Category: DfE

  • What the saga of Oxford Business College tells us about regulation and franchising

    What the saga of Oxford Business College tells us about regulation and franchising

    One of the basic expectations of a system of regulation is consistency.

    It shouldn’t matter how prestigious you are, how rich you are, or how long you’ve been operating: if you are active in a regulated market then the same rules should apply to all.

    Regulatory overreach can happen when there is public outrage over elements of what is happening in that particular market. The pressure a government feels to “do something” can override processes and requirements – attempting to reach the “right” (political or PR) answer rather than the “correct” (according to the rules) one.

    So when courses at Oxford Business College were de-designated by the Secretary of State for Education, there’s more to the tale than a provider where legitimate questions had been raised about the student experience getting just desserts. It is a cautionary tale, involving a fascinating high-court judgment and some interesting arguments about the limits of ministerial power, of what happens when political will gets ahead of regulatory processes.

    Business matters

    A splash in The Sunday Times back in the spring concerned the quality of franchised provision from – as it turned out – four Office for Students registered providers taught at Oxford Business College. The story came alongside tough language from Secretary of State for Education Bridget Phillipson:

    I know people across this country, across the world, feel a fierce pride for our universities. I do too. That’s why I am so outraged by these reports, and why I am acting so swiftly and so strongly today to put this right.

    And she was in no way alone in feeling that way. Let’s remind ourselves, the allegations made in The Sunday Times were dreadful. Four million pounds in fraudulent loans. Fake students, and students with no apparent interest in studying. Non-existent entry criteria. And, as we shall see, that’s not even as bad as the allegations got.

    De-designation – removing the eligibility of students at a provider to apply for SLC fee or maintenance loans – is one of the few levers government has to address “low quality” provision at an unregistered provider. Designation comes automatically when a course is franchised from a registered provider: a loophole in the regulatory framework that has caused concern over a number of years. Technically an awarding provider is responsible for maintaining academic quality and standards for its students studying elsewhere.

    The Office for Students didn’t have any regulatory jurisdiction other than pursuing the awarding institutions. OBC had, in fact, tried to register with OfS – withdrawing the application in the teeth of the media firestorm at the end of March.

    So everything depended on the Department for Education overturning precedent.

    Ministering

    It is “one of the biggest financial scandals universities have faced.” That’s what Bridget Phillipson said when presented with The Sunday Times’ findings. She announced that the Public Sector Fraud Authority would coordinate immediate action, and promised to empower the Office for Students to act in such cases.

    In fact, OBC was already under investigation by the Government Internal Audit Agency (GIAA) and had been since 2024. DfE had been notified by the Student Loans Company about trends in the data and other information that might indicate fraud at various points between November 2023 and February 2024 – notifications that we now know were summarised as a report detailing the concerns which was sent to DfE in January 2024. The eventual High Court judgement (the details of which we will get to shortly) outlined just a few of these allegations, which I take from from the court documents:

    • Students enrolled in the Business Management BA (Hons) course did not have basic English language skills.
    • Less than 50 per cent of students enrolled in the London campus participate, and the remainder instead pay staff to record them as in attendance.
    • Students have had bank details altered or new bank accounts opened in their name, to which their maintenance payments were redirected.
    • Staff are encouraging fraud through fake documents sent to SLC, fake diplomas, and fake references. Staff are charging students to draft their UCAS applications and personal statements. Senior staff are aware of this and are uninterested.
    • Students attending OBC do not live in the country. In one instance, a dead student was kept on the attendance list.
    • Students were receiving threats from agents demanding money and, if the students complained, their complaints were often dealt with by those same agents threatening the students.
    • Remote utilities were being used for English language tests where computers were controlled remotely to respond to the questions on behalf of prospective students.
    • At the Nottingham campus, employees and others were demanding money from students for assignments and to mark their attendance to avoid being kicked off their course.

    At the instigation of DfE, and with the cooperation of OBC, GIAA started its investigation on 19 September 2024, continuing to request information from and correspond with the college until 17 January 2025. An “interim report” detailing emerging findings went to DfE on 17 December 2024; the final report arrived on 30 January 2025. The final report made numerous recommendations about OBC processes and policies, but did not recommend de-designation. That recommendation came in a ministerial submission, prepared by civil servants, dated 18 March 2025.

    Process story

    OBC didn’t get sight of these reports until 20 March 2025, after the decisions were made. It got summaries of both the interim and final reports in a letter from DfE notifying it that Phillipson was “minded to” de-designate. The documentation tells us that GIAA reported that OBC had:

    • recruited students without the required experience and qualifications to successfully complete their courses
    • failed to ensure students met the English language proficiency as set out in OBC and lead provider policies
    • failed to ensure attendance is managed effectively
    • failed to withdraw or suspend students that fell below the required thresholds for performance and/or engagement;
    • failed to provide evidence that immigration documents, where required, are being adequately verified.

    The college had 14 days to respond to the summary and provide factual comment for consideration, during which period The Sunday Times published its story. OBC asked DfE for the underlying material that informed the findings and the subsequent decision, and for an extension (it didn’t get all the material, but it got a further five days) – and it submitted 68 pages of argument and evidence to DfE, on 7 April 2025. Another departmental ministerial submission (on 16 April 2025) recommended that the Secretary of State confirm the decision to de-designate.

