It’s been over six years since the last International Education Strategy.
We now have a new one – with three core ambitions, including to “sustainably recruit high-quality international students.”
But this isn’t really the higher education international education strategy. That’s to come.
The government’s approach to international student recruitment in HE is parked almost entirely to the Education Sector Action Group (ESAG) – a sector-led body tasked with producing an action plan for higher education.
If nothing else, that should be a good opportunity to get some actual international student voices into the mix – they’ve been notably absent from previous iterations and are hard to find in this high level document too.
The published strategy commits to “work with the sector” through ESAG on student experience, quality outcomes, housing, infrastructure, support systems, and responsible recruitment. The details will follow.
Since I last looked at a bunch of strategies from “competitor” countries, I’ve continued to keep an eye on what other countries commit to – and so the question remains – what should be in the higher education action plan when it arrives?
Graduate outcomes
The published strategy promises “world-class outcomes for graduates” through ESAG working with institutions, though it doesn’t specify what targets or baseline measurements ESAG should develop – so what have other countries committed to?
The UK collects some international graduate outcomes data through the Graduate Outcomes survey, but coverage is poor and deteriorating – response rates for non-UK students stood at just 11 per cent in 2021/22 compared to 51 per cent for UK students, and in 2021, HESA stopped telephoning international graduates to follow up non-responses, a cost-saving measure that further reduced data quality.
Back in 2019, the then education secretary wrote that:
…it will be critical to ensure the OfS makes public transparent data on the outcomes achieved by international students.
But five years later, the UK still lacks robust, representative data on where international graduates end up or whether they’re employed.
Recent Graduate Outcomes data shows rising dissatisfaction among international students, particularly at postgraduate level, with nearly 30 per cent of non-EU postgraduates reporting they’re not using what they learned. But with response rates so low, it’s unclear whether this represents the full picture or just a particularly dissatisfied minority who chose to respond.
Finland sets explicit retention targets and tracks employment rates post-graduation, with ministry data showing improvement over time and explicitly linking recruitment to national R&D targets and skilled worker shortages through the internationalisation programme and global networks and accompanying strategy document.
Ireland’s Global Citizens 2030 lists specific indicators – retention, graduation and first employment of international learners, employer satisfaction, and mobility rates – all monitored and reported, as detailed in the IUA publication. Germany’s strategy on the internationalisation of higher education institutions references federal skilled worker shortages and notes international graduates are “particularly attractive for the German labour market”, with DAAD data showing retention rates among the highest in the OECD alongside Canada.
The Netherlands publishes detailed stay rates through Nuffic research, tracking both immediate post-graduation employment and five-year retention, with the government explicitly noting housing as a major barrier to retention. France’s Cour des comptes found in March 2025 that tracking was inadequate, recommending systematic cohort studies in its evaluation of attractiveness and accompanying synthesis report.
Perhaps ESAG’s action plan should commit to systematic, robust tracking of international graduate outcomes with adequate response rates.
Student wellbeing
The strategy says government will “work closely with the sector” through ESAG on student experience and quality outcomes, but doesn’t specify what this means in practice – so what binding or voluntary frameworks have other countries established?
Ireland’s International Education Mark creates statutory requirements through its QQI Code of Practice – providers must designate appropriate personnel for learner support, establish mechanisms for emergency financial support, foster a supportive wellbeing environment, create feedback mechanisms, provide intercultural competence training for staff, and maintain written agent agreements, while QQI assesses compliance through panels, and authorisation can be refused, conditioned, or revoked.
Australia’s National Code under the ESOS framework requires registered providers to give students information about support services and offer reasonable support at no additional cost – providers must have documented critical incident policies, provide information on employment rights, give pre-enrolment information on living costs and accommodation, and ensure appropriate arrangements for under-18s, while breaches can suspend or cancel registration, and the Tuition Protection Service provides refunds if providers fail, as set out in the legislation.
Finland’s SIMHE network provides integrated support including Finnish language training, career guidance, and recognition of prior learning, though participation is voluntary for institutions. Germany’s Campus Initiative funds projects supporting the full student lifecycle from recruitment through to labour market transition. Latvia conducts annual international student satisfaction surveys. Ireland explicitly lists student satisfaction as a performance indicator alongside retention and employment outcomes.
France’s Bienvenue en France Label certifies institutions demonstrating quality welcome services, assessing institutions across six areas – information quality and accessibility, reception facilities, teaching accessibility and support, housing and campus life, post-graduate follow-up, and environmental sustainability – where institutions receive ratings from one to three stars based on performance against 28 indicators, and as of October 2025, 180 institutions hold the label, enrolling 65 per cent of international degree-seeking students. France also operates a €10 million fund supporting institutions to meet label standards.
