For Australian migration agents
Pre-lodgement risk audit — peer RMA second opinion before you lodge
A structured audit of your draft visa application by an experienced Registered Migration Agent (MARN 1576536), scored against 11 refusal-pattern dimensions. Written PDF report delivered within 24-48 hours. The kind of pre-lodgement QA that turns "I think it's ready" into "I have documented evidence it's ready".
MARN 1576536 · Keshab Chapagain · Verifiable at mara.gov.au
The economic case: a refused $4,000+ visa application typically costs your client the application fee, often $2,500+ in ART lodgement fees, 6-12 months of distress, and frequently the relationship with the referring source. Set against the cost of even a single refusal, an $800 audit pays for itself many times over.
What you're buying — exactly
A written PDF audit report covering, at minimum:
- Overall risk assessment — Green / Yellow / Red headline rating with a one-sentence summary of dominant risk
- Dimension scorecard — every risk dimension scored individually so you can see exactly where the application is strong and where it's exposed
- High-impact fixes — every Red and Yellow flag with specific written recommendations on what to fix, what evidence to gather, and how to phrase it
- Medium-impact suggestions — items that aren't refusal risks but would strengthen the application
- Notes — free-text section for anything that doesn't fit the rubric — recent policy changes affecting the case, specific risk factors for the client profile, alternative pathways worth considering
- File-note format — the report is structured so you can drop it into your matter file as a defensible record of pre-lodgement due diligence
The 11-dimension rubric
Every audit covers 6 universal dimensions that apply to every visa subclass, plus subclass-specific dimensions tailored to the application type.
Universal — every visa subclass
- Document completeness & currency. Every required document present, certified where needed, dated within validity windows, translations attached. Cross-checks: are police checks from every country lived 12+ months past 10 years? Are translations NAATI-certified or accompanied by sworn translator declarations?
- Identity & character. Character declarations complete and consistent with prior applications. Prior visa history disclosed accurately. Convictions, charges, and adverse migration history reviewed against PIC 4001 and s 501 considerations.
- Health requirement. Examinations scheduled or completed via panel doctor / Bupa Medical Visa Services. PIC 4007 considerations flagged where relevant (significant health care cost, community impact). TB screening rules applied for applicants from relevant countries.
- English language. Test type accepted by the Department for this visa. Score current (within 3 years where required). Minimum-component requirements met — not just the overall score (a common silent failure mode).
- PIC 4020 disclosure discipline. Cross-check against any prior applications for the same applicant. No inconsistencies in dates, addresses, employment history, family relationships, qualifications, or identity details. Material facts disclosed. This is one of the most expensive things to get wrong — PIC 4020 findings can affect future applications for several years.
- Procedural compliance. Form version current (Department periodically updates). Deadlines respected. VAC paid via the correct method. Lodgement format meets current Departmental requirements. Decision-ready package — anything missing that the Department typically requests as additional information later.
Skilled visas (189 / 190 / 491 / 482 / 186) — add 5
- ANZSCO occupation match. Position description and actual duties cleanly mapped to the nominated ANZSCO code. Mismatches between the role's day-to-day work and the ANZSCO description are a high-frequency refusal reason.
- Skills assessment validity. Assessment current (within 3 years where required), issued by the correct authority for the nominated occupation, and the occupation on the assessment matches the occupation on the application exactly.
- Employment evidence quality. Reference letters on letterhead with the right structure: dates, hours, location, duties (mapped to ANZSCO), salary where required. Payslip evidence. No overlap between claimed full-time skilled employment and full-time study (a common silent points-test failure mode).
- AMSR / income threshold (482 / 186). Salary at or above the Annual Market Salary Rate (AMSR) with comparator evidence the Department accepts. Meets the relevant income threshold — Core Skills Income Threshold (CSIT) for 482 Core Skills stream and 186 nominations lodged on or after 7 December 2024; Specialist Skills Income Threshold (SSIT) for 482 Specialist Skills stream; TSMIT for Subclass 494 / 187 — where applicable. SAF levy paid and evidenced. AMSR is the most common documented reason for 482 nomination refusal — audited carefully.
- Genuine position (482 / 186). Real role + business need + ANZSCO alignment + business capacity evidenced. A position description that doesn't fit the business's actual operations or financial capacity is one of the most consistent refusal patterns for small-business sponsors.
Partner visas (820 / 801, 309 / 100) — add 4
- Four-area framework coverage. Financial, household, social, and commitment evidence reviewed individually for adequacy and balance. Applications that cover three areas heavily and one area thinly are common refusal patterns.
- Cohabitation evidence consistency. Dates align between sworn statements, leases, joint utility account setup, joint bank account opening, and police check addresses. Inconsistencies in stated cohabitation start date are one of the most damaging silent failure modes.
- Sponsor eligibility & history. Citizenship / PR status verified. Prior partner sponsorships checked against the 5-year rule and 2-sponsorships lifetime limit. Sponsor character disclosure complete. Sponsor undertaking obligations explained to the sponsor in writing.