    According to the OBC legal team, these emerging findings were not backed up by the full GIAA reports, and there were concerns about the way a small student sample had been used to generalise across an entire college. Most concerningly, the reports as eventually shared with the college did not support de-designation (though they supported a number of other concerns about OBC and its admission process). This was supported by a note from GIAA regarding OBC’s submission, which – although conceding that aspects of the report could have been expressed more clearly – concluded:

    The majority of the issues raised relate to interpretation rather than factual accuracy. Crucially, we are satisfied that none of the concerns identified have a material impact on our findings, conclusions or overall assessment.

    Phillipson’s decision to de-designate was sent to the college on 17 April 2025, and it was published as a Written Ministerial Statement. Importantly, in her letter, she noted that:

    The Secretary of State’s decisions have not been made solely on the basis of whether or not fraud has been detected. She has also addressed the issue of whether, on the balance of probabilities, the College has delivered these courses, particularly as regards the recruitment of students and the management of attendance, in such a way that gives her adequate assurance that the substantial amounts of public money it has received in respect of student fees, via its partners, have been managed to the standards she is entitled to expect.

    Appeal

    Oxford Business College appealed the Secretary of State’s decision. Four grounds of challenge were pursued with:

    • Ground 3: the Secretary of State had stepped beyond her powers in prohibiting OBC from receiving public funds from providing new franchised courses in the future.
    • Ground 1: the decision was procedurally unfair, with key materials used by the Secretary of State in making the decision not provided to the college, and the college never being told the criteria it was being assessed against
    • Ground 4: By de-designating courses, DfE breached OBCs rights under Article 1 of the First Protocol to the European Convention on Human Rights (to peaceful enjoyment of its possessions – in this case the courses themselves)
    • Ground 7: The decision by the Secretary of State had breached the public sector equality duty

    Of these, ground 3 was not determined, as the Secretary of State had clarified that no decision had been taken regarding future courses delivered by OBC. Ground 4 was deemed to be a “controversial” point of law regarding whether a course and its designation status could be a “possession” under ECHR, but could be proceeded with at a later date. Ground 7 was not decided.

    Ground 1 succeeded. The court found that OBC had been subject to an unfair process, where:

    OBC was prejudiced in its ability to understand and respond to the matters of the subject of investigation, including as to the appropriate sanction, and to understand the reasons for the decision.

    Judgement

    OBC itself, or the lawyers it engaged, have perhaps unwisely decided to put the judgement into the public domain – it has yet to be formally published. I say unwisely, because it also puts the initial allegations into the public domain and does not detail any meaningful rebuttal from the college – though The Telegraph has reported that the college now plans to sue the Secretary of State for “tens of millions of pounds.”

    The win, such as it is, was entirely procedural. The Secretary of State should have shared more detail of the findings of the GIAA investigation (at both “emerging” and “final” stages) in order that the college could make its own investigations and dispute any points of fact.

    Much of the judgement deals with the criteria by which a sample of 200 students were selected – OBC was not made aware that this was a sample comprising those “giving the greatest cause for suspicion” rather than a random sample, and the inability of OBC to identify students whose circumstances or behaviour were mentioned in the report. These were omissions, but nowhere is it argued by OBC that these were not real students with real experiences.

    Where allegations are made that students might be being threatened by agents and institutional staff, it is perhaps understandable that identifying details might be redacted – though DfE cited the “”pressure resulting from the attenuated timetable following the order for expedition, the evidence having been filed within 11 days of that order” for difficulties faced in redacting the report properly. On this point, DfE noted that OBC, using the materials provided, “had been able to make detailed representations running to 68 pages, which it had described as ‘comprehensive’ and which had been duly considered by the Secretary of State”.

    The Secretary of State, in evidence, rolled back from the idea that she could automatically de-designate future courses without specific reason, but this does not change the decisions she has made about the five existing courses delivered in partnership. Neither does it change the fact that OBC, having had five courses forcibly de-designated, and seen the specifics of the allegations underpinning this exceptional decision put into the public domain without any meaningful rebuttal, may struggle to find willing academic partners.

    The other chink of legal light came with an argument that a contract (or subcontract) could be deemed a “possession” under certain circumstances, and that article one section one of the European Convention on Human Rights permits the free enjoyment of possessions. The judgement admits that there could be grounds for debate here, but that debate has not yet happened.

    Rules

    Whatever your feelings about OBC, or franchising in general, the way in which DfE appears to have used a carefully redacted and summarised report to remove an institution from the sector is concerning. If the rules of the market permit behaviour that ministers do not like, then these rules need to be re-written. DfE can’t just regulate based on what it thinks the rules should be.

    The college issued a statement on 25 August, three days after the judgement was published – it claims to be engaging with “partner institutions” (named as Buckinghamshire New University, University of West London, Ravensbourne University London, and New College Durham – though all four had already ended their partnerships with the remaining students being “taught out”) about the future of the students affected by the designation decision – many had already transferred to other courses at other providers.