Ireland’s International Education Mark operates differently – providers recruiting non-EU/EEA learners requiring study visas must obtain the mark, making it a regulatory requirement rather than voluntary certification, branded as “TrustEd Ireland” and backed by statutory quality standards.
Maybe ESAG should recommend binding student experience requirements with compliance monitoring, or at least quality standards or voluntary certification recognising institutions demonstrating excellence in international student experience.
Before arrival
The strategy says government will “encourage” the Agent Quality Framework to “help tackle the risk of poor practices”. Beyond that, the strategy doesn’t specify pre-arrival or onboarding requirements, leaving these to institutional practice – but what have other countries mandated or encouraged?
Finland’s Agent Code of Conduct was jointly developed by sector bodies, including ethics requirements, through non-binding voluntary adoption. However, following a December 2024 investigation by national broadcaster Yle which uncovered evidence that third-party agents were spreading false and misleading information to prospective students about work opportunities and living costs, the Finnish government has announced further work.
Under the proposals, students would only be permitted to use agents that have formal agreements with Finnish universities, and those will be more closely monitored. Ireland’s IEM Code requires written agent agreements incorporating ethics with termination clauses, enforced by QQI. Australia’s ESOS framework creates legally binding agent conduct requirements with sanctions, and Germany’s National Code includes a complaints mechanism where institutions designate a complaints body with unresolved disputes going to mediation, while agents must comply and can be dismissed for violations.
Australia’s National Code requires providers to give pre-enrolment information on living costs and accommodation options before students arrive. Ireland’s IEM Code requires providers to give clear information on fees, accommodation costs, insurance requirements, and subsistence costs prior to enrolment, alongside tailored inductions meeting international learner needs.
Germany’s National Code establishes minimum standards for pre-arrival information, though compliance is voluntary with a complaints mechanism for disputes. France’s Bienvenue en France Label assesses quality of pre-arrival information and reception facilities as part of institutional certification.
Finland provides preparation through the SIMHE network, though not all institutions participate. The Netherlands acknowledges international students face immediate housing needs creating vulnerability to discrimination, but has no binding pre-arrival housing guarantee requirement.
Standards for pre-arrival information and onboarding support would be very much appreciated by the international students I’ve talked to.
Costs are a big concern. France operates VISALE – a free government-backed rental guarantee for students covering rent up to €1,500 monthly in Paris and €1,300 elsewhere, universally available to international students with residence permits who are also eligible for CAF housing benefits.
Australia requires providers to give pre-enrolment information on living costs, and Ireland requires providers to inform students about average costs including accommodation, food, transport, and medical care.
Even if cost of living support mechanisms can’t be mandated, minimum transparency requirements about true costs would be very welcome.
Working while studying
The strategy doesn’t address during-study work rights or employer connections, though these differ from post-graduation pathways – what approaches have other countries taken?
Finland permits students to work 30 hours weekly as a yearly average. Germany allows 140 full days or 280 half-days yearly, increased from 120 and 240 in March 2024, or 20 hours weekly. France permits 964 hours yearly, approximately 60 per cent of full-time work.
Sweden permits work during studies with recent changes to work permit portability. Germany’s Campus Initiative explicitly funds projects covering recruitment through labour market transition, integrating employer connections throughout study. Finland’s Talent Boost programme integrates career services and employer connections with language training.
France’s “Invest Your Talent in Italy” programme includes mandatory internship components. Ireland includes employer satisfaction with international graduate competencies as an explicit performance indicator. Australia’s National Code requires providers to inform students about employment rights and Fair Work Ombudsman access.
International students would commitments in this space to be very welcome indeed.
Institutional commitments
Ireland’s International Education Mark creates statutory requirements through its QQI Code, which mandates designated personnel for learner support, mechanisms for emergency financial support, supportive wellbeing environment, feedback mechanisms, intercultural competence training, and written agent agreements incorporating ethics with termination clauses, alongside a Learner Protection Fund for provider failures, while QQI assesses compliance through panels, and authorisation can be refused, conditioned, or revoked.
Australia’s National Code under the ESOS framework requires information on support services, reasonable support at no additional cost, documented critical incident policy, information on employment rights, pre-enrolment information on living costs and accommodation, and appropriate arrangements for under-18s, while breaches can suspend or cancel registration, and the Tuition Protection Service provides refunds if providers fail.
Canada’s federal strategy expired unreplaced, but British Columbia implemented provincial standards requiring minimum in-person delivery, institution-controlled locations, and information about academic and housing support. Germany’s National Code establishes minimum standards for information, marketing, admissions, supervision, and follow-up – it’s voluntary but includes a complaints mechanism where institutions designate a body and unresolved disputes go to HRK mediation, while agents must comply and can be dismissed for violations.
The strategy doesn’t explicitly address consumer protection for international students beyond encouraging the Agent Quality Framework, but the Office for Students has recognised international students face heightened risks of unfair treatment.
