DIBP must come clean: is it encouraging unregistered practice?

A recently introduced government instrument indicates that the department of immigration has an agreement in place with ‘agents’ in China for the purposes of lodging internet applications. On the face of it, the instrument gives recognition to unregistered practice in China because it fails to make the distinction between registered and unregistered practitioners in its wording. It would be good to know if any readers here are aware of (or party to) this agreement and if the agreement includes unregistered practitioners.
The recently introduced instrument IMMI 14/104 makes internet applications compulsory for certain types of tourist visa applications from China. Particularly, the instrument states as follows,
“that form 1419 (Internet) must be used by persons applying for a Subclass 600 (Visitor) visa who:
(a) hold a passport issued by a country specified in column 1 of Schedule A and subject to the conditions (if any) specified in column 2 of Schedule A; and
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