    In fact, the judgement tells us that of 5,000 students registered at OBC on 17 April 2025, around 4,700 had either withdrawn or transferred out of OBC to be taught out. We also learn that 1,500 new students, who had planned to start an OBC-delivered course after 2025, would no longer be doing so. Four lead providers had given notice to terminate franchise agreements between April 2024 and May of 2025. Franchise discussions with another provider – Southampton Solent University – underway shortly before the decision to de-designate, had ended.

    OBC currently offers one course itself (no partnership offers are listed) – a foundation programme covering academic skills and English language including specialisms in law, engineering, and business – which is designed to prepare students for the first year of an undergraduate degree course. It is not clear what award this course leads to, or how it is regulated. It is also expensive – a 6 month version (requiring IELTS 5.5 or above) costs an eyewatering £17,500. And there is no information as to how students might enroll on this course.

    OBC’s statement about the court case indicates that it “rigorously adheres to all regulatory requirements”, but it is not clear which (if any) regulator has jurisdiction over the one course it currently advertises.

    If there are concerns about the quality of teaching, or about academic standards, in any provider in receipt of public funds they clearly need to be addressed – and this is as true for Oxford Business College as it is for the University of Oxford. This should start with a clear plan for quality assurance (ideally one that reflects the current concerns of students) and a watertight process that can be used both to drive compliance and take action against those who don’t measure up. Ministerial legal innovation, it seems, doesn’t quite cut it.

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  • Higher education mergers are a marathon not a sprint

    Higher education mergers are a marathon not a sprint

    When the announcement came last Wednesday that the universities of Kent and Greenwich are planning to merge, the two institutions did a fine job of anticipating all the obvious questions.

    In particular, announcing that the totemic decision has already been taken on who should lead the new institution – University of Greenwich vice chancellor Jane Harrington – was a pragmatic move that will save a great deal of gossip and speculation that could otherwise have derailed the discussions that will now commence on how to turn “intention to formally collaborate” to the “first-of-its-kind multi university group.”

    But even with that really tricky bit of business out of the way, there is still a lot to work through. Broadly those questions fall into two baskets: the strategic direction and the practical fine detail. Practicalities are important for giving reassurance that people’s lives aren’t about to radically change overnight; albeit there are inevitably lots of issues that are either formally unknown at this stage or which can only be tackled in light of the evolution of the final agreement and organisational structure.

    With that in mind, it is really worth emphasising that the notion of a “multi university group” is a brand new idea, given a conceptual shape in the very recent publication Radical collaboration: a playbook from KPMG and Mills & Reeve, produced under the auspices of the Universities UK transformation and efficiency taskforce. The idea of a “multi university trust” explored in that report, derived from the school sector, posits the creation of a single legal entity that can nevertheless “house” a range of distinct “trading entities” with unique “brands” each with an agreed level of local autonomy.

    It answers the question of how you take two (or more) institutions, each with their own histories and characteristics and find ways to create the strength and resilience that scale might offer, while retaining the local distinctive characteristics that staff, students, and local communities value and feel a sense of affinity to. It also, as has been noted in the coverage following the announcement, leaves an option open for other institutions to join the new structure, if there’s a case for them to do so.

    “It is very positive to see institutions taking proactive steps to finding new ways to work together,” says Sam Sanders, head of education, skills and productivity for KPMG in the UK. “The group structure proposed is a model we have seen be successful elsewhere, where brand identity is retained but you get economies of scale, meaning institutions can focus on their core activities while sharing the burden of the overheads. If it goes well it could act as a blueprint for other similar ventures.”

    Sam’s reflection is that establishing a new entity might be the most straightforward part of the process: “The complicated part is moving to a new model that simultaneously preserves the right culture in the right places while achieving the savings you might want to see in areas like IT, infrastructure, and estates. These are multi-year agendas so everyone involved needs to be prepared for that.”

    The long and winding road

    With lots to work through, it’s really important to step back, and give space to the institutions to work this out. Because the big picture is about mapping what that critical path looks like from single-institution vulnerabilities to strength in numbers – and that is a path that these institutions and their governing bodies are, to a large extent, carving out as they go, potentially doing the wider sector a service in the process as others may look to follow the same path in the future.

    “The sector response has been overwhelmingly positive,” says Jane Harrington, who is already fielding calls from heads of institution who are curious about the planned new model. Both Jane and University of Kent acting vice chancellor Georgina Randsley de Moura have experience with group structures in schools and further education, knowledge they drew on in thinking through the options for formal collaboration – starting with ten different possible models which were narrowed down to two that were explored in more depth.

    “We started with what we wanted to achieve, and then we looked for models,” says Georgina. “We kept going back to our principles: widening participation, education without boundaries, high quality teaching and research, and what will make sense for our regions. Inevitably there is some focus in the news around finances and that is an important part of the context, but this would not work if our universities didn’t have values and mission alignment.”

    “We also had examples in mind of where we don’t want to end up,” adds Jane. “You see mergers where the brand identity is lost and it takes a decade to get it back. We have, right now, two student-facing brands that are strong in their own right. And in five or ten years time it might be that we have four or five institutions that are part of this structure – we don’t think it would make sense for them to become part of one amorphous brand.”

