: check the form fields, check nothing is missing, lodge.
The Code of Conduct frames it differently. Section 20 is about verification, and it operates at three thresholds — what you know, what you suspect, and what you reasonably ought to suspect.
That third one is the reason a review cannot be only a completeness check. You do not have to have suspected anything. It is enough that you reasonably ought to have.
The three thresholds
What you know. Section 20(1) prohibits giving a government official a document you know is false or misleading, unless you disclose that to them.
What you suspect, or ought to. Section 20(2) and (3) are the operative provisions for a review. You must not make a statement, or give a document, that you suspect or reasonably ought to suspect is false or misleading — unless you disclose the suspicion, or have taken all reasonable steps to determine the position.
What you asserted. Sections 20(4) to (7) impose verification duties with no suspicion requirement at all. You must not state that a person is endorsed, nominated or sponsored, or give a document saying so, unless you have taken all reasonable steps to verify it. And you must not state, or give, a document as originating from a specified third party unless you have taken all reasonable steps to verify its origin.
That last set is the one practices miss, because it applies even where nothing looks wrong. Sponsorship and third-party origin need verifying as a matter of course.
What "all reasonable steps" actually means
OMARA has published guidance on this, and it is more reassuring and more specific than the section reads.
On documents you ought to suspect: what is reasonable depends on the circumstances, and "reasonable" means simply rational — not irrational, absurd or ridiculous. The worked example given is a document from someone purportedly representing a sponsor that contains incorrect company details; the reasonable step suggested is to contact the employer directly and ask about it.
On third-party origin: the guidance is explicit that it would not be necessary to engage a fraud expert, and that it was not the intention of these provisions to have agents verify document authenticity. What is expected is common sense, due diligence and the reasonable person test — a phone call or an email to the third party confirming they provided the document.
It gives a specific scenario worth internalising. Where a visa applicant approaches an agent with the nomination paperwork already prepared, there are two clients and two applications, and the agent is expected to verify with each client the documents provided for their own application. The guidance says it is important that the agent contact the employer to verify their instructions, confirm they intend to sponsor the applicant, and confirm they provided the nomination documents.
So the standard is a contact, not a forensic examination. Which makes it entirely achievable — and makes not doing it hard to explain.
Separating preparer and reviewer
The value of a second person is that they have not already decided the answer. Someone who assembled the evidence over three months cannot easily see what is missing from it.
Which means the reviewer's job is not to repeat the preparer's work. It is to ask the questions the preparer can no longer ask:
- Does the evidence support the claim, or does it support a related claim that is not quite this one?
- What is asserted that has not been verified? Particularly endorsements, nominations, sponsorships and third-party documents.
- What is inconsistent? Dates that conflict across documents, an address that does not match, a relationship timeline that does not reconcile.
- What is absent that should exist? The gap in a work history, the missing period in an address record.
- What would a case officer ask first?
Section 24 sits behind this: an agent must take all reasonable steps to ensure the quality, accuracy and timeliness of work performed by another person assisting them — with the exception that the duty does not extend to work performed by another registered agent. OMARA's practice management guidance names reviewing visa applications before they are lodged as a supervisory arrangement a practice should have.
Where a solo practice gets its second reader
The obvious objection is that a solo agent has no colleague. Three substitutes work reasonably well.
Time. Reviewing two days after preparing recovers some of the distance a second person provides.
Structure. A checklist derived from the criteria rather than from habit forces attention onto things you would otherwise skim. Our document checklist guide is a starting point.
Reciprocity. A standing arrangement with another agent to review each other's complex matters. Note that section 24(2) means you do not take on responsibility for another registered agent's work by doing so — though the Code's guidance on responsible migration agents is a reason to keep the arrangement to review rather than substantive input.
If something is wrong after lodgement
Section 21 is the provision to know before you need it, because its structure surprises people.
Where an agent becomes aware that a statement or document given to a government official — by the client, by the agent on the client's behalf, or by a third party on behalf of someone who is now a client — was false or misleading, or that a client concealed relevant information, the agent must not give immigration assistance to the client unless three things happen: an agent has informed the client about the potential consequences and discussed how the matter may be corrected; the client agrees to it being corrected; and the client takes all reasonable steps to correct it.
Read that carefully. The default is that you stop. Continuing to act is conditional on the client agreeing to correct the record. It applies to statements made before you were engaged, and to statements made by third parties.
That is a difficult conversation, and having it is not optional.
A review that leaves evidence
The review has to produce a record, or it did not happen for any purpose that matters later.
- Preparer completes and marks it ready, with the evidence set attached to the matter.
- Reviewer works from criteria, not from the preparer's summary.
- Verification steps are recorded individually — who was contacted, when, and what they confirmed. This is the section 20 evidence, and a file note of the call is the artefact.
- Findings go back as items, not as a conversation.
- Sign-off is by a named person against a specific version of the application.
- Lodgement happens under the agent's own credentials, never a shared login.
- The client receives written confirmation and a copy, as section 39 requires.
The review test
- Does your review check verification, or only completeness?
- For sponsored matters, do you contact the sponsor to confirm the documents came from them?
- Is each verification step recorded as a file note?
- Does the reviewer work from the criteria or from the preparer's summary?
- Is sign-off attributed to a named person and a version?
- Would a false statement discovered next month trigger your section 21 process, or a discussion about whether to raise it?
Where a system helps
Pre-lodgement review breaks down under time pressure, and it breaks down invisibly — the step is skipped, nothing looks different, and the omission only surfaces if something goes wrong.
Making it structural fixes that: a stage that cannot advance to lodged without a recorded review, a checklist attached to the matter, verification steps captured as file notes at the moment of the call, and a sign-off attributed to a person and a document version. Our guide to client onboarding covers where the evidence set starts, and starting a migration agency covers building the habit early.
LodgeHQ supports review checklists and recorded sign-off on the matter. Start a free trial and see how many of your recent lodgements have a review you could evidence.
Verify before you rely on it
Criteria change and this article is about process rather than substantive requirements. Check eligibility against the current legislation and departmental material for the specific visa, every time.
This is general information for migration practices, not legal advice. Where you suspect a document is false, or discover a false statement has been made, get advice before lodging or continuing — section 21 constrains what you may do next.