Category: Wales

  • Welsh higher education is running out of wriggle room

    Welsh higher education is running out of wriggle room

    Back in November 2025, Vikki Howells – minister for further and higher education in the Welsh government – delivered an oral statement on “The Future of Tertiary Education in Wales: Sustainability and Participation.”

    What followed was the usual pre-election chamber choreography – the Conservative spokesperson, Natasha Asghar, complained about “warm words about the Welsh government’s achievements, but a little less about immediate action” and demanded to know which institutions were at financial risk, while Plaid’s education spokesman wanted to know what the Welsh government was doing about participation gaps.

    The minister responded with appropriate defensiveness about Diamond-era achievements and appropriate concern about sector challenges. Nobody learned anything they didn’t already know.

    Now Howells’s department has published the actual substance – 60 pages of analysis, data, and, unusually for these things, genuine honesty about the constraints the system is operating under.

    A call for submissions is now open until March, neatly timed to close before the Senedd elections in May – allowing officials to prepare an evidence base for whichever government emerges, while the current administration claims credit for having started the conversation.

    The document – The future of tertiary education in Wales: five challenges and call for submission – is, in many ways, a model of what policy analysis should look like. It is educational in the best sense – reading it carefully teaches you how the Welsh tertiary system works, how its funding flows, where its constraints bind, and why choices that might seem straightforward are anything but.

    This is not a “Now!” album of policy announcements – the kind of thing Westminster tends to produce, heavy on vibes and light on fiscal reality – but a sustained attempt to look at interconnected problems in the round, with appropriate caveats about what is known and what remains uncertain.

    Howells herself wrote a companion piece for Wonkhe late last year setting out her framing of the five challenges. But the real substance is in the document itself – and in particular, in section 2.4 on financial sustainability, which contains some of the most candid analysis of student finance constraints that any UK government has published in recent years.

    The financial trap

    The core problem runs like this. Welsh ministers have formal, devolved powers over student support – maintenance grant levels, total maintenance entitlements, and repayment terms for Welsh-domiciled borrowers.

    But the money to fund student loans comes from HM Treasury as Annually Managed Expenditure, and it only flows if Wales offers what the Statement of Funding Policy calls “broadly similar terms” to England. Grants, meanwhile, come from the Welsh government’s own resource budget, where ministers have discretion but limited headroom.

    Since the Diamond reforms took effect in 2018, Wales has operated a more progressive system than England – higher maintenance support, more generous grants for the poorest students, and – until recently – more favourable repayment thresholds. The comparative position is striking.

    According to London Economics analysis cited in the document, Welsh government direct support for the costs of higher education per student is just over double the contribution from the exchequer for students from England – but only half the contribution for students in Scotland.

    The average split of costs for new students entering higher education from Wales is approximately 56 per cent for government and 44 per cent for graduates. In England, costs are overwhelmingly borne by graduates. In Scotland and Northern Ireland, predominantly by the state.

    The fiscal mechanics have been steadily eroding that position. Grant thresholds have been frozen since 2018, meaning fewer students qualify for the most generous support as household incomes rise with inflation.

    The grant-to-loan ratio has shifted from 32:68 in 2020-21 to 23:77 in 2024-25. Grant expenditure has fallen 25 per cent in cash terms. Meanwhile, total maintenance support has increased – first in line with the National Living Wage, then with CPI – pushing up loan outlay substantially.

    The average annual maintenance loan for a full-time undergraduate student from Wales increased by 59 per cent from £5,110 to £8,150 between 2020-21 and 2024-25, exceeding the England average for the first time.”

    The document explains that Welsh government models a counterfactual – what would loan outlay be if UK government policy applied? – to ensure it stays within HMT limits. That modelling has now reached its endpoint.

    The Welsh Government can no longer afford to increase overall student loan outlay at a greater rate than The UK Government.

    This is the end of Diamond-era divergence on loan outlay. Wales can still choose to be more generous on grants from its own budget, but it cannot continue to offer higher total maintenance than England funds for English students. The financial room for manoeuvre has been exhausted.

    One reading of all this is that we are being teed up for a fundamental rethink of how the money gets spent – that Diamond was too generous, hasn’t delivered the participation gains hoped for, and the resource should be redirected toward fixing the Level 3 pipeline instead. The Diamond evaluation, due in Spring 2026, will presumably speak to this. But the picture is messier than a simple “it didn’t work” narrative would suggest.

    The part-time participation numbers show that student finance can drive participation when it’s designed well. The danger is that cutting higher education finance to fix the schools and further education pipeline simply moves the money around without increasing total participation – especially if the graduates Wales does produce continue to leave for London.

    The Plan 2 problem

    Then there is the question of repayment terms – where the document reveals a rather pointed intergovernmental dispute, albeit expressed in the most diplomatic language imaginable.

    In the autumn budget 2025, the Chancellor announced that Plan 2 repayment thresholds would be frozen from 2027 to 2030 “for borrowers in England.” The document notes this carefully – “for borrowers in England” – before immediately asserting that “repayment terms for Welsh borrowers remain within the powers of The Welsh ministers.”

    But Plan 2 is a shared system. Welsh and English borrowers on Plan 2 have, until now, operated under the same terms, administered by the Student Loans Company. The Chancellor’s announcement was made as if it applied only to England, yet the mechanics of the loan book mean Wales will face pressure to follow.

    The Welsh Government is in discussions with HMT and the Department of Education regarding the implications of the Plan 2 threshold freeze decision for Wales.”