    It’s frequently observed that bringing together two or more institutions that are facing difficult financial headwinds may simply create a larger institution with correspondingly larger challenges. So having a very clear sense strategically of where the strengths and opportunities lie, as well as the where risks and weaknesses might also be subject to force-multiplier effects, is pretty important at the outset.

    It’s clear that there is an efficiency agenda in play in the sense that merging allows for the adoption of a single set of systems and processes – an area where Jane is especially interested in curating creative thinking. But the wider opportunities afforded by scale are also compelling, especially in being more strategic about the collective skills and innovation offer to the region.

    Kent and Medway local councils and MPs have also responded enthusiastically to the universities’ proposal, the two heads of institution tell me – not least because navigating politics around different HE providers can be a headache for regional actors who want to engage higher education institutions in key regional agendas.

    “There are cold spots in our region where nobody is offering what is needed,” says Jane. “But developing new provision is much harder when you are acting alone. This region has pockets of multiple forms of deprivation: rural, urban and coastal. The capacity and scale afforded by combining means we can think strategically about how to do the regional growth work, and what our combined offer should be, including to support reskilling and upskilling.”

    Georgina makes a similar case for combining research strengths. “Our shared research areas, like health, food sustainability, and creative industries, play to regional strengths,” she says. “When research resources are constrained, by combining we can do more.”

    We can work it out

    The multi university group is not, in theory, a million miles from a federation in structure in that in federations generally there is a degree of autonomy ceded by the constituent elements to a single governing body – but in a federation each entity retains its individual legal status. A critical difference is the extent to which a sharing economy among the entities would have to be painstakingly negotiated for a federation, which could erode the value that is created in collaborating. It could also raise tricky questions around things like VAT.

    But the sheer novelty of the multi university group also raises a bunch of regulatory questions, covered in all the depth you’d expect by DK elsewhere on the site – to give a flavour, can you use the word “university” for your trading entity without that existing as a legal entity with its own degree awarding powers?

    The supportive noises from DfE and OfS at the time of the initial announcement should give Kent and Greenwich some degree of comfort as they work through some of these questions. The sector has been making the argument for some time now that if the government and regulator want to see institutions seizing the initiative on innovative forms of collaboration, there will need to be some legal and regulatory quarter given, up to and including making active provision for forms of collaboration that emerge without a legal playbook.

    Aside from the formal conditions for collaboration, how OfS conducts itself in this period will be watched closely by others considering similar moves. While nobody would suggest that changing structure offers an excuse for dropping the ball on quality or student experience – and both heads of institution are very clear there is no expectation of that happening – OfS now has a choice. It can choose to be highly activist in requesting reams of documentation and evidence in response to events as they unfold, from institutions already grappling with a highly complex landscape. Or it can work out an approach that offers a degree of advance clarity to the institutions what their accountabilities are in this time of transition, and how they can/should keep the regulator informed of any material risks arising to students from the process.

    Despite the generally positive response, there is no shortage of scepticism about whether a plan like the one proposed can work. The answer, of course, depends on what you think success looks like. Certainly, anyone expecting a sudden and material shrinkage in costs is bound to be disappointed. Decisions will be made along the way with which some disagree, perhaps profoundly.

    But I think what is often forgotten in these discussions is that the alternative to the decision to pursue a new structure is not to carry on in broadly the same way as before, but to pursue a different but equally radical and equally contentious course of action. If the status quo was satisfactory then there would be no case for the change. In that sense, being as useful as possible in helping these two institutions make the very best fist that they can of their new venture is the right thing for everyone to do, from government downwards.

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  • The trouble with the latest accreditation round for initial teacher education

    The trouble with the latest accreditation round for initial teacher education

    English teacher education has been the subject of ongoing and turbulent policy change for many years. But the radical shift in agenda instigated by the Department for Education (DfE) market review between 2022 and 2024 brought this change to another level. The policy instigated a reaccreditation process for all initial teacher education (ITE) providers awarding qualified teacher status.

    The Conservative government’s attempt at “delivering world-class teacher development” ended up decimating the landscape of ITE, leaving those of us left to pick up the pieces. Now DfE has opened a second round of the accreditation process – has it learned any lessons?

    What went wrong

    Stage 1 of the process the first time around included a written proposal of over 7,000 words outlining compliance with the new standards, including curriculum alignment to the ITE core curriculum framework. Additional details and evidence of partnership and mentoring systems and processes also had to be included. Successful applicants progressed to stage 2. Here, rigorous scrutiny of further preparation and plans began, with each institution being allocated a DfE associate to work with for a further twelve months.

    The additional workload this required stretched the capacity and resources of all education departments within higher education institutions. Academics were simultaneously delivering ongoing provision, continuing recruitment, and writing additional postgraduate (and for many undergraduate) revised provision – and many were under the threat of redundancy. All of the above, under constant threat of looming Ofsted visits.

    A previous Wonkhe article likened to the process to the Netflix series Squid Game, using the metaphor to describe the experience for existing ITT providers – meet the confusing demands and conflicting eligibility requirements, or you’re out.

    A significant number of providers failed to secure accreditation, either losing or giving up their status, with provider numbers reducing from 240 to 179.