OfS’ proposed initial condition C5 on fair treatment explicitly includes international students, reflecting that they’re exposed to the same risks as domestic students and in some cases greater ones – higher fees, greater reliance on pre-arrival information, visa dependencies, and higher switching costs if things go wrong all amplify the potential for consumer detriment.
Recent OfS research shows international students aren’t fundamentally different from domestic students in how they understand promises and rights, but they experience some issues more acutely – when disruptions occur, international students were more likely to report that limited support from academic staff had significant impact on their academic experience, and while both international and domestic students show weak awareness of rights and redress mechanisms, this is particularly consequential for international students who are more dependent on institutional processes because informal escalation, legal challenge, or withdrawal are often less viable options.
The combined evidence implies that international recruitment carries heightened regulatory risk – many international students struggle to identify what was promised versus what was merely expected, increasing the likelihood of disputes and perceived unfairness after enrolment, and while international students aren’t uniquely dissatisfied, they are structurally more exposed when fairness breaks down, justifying closer regulatory scrutiny of provider behaviour at the point of entry and during delivery.
Were ESAG’s action plan to recommend strengthened consumer protection measures specifically recognising international students’ structural vulnerabilities, students would be pleased.
Housing
The strategy mentions housing once – government will work with the sector through ESAG on “adequate infrastructure and access to local housing”.
While housing coordination mechanisms aren’t detailed in the strategy, what approaches have other countries taken to student housing challenges?
The Netherlands launched its National Action Plan for Student Housing with government investment, targeting new affordable homes through multi-stakeholder coordination including government, municipalities, housing providers, universities, and SUs, while the plan explicitly acknowledges international students face discrimination and current shortages are substantial.
Italy allocated significant PNRR funding to increase student beds, France operates a free government-backed rental guarantee for students, Germany identifies housing as a top barrier with government funding promised for student housing, and Hungary’s dormitory programme provides guaranteed places with government funding.
Ireland acknowledges “tangible constraints can’t be ignored, such as availability of accommodation”, with research finding scams and exploitation widespread while planned on-campus beds remain unbuilt. It now has a national student housing plan, as do several other countries.
Ideally, ESAG’s action plan would include housing targets, investment proposals, or at least coordination mechanisms with local authorities.
Coordination
The strategy is “co-owned by the Department for Education, the Department for Business and Trade, and the Foreign, Commonwealth and Development Office” with leadership “sitting firmly across the government”.
Immigration policy remains under Home Office responsibility – but maybe that’s part of the problem.
Finland’s Talent Boost is cross-ministerial with Education and Economic Affairs jointly leading, explicitly integrating immigration, education, employment, business, and R&D policy.
Germany’s strategy is implemented by federal and state governments, explicitly linking to skilled immigration legislation, with agencies working across employment and business while referencing federal skilled worker strategies. Ireland involves multiple departments as lead alongside Justice for immigration and Enterprise for employment, linking to national skills, access, and languages strategies.
France’s Cour des comptes criticised the absence of Economy and Labour ministries, recommending comprehensive strategy “under Prime Minister’s authority with full involvement of Economy and Labour ministries” after concluding France “failed to define clear strategic priorities.” Sweden’s coordination programme brings together eleven government agencies.
What next?
The strategy confirms £925 per international student per year from 2028–29, stating:
the levy will be fully reinvested into higher education and skills, including the reintroduction of targeted maintenance grant for disadvantaged domestic students.
This is the strategy’s binding financial commitment regarding international students – extracting funds to redistribute to domestic students.
Yet many of the mechanisms other countries use to support international students – multi-stakeholder housing coordination, dedicated integration funding, careers support programmes, language provision, pre-arrival services, quality assurance frameworks – require investment.
International students might reasonably argue that a levy explicitly charged on them should fund improvements to their experience rather than subsidising domestic students’ maintenance.
If the state can’t afford that kind of investment from general taxation, the case for redirecting levy income toward international student support becomes stronger – especially when rising graduate dissatisfaction suggests current provision is inadequate.
The published strategy delegates the substance of higher education international student policy to ESAG, and the action plan could include measurable graduate employment targets, published retention tracking data, binding institutional requirements with enforcement, dedicated integration funding, housing targets and investment proposals, cross-departmental coordination mechanisms, language integration programmes, agent regulation with enforcement, quality certification standards, performance-based institutional funding, student experience and wellbeing frameworks, pre-arrival support requirements, cost of living transparency or support, during-study work provisions, consumer protection measures recognising structural vulnerabilities, and risk management frameworks.
Other countries – including those ramping up their recruitment to English language programmes – have developed accountability frameworks, binding requirements, and funded infrastructure that ESAG could consider for the UK’s higher education action plan.
The evidence from fifteen other countries provides options to consider.