- Family violence provisions (if applicable). Where the relationship has ended due to family violence, evidentiary requirements per Regulations met — judicial or non-judicial evidence sufficient. This area has very specific procedural requirements; mistakes are expensive.
Student visas (Subclass 500) — add 3
- Genuine Student four-area framework. Immigration history / personal circumstances / chosen course / post-study intentions reviewed for coherence and internal consistency. Inconsistencies between any two areas are the primary GS refusal trigger.
- Financial capacity evidence. Tuition + OSHC + living costs + travel + dependants. Source of funds traceable (not just bank balance — where did the funds come from?). Sponsor capacity evidenced where the applicant is supported by a parent.
- Course choice rationale. Course aligned with the applicant's prior education and post-study plans. Specific written explanation for any progression that looks unusual — field changes, qualification level drops (e.g. Master's holder applying for a Diploma), long gaps between prior study and the proposed course.
Refusal-recovery / re-applications — add 2
- Original refusal-reason fix verification. Each ground cited in the original Department decision letter is specifically and demonstrably addressed in the re-application. A re-application that doesn't directly address the original refusal grounds is almost always refused again.
- Section 48 bar consideration (onshore). Whether s 48 applies to this fresh application and which visa subclasses remain available to lodge from within Australia. Misjudging s 48 can result in a refusal on procedural grounds before substantive review.
Sample audit excerpt
So you know exactly what you'll receive:
How it works — submission to delivery
- Submit the audit request. Use the form at the bottom of this page — visa subclass, lodgement target date, anything you're specifically worried about, and (optionally) a flag for expedited turnaround if your timeline is tight.
- You receive the document-collection email within 1-2 hours. Reply with your draft application, all supporting documents (CV, qualifications, references, police checks, English test, sponsor documents if applicable, relationship evidence if applicable), and the original decision letter if this is a refusal-recovery audit. Drive folder share or email attachments — whichever is easier for you.
- The audit runs. Standard turnaround is 24-48 hours from when I have a complete document pack (the clock doesn't start on partial submissions). Complex audits take 48-72 hours. Expedited turnaround available subject to capacity at +50%, by prior arrangement.
- PDF audit report delivered to your email. Risk-scored dimensions, ranked fixes, file-note ready for your matter file. Optional 30-minute follow-up call to walk through high-risk items (included in complex-audit tier; +$200 for standard tier).
- You action the fixes. You lodge. The matter is yours. The audit is your QA input, not a substitute for your judgment. Lodgement decision and timing entirely your call.
- Invoice on delivery. $800 + GST (standard) or $1,500 + GST (complex). Payable on 14- or 30-day account terms — your choice on the first audit, fixed on subsequent matters.
What's included — and what isn't
Included
- Full review of the draft application + every supporting document you provide
- Scoring against the relevant rubric for the visa subclass
- Written PDF audit report (typically 4-8 pages depending on complexity)
- Specific written fixes ranked by impact
- File-note format suitable for your matter file
- One round of clarifying questions by email if you want to discuss findings
Not included (unless arranged separately)
- Direct contact with your client (the audit is purely on documents you provide)
- Drafting of replacement evidence (we identify what's needed; you gather and draft it)
- Lodgement of any application (you lodge under your MARN)
- Representation at AAT / ART review hearings (separate engagement under written service agreement)
- Ongoing matter management or status updates (one-off audit per matter unless re-engaged)
- Legal advice on tax, financial, or non-migration matters
Compliance positioning — why this is safe
This service is structured as peer-to-peer professional quality assurance, paid for from your practice's funds. Specifically:
- The service is structured so that it does not constitute subcontracting under s 32 of the Migration Agents Code of Conduct 2022. I'm reviewing your application, not preparing it or any part of it.
- It is NOT dual representation. No solicitor-client / agent-client relationship is created between me and the end-applicant. Your client is your client throughout.
- It is NOT fee-sharing with the client. Your practice pays me a fixed fee from practice funds. No portion of the end-client's fees is shared with me.
- It IS a defensible record of pre-lodgement due diligence. Your matter file records that an external RMA pre-lodgement review was conducted on [date]; the audit report sits in the file. If the application is later refused and your client questions the lodgement quality, you have documented evidence of the QA process.
- Confidentiality applies (s 35 of the Code). I don't share matter details, applicant identities, or report contents with anyone other than you. I don't retain copies after delivery longer than required for professional record-keeping.
If your practice's PI insurer wants the arrangement documented, I can provide a one-page Memorandum of Understanding describing the audit scope, fee, confidentiality, and file-note structure. Most established practices don't request this; some new ones do. Either way is fine.
About the auditor
Keshab Chapagain · MARN 1576536
Registered migration agent practising from Office 6, 2-16 Anglo Road, Campsie NSW 2194. Practice focus concentrated in RPL submissions, 407 training plans, and 482/186 employer-sponsored work — with additional capacity on partner visa, student visa, and refusal-recovery matters under the pre-lodgement audit format. Available to fellow Australian RMAs for pre-lodgement review on a peer-to-peer basis.