    At the time the sector offered collegiate support, forming working groups to foster joint responses when collating the sheer volume of output required. Pressures surfaced including stress and anxiety caused by the increase in workload. Insecurity of jobs and the conflicting and at times confusing advice brought many individuals to the point of exhaustion and burnout.

    Squid: off the menu?

    You would therefore expect an announcement of the opportunity for providers to re-enter the market to be met with a sense of joy. Wouldn’t you?

    However, the new round is only for any lead provider currently working in partnership with an accredited provider. These partnerships are only in their first year and were encouraged by the DfE because of the “cold spots” created when thirteen higher education institutions failed to pass the previous process – despite having proven a history of quality provision.

    The creation of such partnerships added yet more stress and workload to all concerned. No legal advice on governance was provided. They proved incredibly complex to navigate, requiring long standing buy-in to make them workable and financially viable. As of yet no advice has been published of how to exit these partnership arrangements.

    Providers wishing to begin delivering ITT from September 2026 must meet the eligibility criteria. The window for the applications will be open for a much shorter period than the previous round, with the process and outcome to be completed 30 June 2025. This contrasts to the 18 months previously required for providers to demonstrate their “market readiness” in the previous round.

    Stage 1 of the new process will include a written submission of no more than 1500 words – remember, it was 7,000 last time – with applicants submitting a brief summary of their ITT and mentor curricula. In this short piece they will need to “demonstrate how their curriculum meets the quality requirements in the ITT criteria.” A window across March and April 2025 was open to complete and upload this portfolio.

    Stage 2, this time round, is an interview, where applicants “deliver a presentation to a panel, and answer questions further demonstrating how they meet the quality requirement.” Following both the written and verbal submissions, an assessment will be made and moderated by panels of ITT experts.

    For those still haunted by the lived experience of the first round of ITT accreditation, the greatly reduced stringency of the process would appear to make a mockery of the previous, highly controversial, demands and expectations.

    Like last time, success in the accreditation will require a demonstration of compliance with the expectations of the core curriculum framework (or from September, the ITTECF) along with further DfE quality requirements through submission.

    However, unlike last time, prospective providers will not be required to create extensive written responses, detailed curriculum resources or an extensive mentor curriculum (for which many of the requirements were axed overnight in the government’s announcement in November).

    Unbalanced

    How can the two contrasting timelines and expectations possibly be seen as equitable or comparable?

    In addition, how can we guarantee a smooth transition between lead partners and current accredited providers? Some of these partnerships involve undergraduate provision, established as a result of “rationalising” ITT provision. For those students only in year one of a three-year degree, how will this transition work?

    As a sector we recognise that the policy is aimed at meeting the government target of recruiting an extra 6,500 teachers this sitting parliament. And we welcome our peers back into the fold. Many of us are still reeling from the injustice of those colleagues being locked out in the last round (at the time all rated good or better by Ofsted).

    However, as NFER’s recent teacher labour market report pointed out, teachers’ pay and workload remain the highest cited reasons for ongoing difficulties in recruitment and retention. Neither of these things have been addressed by the new accreditation process.

    For those of us still clinging on for dear life, our confidence in the system is fading. One day, just like our stamina and resilience, it will evaporate all together.

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  • Your 2025 higher education policy almanac

    Your 2025 higher education policy almanac

    Well, it’s January again.

    The early months of last year were dominated by the Conservatives’ slow swan dive into electoral oblivion, and then we got a general election that saw little serious discussion of the sector’s future, aside from the trotting out of a few old canards.

    And since Labour took power in July, there have been two broad phases: an initial “these things take time” framing in which universities – as well as many other groups and industries – were asked to be patient. In November we got the tuition fee uplift in England (in cash terms, for one year) and news of a bigger reform plan due next summer. A little movement, but in grand terms it was still can-kicking. Even the concrete announcements we’ve had, such as on level 7 apprenticeships, have not been accompanied by detailed policy papers or formal consultations.

    There’s reason to think that 2025 will have more for wonks to get their teeth into. There’s plenty pending, promised, or otherwise pretty damn urgent. So the below is an attempt to reckon with absolutely everything we know is on its way that matters for HE. Please charitably ascribe any oversights to a post-holidays sugar crash on my part rather than wilfully turning a blind eye, and let me know what I’ve missed in the comments.

    Big ticket items

    In Westminster politics, the first half of next year is going to be completely dominated by the spending review, which will set departmental budgets for three financial years (2026–29) as well as lay out a five-year programme of capital spending. It has always been described as being “in the spring”, but recent reports suggest that Labour will fly as close to the summer solstice as they can with this definition, so make sure you’ve got some free time in June to deal with the fallout.

    If what we read in the papers is to be believed, what is – counterintuitively – the default policy of inflation-linked tuition fees will be confirmed for England at this point, taking us up over £10,000 a year by the end of the Parliament.

