A file note is a written record of a conversation, made at the time or straight after it. For a registered migration agent it is not optional. The Code of Conduct requires you to make a contemporaneous written record of oral communications with a client about immigration assistance, including the client's oral instructions and your oral advice (section 55), and to keep those records on the client file (section 56). This guide explains what a good file note contains and gives you a free template to copy.
This is general information, not legal advice.
Why file notes matter
The Code requires them. Section 55 of the Code of Conduct for registered migration agents covers oral communications with a client. Section 56(2)(e) adds records of material oral communications with anyone else about the client, such as an employer sponsor, an education provider or the Department. Both belong on the client file, which you must keep for 7 years after the last action on it. See the full record keeping checklist.
Advice is usually given out loud. Most of the advice a client relies on is given in a meeting or on the phone. If the only record is your memory, it is hard to show later what you said, what the client told you and what they asked you to do.
Complaints and file reviews start with the file. OMARA can ask in writing for access to a client file (section 56(9)). A clear note written on the day is far more useful than a summary reconstructed months later.
Files change hands. When a colleague takes over a matter, or a client moves to another agent, the file notes are how the next person understands the history. Good notes save the next conversation from starting at zero.
What a good file note contains
A useful file note answers six questions: when, who, how, what was said, what was advised, and what happens next.
- Date, time and length. When the conversation happened, and roughly how long it took.
- Who took part. The client, anyone with them, the agent and any staff member. If an interpreter assisted, record their name and how they were engaged. The Code requires you to arrange an interpreter if the client asks (section 37).
- How. In person, phone, video call or another channel.
- What the client said. Facts they gave you and any change in their circumstances, in plain words.
- Instructions. What the client asked you to do, or not to do. Keep instructions separate from advice so the note is easy to read later.
- Advice given. The options you discussed, what you recommended, and any risks or deadlines you pointed out, such as a visa expiry date or a condition on their visa.
- Documents and fees. Documents received or requested, and any fees or costs discussed.
- Next steps. Each action, who owns it and when it is due.
- Author and time of writing. Your name, and when you wrote the note if it was not during the conversation.
Habits that keep file notes reliable
Write the note the same day, ideally straight after the call. Record facts and advice, not opinions about the client. Use the client's own words for key instructions. If a note is wrong, add a new dated note that corrects it rather than rewriting the original, so the history stays clear. For an initial consultation held before a service agreement is signed (section 43), make the note anyway: it records the advice you gave and becomes the start of the file if the client goes ahead.
Free file note template
Copy this template into your practice's system or document template. It is plain text, so it works anywhere.
FILE NOTE
Client name:
Client reference:
Matter / application:
Date of conversation:
Time and duration:
Method: in person / phone / video / other:
Participants (names and roles):
Interpreter (name, how engaged), if any:
WHAT THE CLIENT TOLD US
-
CLIENT INSTRUCTIONS
-
ADVICE GIVEN
Options discussed:
Recommendation:
Risks, deadlines and conditions explained:
DOCUMENTS
Received:
Requested (with due date):
FEES AND COSTS DISCUSSED
-
NEXT STEPS
Action | Owner | Due date
-
Note written by:
Date and time written:
Registered migration agent (name and MARN):Leave a section blank rather than deleting it. A blank "Advice given" section tells the reader no advice was given, which is useful in itself.
How to keep file notes in AgentDS
AgentDS keeps file notes where the rest of the client file lives, so the next person who opens the record sees them in context.
Add the note to the client record. Record case notes alongside the client's work, next to their applications, requested documents and fees. For application-specific points, track private notes on the application itself. See visa application tracking.
Read the history on the activity timeline. Every lead and client has an activity timeline showing calls, emails, follow-ups and notes. When a lead converts to a client, the timeline carries over, so notes from the first enquiry and the initial consultation stay with the client.
Turn next steps into tasks. Give each action from the note an owner and a due date. AgentDS sends a morning reminder email to the owner and the responsible person when a recorded task date reaches 90, 60, 30 or 7 days, or falls due. If the note records a visa expiry, record it on the client profile so it appears on the dashboard and in visa expiry tracking.
Paste the template. Keep the plain-text template above in a shared document, and paste it into each new note so every file note in the practice follows the same shape. Include the date, the author and the time of writing in the note text itself.
Control who sees it. Individual accounts, staff roles and case assignments control access to each client's records.
Keep your own copy. You can export all your data as a CSV file at any time, which helps when you plan how closed files will be retained for 7 years.
This is general information, not legal advice. Check the current Code of Conduct on the OMARA website and get advice for your own practice.
Frequently asked questions
Do registered migration agents have to keep file notes?
Yes. Section 55 of the Code of Conduct requires a contemporaneous written record of oral communications with a client about immigration assistance, including oral instructions and oral advice.
What should a migration agent's file note include?
The date, time and method, who took part (including any interpreter), what the client said, their instructions, the advice given, documents and fees discussed, and next steps with an owner and due date.
How soon should I write a file note?
The Code requires a contemporaneous record, so write it during the conversation or as soon as possible afterwards, ideally the same day.
Do I need file notes for calls with people other than the client?
Records of material oral communications with any other person or organisation about the client must be on the client file (section 56(2)(e)).
Where do file notes go in AgentDS?
On the client record as case notes, and they appear on the client's activity timeline with calls, emails and follow-ups. Notes made on a lead carry over when it converts to a client.