PI insurance held under the Migration Agents Regulations 1998. MARN verifiable on the MARA Register. Code of Conduct 2022 and OMARA Consumer Guide available from MARA.
Pricing summary
- Standard audit: $800 + GST · 24-48 hour turnaround · most visa subclasses
- Complex audit: $1,500 + GST · 48-72 hour turnaround · refusal-recovery, character matters, PIC 4020-affected applications · includes 30-min follow-up call
- Expedited turnaround: +50% surcharge · subject to capacity, by prior arrangement
- Bulk packages · 10-audit pack at 15% discount for standing referrers · invoice monthly
- One-off review of complex evidence (no full audit): from $400 + GST · scoped per matter
Frequently asked questions
Is this subcontracting or a referral?
Neither. This is peer-to-peer professional quality assurance, paid for by your practice from practice funds. You retain the service agreement with the applicant, you retain the client relationship, you make the lodgement decision, and you lodge under your MARN. I provide a written audit and a defensible file-note. The end-applicant typically never knows the audit happened — your practice's matter file records that an external RMA pre-lodgement review was conducted on a specific date.
How is this different from just asking a colleague?
Three differences. First, it's structured against an 11-dimension refusal-pattern rubric — not a casual read-through. Second, it produces a written audit report that becomes part of your matter file as evidence of due diligence. Third, the turnaround is committed at 24-48 hours, not 'whenever I get to it'. Informal colleague reviews are valuable but unsystematic — this is a formal QA process.
Why $800 + GST?
Pricing is set at $800 + GST for standard audits because a refused $4,000+ visa application typically costs your client the application fee, often $2,500+ in ART lodgement fees, 6-12 months of distress, and frequently the relationship with the referring source. Set against the cost of even a single avoided refusal, the audit pays for itself many times over. Complex audits (refusal-recovery, character matters, PIC 4020-affected) are $1,500 + GST because they require materially more analysis time.
What turnaround can I commit to with my client?
24-48 hours from receipt of a complete document pack for standard audits. 48-72 hours for complex audits. If the matter is more urgent (e.g. lodgement deadline in 24 hours), expedited turnaround is available subject to capacity, by prior arrangement, at +50% surcharge. The clock starts when I have everything — incomplete submissions don't start the clock.
Do you contact my client?
Not unless you specifically invite me to. The audit is conducted entirely on the documents you provide. If a question arises that needs client clarification, I flag it in the report — you decide whether to action it. If you want me on a call with your client (for a specific technical question), that's billed separately.
What if you find serious issues — can my client refuse?
Your call entirely. The audit identifies risk; the lodgement decision is yours. Some agents use audits as cover for difficult client conversations ('an independent RMA has flagged X — we need to address it before lodgement'). Some use them as internal QA only and never disclose to the client. Both approaches are defensible.
Will the AAT / ART see the audit report if there's a refusal later?
Generally not, unless you choose to put it in. The audit is your internal work product — it's not part of the application file the Department holds. However, if you do choose to disclose it during ART review (as evidence that pre-lodgement risk assessment was conducted), the rubric-based structure makes it defensible as a professional QA process.
Is the audit confidential?
Yes. Standard professional confidentiality (s 35 of the Migration Agents Code of Conduct 2022). I don't share matter details, applicant identities, or report contents with anyone other than the referring agent. I don't retain copies after delivery for longer than required for professional record-keeping.
What if the audit is wrong about something?
The audit reflects my professional read of the documents you provide at the time of review. Migration law is dynamic and the Department's case officer ultimately decides outcomes. The audit is not a guarantee — outcomes can't be guaranteed by any RMA (s 15, Code of Conduct 2022). It's a structured second opinion. Your judgment as the lodging agent prevails.
Can I get audits at volume?
Yes. Standing arrangements for high-volume referrers (5+ audits/month) include pricing discounts, priority turnaround, and a simplified intake template that pre-populates the matter brief. Get in touch and we'll set up the arrangement.
Request an audit
Use the contact form at /contact or email info@widen.com.au with subject line "Pre-Lodgement Audit Request". Include visa subclass, lodgement target date, and anything you're specifically worried about. You'll receive the document-collection email back within 1-2 business hours.
Request a pre-lodgement audit →
Peer-to-peer professional service. Pre-lodgement risk audits are provided by Keshab Chapagain (MARN 1576536) to other Australian registered migration agents on a B2B basis. The audit is a structured second opinion on a draft application — it is not migration advice to the end-applicant, does not create a client-agent relationship between the auditor and the end-applicant, and does not transfer the underlying matter from the referring agent. Outcomes cannot be guaranteed by any registered migration agent (s 15, Migration Agents Code of Conduct 2022). Audit findings reflect the auditor's professional read of the documents provided at the time of review; migration law is dynamic and the Department's case officer ultimately decides outcomes. Confidentiality maintained under s 35 of the Code. PI insurance held under the Migration Agents Regulations 1998.