    This is also when we’ll hear more about the government’s plans for ten-year R&D budgets. Attendees of the 2023 Labour conference may recall science secretary Peter Kyle promising a decade of confirmed funding for UKRI and ARIA – this commitment has been repeatedly qualified since then, partly due to issues of practicality (given that it’s not a ten-year spending review) and partly due to a question mark over whether fixing research spending in this way is really a good idea. It’s likely to be restricted now to “specific R&D activities” – the (much) bigger question will be around levels of investment in R&D. Plus we’ll see to what extent the government really wants to commit to linking research and its missions – last autumn brought only a small pot of cash for this in 2025–26.

    Also due alongside the spending review is “further detail and plans for delivery” for the Lifelong Learning Entitlement – so don’t expect to hear much more before then, though the delayed commencement in 2027 makes the need for information marginally less pressing. And the finalised industrial strategy will also arrive, “aligned with” (and likely published together with) the spending review, laying out specific sector plans for areas like the creative industries, the life sciences, and professional services. Once complete, the idea is that these plans can then inform Skills England’s work, and potentially migration policy – it’s all very ambitious.

    The HE reform announcement in England that we’ve been promised for “the summer” will land – it appears – fairly hot on the heels of the spending review settlements, and any money needed for it will need to have been allocated already, or at least tucked in to Office for Budgetary Responsibility (OBR) projections in some way. On the topic of the OBR, its spring forecast is due on 26 March – there are rumblings that its revised projections could spell fiscal trouble for the government.

    There are also clear indications that the HE reform statement will be preceded, or possibly accompanied, by a review of some kind. There have been rumours of a panel in place, and the indications are that this will fly under the radar somewhat and happen quickly – think Becky Francis’ curriculum review or Lord Darzi’s NHS audit, rather than a grand commission in the traditional “major review” style we have become used to.

    Around the sector

    Part of the Westminster government’s reform agenda is predicated on the sector coming up with ideas itself, which may end up drawing quite a lot on Universities UK’s blueprint from back in September. UUK’s own “efficiency and transformation taskforce” will be busy putting out recommendations on business models and collaboration, with the endorsement of education secretary Bridget Phillipson – “all options are on the table,” we are told, with plenty of policy debate likely to ensue once publications begin to appear.

    With many universities in poor financial shape, the search for longer-term sustainability will likely be derailed at regular intervals by news of redundancies and course closures. National industrial action is a possibility, though there are real questions around the willingness of struggling union members to take action on pay at this point. Local disputes will continue to flare up. Alongside this we have a renewed push for newer English universities to be exempted from the Teachers’ Pension Scheme due to the massively increased costs it is now carrying, a move which would substantially inflame industrial relations if it came to pass.

    And looming over all of this is the possibility of a disorderly market exit, and the question of whether the government has a viable plan in place to step in if a large institution were to hit the wall. All the other policy developments we are highlighting here could be hugely complicated by a sudden shock to the system and what is likely to be a political rather than a strategic response.

    The world of regulation

    There’s a lot to look out for from the Office for Students, from the appointment of a new permanent chair down (interviews are being held this month).

    There’s the ongoing consultation on a new strategy, the continuing fallout from the temporary closure of the register (this should supposedly also bring new proposals on improvements to the registration process), whispers of a more “integrated approach” to quality and whatever that means for the TEF, and a greater regional focus to access and participation.

    We should start getting assessment reports for the second round of quality investigations (where franchising and foundation years will be a focus) as well as the belated release of those grade inflation investigations that were announced on 2 September 2022. We’re waiting for consultation responses on a new approach to public grant funding and even on LLE regulation, though you can’t blame them for waiting to see what exactly the government is planning with this one.

    According to last summer’s business plan, there should also be consultations of potential new initial conditions of registration on both management and governance, and consumer protection. And this year’s National Student Survey will have a sexual misconduct questionnaire appended – though it’s not clear at time of writing to what extent the results will be made public.

    Over in Wales, Medr is taking shape, with a finalised strategic plan due to have been submitted to the Welsh government for approval just before the Christmas break – we should hear more of this soon, along with the consultation response.

    And if all that sounds like a lot, in Scotland we are due a Post-School Education Reform Bill at some point in the 2024–25 parliamentary session, which will make big changes to how the Scottish Funding Council (SFC) and Student Awards Agency Scotland operate. A consultation which closed in September asked stakeholders for thoughts on what the funding agency landscape should look like – we haven’t heard much since then. The sector is keen to stress the importance of universities retaining their autonomy, whatever happens – legislative passage could see MSPs push for new duties on the SFC.

    We’ve been aware for a long time that the Office for National Statistics is undertaking a review into whether higher education should be seen as “public sector” in the national accounts – it’s now been slightly rejigged into a review of the statistical classification of “the transactions in which UK universities engage.” For what is a very technical definition, an eye over the recent travails of the FE sector suggest that there are potential implications for everything from procurement to senior staff pay. The long delayed work will kick off early in 2025.

    The research agenda

    What little research policy we’ve seen come out of the new government so far has been limited to haggling over budgets and science minister Patrick Vallance stressing that ministers should not meddle in university research. There’s no reason to think we will get big policy pronouncements out of the Department for Science, Innovation and Technology, which feels more interested in the tech and digital side of its remit, both legislatively and aesthetically. But there’s lots going on around the margins that could end up being quite consequential.

    First up we have the appointment of a new UKRI chief executive, where there’s already evidence the new minister has been having a think about longer term strategic direction. While the new roleholder won’t take up office until June, we should get news of the appointment fairly soon.

    In the Research Excellence Framework world, the “modular” approach to releasing different policies on a staggered timetable will see the release of the volume measure policy (imminently) and the contribution to knowledge and understanding policy (scheduled for the summer). The more contentious people, culture and environment pilot will continue throughout the year, with criteria and definitions due for the winter – any slippage on this will likely provoke controversy.

    At UKRI, January will bring an update on its work reviewing how PGR stipends are set (as well as the stipend level for 2025–26). Elsewhere, the ongoing National Audit Office work looking at UKRI grants and loans could be a wildcard – it’s due to report in spring 2025 – and at the very least is a moment where the government will need to comment on how the research funding system is operating. Research England is also thinking about the current state of research infrastructure, via its condition of the estate survey, and how the sector’s financial challenges are affecting research – for both of these pieces of ongoing work, it’s doubtful that much will be shared publicly.

    Further afield, a European Commission proposal for the successor to Horizon Europe is due midway through the year, preceded by an interim evaluation of the current funding programme which will likely give an indication of its plans. We will also get regulations for the Foreign Influence Registration Scheme in the new year – the measures, which will speak to research security, are now expected to come into effect in the summer. It’s been reported that the government is resisting calls to put China on the “enhanced tier” of the scheme, a move that would have greatly complicated UK-China academic partnerships. On a related note, the government has quietly been conducting a “China audit” – this will be released in the coming months, and in theory will spell out the policy areas where closer ties will be permitted.

    Finally, the House of Commons Science, Innovation and Technology Committee will be conducting a timely inquiry into regional R&D, which should be a good opportunity for some more insight into how the government’s English devolution-related plans for more mayoral involvement in the research system will come together.

    International

    If you had to pick a policy area that will have the biggest macro impacts on the sector in 2025, you could do a lot worse than opt for international recruitment (you would arguably have been proved right if you’d chosen it in any of the last few years).

    Two big policy items are on their way here: a legal migration white paper, spelling out how the government will fulfil its electoral promise to bring net migration down. And a revised international education strategy (IES), which we’re told is coming “early spring” – whether it will appear before, after, or alongside the white paper remains to be seen, but could be significant.

    The big questions here are whether the government will put a recruitment target on the face of the strategy – the aspiration for 600,000 students in the last one ended up coming back to haunt the Conservatives among their own base – and what the plan for education exports targets might be. But there are other areas we could see movement, such as on post-study work, where some in the sector seem hopeful that a little improvement could be on offer, despite the enormous political pushback the Graduate route has faced over the last couple of years. It feels like an outside bet.

    More important to keep an eye on will be whether some kind of arrangement is arrived at with net migration statistics – we know that the Office for National Statistics is looking at how estimates excluding students could be arrived at, and it’s been on the higher education sector’s wishlist for years.

    If it did come to pass, the devil would very much be in the detail – the Migration Advisory Committee annual report has already been noting the contribution that students make to long-term net migration, and Starmerite think tank Labour Together’s recent proposal is for visa routes such as Skilled Worker and Graduate to have multi-year targets, even if the Student visa does not. Put like that, it sounds like a recipe for universities to recruit pretty freely but for students’ post-study options to remain a political football – the seeming lack of student involvement in the IES review would appear all the more glaring in this case. The Universities UK blueprint did promise a kind of quid pro quo on responsible international recruitment, and it has been notable that government ministers have stressed the importance of housing availability when the question has come up in Parliament recently.

    Whatever comes out of it, it looks clear that the Home Office will continue to toe a careful line on student visas, and continue to implement the last government’s Graduate route review response. The use of “action plans” by UKVI for certain providers will continue, even if there is no substantive public comment from the Home Office about what these are and why they are being imposed. And there will also be a review of English language self-assessment policies over the next few months, “driven by growing concern around underlying reasons for reports of students being picked up at the border or entering UKHE with low levels of English” (in UUKi’s words). It’s unlikely much will be shared publicly about these, but they are items to watch, especially in the event that there is further negative publicity about international students in the media.

    It’s worth stressing that developments in migration and visa policy do not only affect students – the House of Lords Science and Technology Committee is next week highlighting the interplay between visas and international researchers, and there are ongoing issues such as the future of the family visa income threshold where the government will eventually need to take a position.

    And despite all this policy in play, the three most significant factors for future international recruitment with likely be the Australian federal election – where the incumbent government’s attempts to impose number caps have been thwarted by an opposition that wants bigger caps – the Canadian election – which could happen at any minute if Justin Trudeau is forced out, and where the Conservatives are strongly favoured to take power – and the impact of Donald Trump on the USA, where universities are already reportedly asking international students to return before he takes office. All these things have the potential to greatly benefit the UK “market”.

    Skills, skills, skills

    Before we get any HE reform news out of Westminster, there’s going to be policy elsewhere in the post-compulsory system, with Skills England gearing up for action – we’ll learn the appointments of chief executive and permanent chair pretty soon – and various policy pronouncements at this end of the tertiary sector are overdue.

    Probably the most impactful for higher education is confirmation about exactly what is happening with the apprenticeship levy, both in wider terms of the planned additional flexibility for non-apprentice courses (this will be less than the 50 per cent originally proposed… at least probably), and for the “defunding” of level 7 apprenticeships.

    Many universities are big operators in this space, and it appears that most if not all of these programmes will be removed from the levy’s scope (“a significant number” is the most recent framing from the government). Over Christmas the Telegraph reported that the much-feted doctor apprenticeship is now “paused in perpetuity”. We should get the full picture very soon, as well as the much-awaited post-16 strategy, which you would hope would give a decent insight into the government’s wider vision for tertiary education. Though it may not.

    The defunding of level 7 apprenticeships is also relevant for those higher education institutions that have been spending their levy contributions on such courses for their staff as part of their professional development offer. DfE assures us all that employers are more than welcome to pay for them using different funds, “where they feel they provide a good return on their investment.”

    Our world in data

    We’re getting the outcome of the Data Futures review soon! There may be some lessons to learn about programme management and platform delivery, which could play out as a shared commitment to improving processes or as an unedifying multi-agency row. Whatever the case, this year’s HESA Student data will arrive later than usual – “in the spring, earlier than last year’s August publication but later than the January release date achieved in previous years.” Whether this is spring as in daffodils, or spring as in spending review, remains to be seen – but the delay (and issues with data quality as we saw last year) will have a knock on effect on data releases elsewhere, once again.

    At the end of this month we are getting HESA Staff data for 2023–24. The headline figures from last year’s release did get quoted the odd time by the previous government – in answer to questions about the impact of redundancies and cuts, it would occasionally be pointed out by ministers that (academic) staff numbers were still rising when you look at the sector as a whole. These figures won’t show the impact of this academic year’s cuts, however.

    Of course, elsewhere we have the usual releases which make up the HE wonk’s annual working rhythm. UCAS end-of-cycle numbers, at provider level, are due out at the end of January, and further down the line (probably around spending review time!) we have HESA Finance data and the Office for Students’ accompanying financial sustainability report, which will likely once again be a moment of maximum attention for higher education’s bottom line.

    One other piece of data we are getting this spring is a new ONS release on student suicides. This will come alongside the independent review commissioned by the last government, and whatever the findings is likely to generate a lot of press coverage and renewed pushes from campaign groups and opposition parties for a statutory duty of care. Early indications from the current government is that they are happy with the voluntary, sector-led approach to mental health – but things can change.

    Elsewhere in government

    It’s amazing it’s taken us this long to get to it, but probably the biggest, most controversial item on DfE’s to-do list is a decision on the fate of the free speech act and its associated provisions and complaints scheme. The Free Speech Union has its day in court on 23 January as part of a legal challenge over the pausing of the bill’s commencement – it’s just possible that the government will try to get a decision out before then. Or it could all drag on intractably for several more months, very much in keeping with the legislation’s passage through Parliament.

    Another hugely consequential move which we may see from DfE this month is the launch of a consultation on proposals to “strengthen oversight of partnership delivery in higher education” in conjunction with OfS. The department “will be developing options for legislative change, if required,” the Public Accounts Committee was told back in September, with a target date of January 2025 for an update.

    We’re due impact assessments and regulations for the tuition fee and maintenance “increases”, which should also involve a government pronouncement on how much the national insurance increase will cost the sector. And while it’s not higher education business, the soon-to-appear curriculum review (covering the curriculum in England from key stage 1 to key stage 5) will have long-term consequences for the wider education system – as well as likely sparking further backlash among those worried about it recklessly promoting diversity and risking PISA scores.

    Elsewhere in Westminster, the ongoing parliamentary passage of massive pieces of legislation will have big consequences for universities and students. The Employment Rights Bill and the Renters’ Rights Bill will both likely see some amendments, and we’re still awaiting the text of the English Devolution Bill and the promised “Hillsborough” bill. The government’s NHS plan for change – again, due at some point in the spring – and proposed updates to the NHS Long-Term Workforce Plan are important to keep an eye on as well.

    Up in Scotland, one day we may see the fruits of the ongoing review of student maintenance for part-time students. Negotiations over the 2025–26 budget will dominate the parliamentary agenda in the early part of the year, with ministers appearing in front of committees to get into the details of what exactly will be funded and what will not – and then the countdown to 2026 elections begins (all of this sentence is also true in Wales).

    It’s dangerous to go alone – take this

    If you’ve made it this far, congratulations. It feels like there is currently a huge number of moving parts in play in policy-land, all of which will contribute to the future shape and operations of the UK higher education sector in various, often hard-to-predict ways. Some are pretty immediate, others are issues that should have been tackled long ago, and then there are long-term policy changes that will be massive news in the 2030s.

    Here at Wonkhe we try to cover every single policy development that affects the sector, especially in our Daily Briefings (which restart on Tuesday 7 January – my alarm is already set).

    So if you’re interested in following even a fraction of the stuff that’s set out above, do join us for the ride this year. And fair warning, it’s likely that a good number of the most important developments that 2025 has in store for us are not even on this list. We’ll cover those as well, the moment they arrive.

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