    You don’t have “discussions about implications” of a decision you were part of making. You have discussions about implications when someone else made a decision and you’re now trying to work out what it means for you. This feels like the Chancellor changed the terms of a shared system without consulting Cardiff, and Wales is now trying to figure out whether it has any choice but to follow.

    The document notes that the UK government’s decision “demonstrates the increased pressure to ensure that the long-term costs of the student loan book remain sustainable” – which is true, but doesn’t quite capture the constitutional oddity of one government announcing changes to a devolved policy area that the other government is then expected to absorb.

    Combined, these pressures will likely require The Welsh Government to review and amend its ongoing policy on student support outlay, and student loan repayments, to maintain appropriate controls on expenditure and continue a policy that aligns with Welsh Government’s policy aims.

    Translation – Diamond is under review, and not by choice.

    The institutional squeeze

    The student finance constraints exist alongside – and compound – a financial crisis in Welsh universities themselves, with six of eight universities reporting underlying deficits in 2023/24 and total sector income falling 6 per cent in real terms between 2021/22 and 2023/24.

    International recruitment – which had been the growth strategy for many institutions – has been hit by visa restrictions imposed by the Home Office, a reserved matter over which Wales has no say, and six Welsh institutions have over 30 per cent of their fee income from international students, with the highest at 44 per cent.

    Cost pressures are mounting from multiple directions. Universities did not receive any additional public funding to compensate for the increased costs of employers’ National Insurance Contributions in 2025-26 – estimated to cost the Welsh sector £20m.

    Parts of the sector also saw increases in Teachers Pension Contributions totalling an estimated £6m in 2024/25, also unfunded – unlike in colleges and schools, where government has provided support. A decade of real-terms decline in the value of tuition fees has eroded per-student income, and Welsh government direct funding has been squeezed in real terms since 2022/23.

    If we cannot indefinitely expand funding to support all forms of provision and support, choices must be made about where investment will have the greatest impact.

    An uncontrollable market

    The financial squeeze on student support and institutions sits alongside a market competition problem that Welsh universities are losing. Section 2.3 of the document sets out, with admirable clarity, what has happened to UK higher education since student number caps were lifted in 2013-14.

    Elite universities with strong brands and secure finances have aggressively expanded their student recruitment (typically in lower cost subjects) to reinvest in research and facilities, and so further increase their appeal, brand and league table positions.

    The numbers tell the story. Between 2016 and 2025, acceptances to higher-tariff universities increased by 25 per cent, while acceptances to lower-tariff universities declined by 22 per cent. Despite total UK acceptances being only 2 per cent lower in 2025 than in 2016, the lower two-thirds of the sector by entry tariff lost 46,015 students – a 13 per cent decline.

    Wales is disproportionately exposed to this dynamic because it has relatively fewer higher-tariff institutions. Only three Welsh universities grew their domestic undergraduate numbers between 2015/16 and 2023/24. More than half saw contractions ranging from 3 to 34 per cent. The 2025 entry cycle saw acceptances at Welsh providers decline by 4.2 per cent overall – and today’s UCAS data on application patterns suggests the competitive pressure is not easing.

    Despite total acceptances in 2025 being only 2 per cent (8,885 students) lower than in 2016, the ‘lower’ two-thirds of the UK sector by entry tariff have seen a reduction of 13 per cent (46,015 students).

    The document quotes Universities UK’s Transformation and Efficiency Taskforce on the perverse effects of this competition.

    The intensity of competition has resulted in universities pursuing very similar and expensive business and operating models, and less, rather than more, differentiation across the higher education sector… In some cases, this can come at the cost of enhancing an institution’s own unique strengths while inhibiting creative approaches to teaching, research and operations.”

    The Welsh government’s answer – to the extent there is one – is collaboration. The document points to existing models such as the USW Group, the UWTSD Group with Coleg Sir Gâr and Coleg Ceredigion, and the North Wales Tertiary Alliance, and notes that Medr has been asked to map subject provision across Wales to support coordinated planning.

    But the fundamental problem is that Welsh institutions are competing in a UK-wide market they cannot control, against competitors with deeper pockets and stronger brands, while their own funding per student remains squeezed.

    The demographic cliff

    Layered on top of the market and finance problems is a demographic challenge that will hit from 2030 – the number of 16-year-olds in Wales is projected to fall by 12 per cent between 2030 and 2040, with 18-year-olds falling by 13 per cent. HEPI research cited in the document estimates that if UK application rates remain level, demand for higher education could fall by nearly 20 per cent over the same period.

    For Welsh universities, this is especially acute because 39 per cent of their students come from the rest of the UK – and three institutions have half their students from outside Wales. UK-wide demographic decline will affect the pool from which Welsh universities recruit, not just the Welsh population itself.

    The document’s response to this challenge is one of the more interesting sections. Wales has, for some years, been doing something distinctive on part-time and mature student participation – and it shows.

    In 2023/24, 37 per cent of Welsh students studied part-time, compared to 23 per cent in England, and 43 per cent were aged 25 or over, compared to 36 per cent in England. Entrant enrolments at the Open University in Wales more than doubled between 2017/18 and 2023/24, coinciding with the introduction of part-subsidised fees and pro-rata maintenance support for part-time students.

    Welsh students are more likely to be older and studying part-time than elsewhere in the UK.

    A real policy success that deserves recognition – and one that complicates the “Diamond didn’t work” narrative. Student finance clearly can drive participation when it’s well-designed and targeted, and the part-time numbers are the proof.

    The question is whether the same approach can work for the populations who aren’t currently participating – particularly the Welsh boys who have the lowest higher education participation rates in the UK, and the students from deprived backgrounds who are systematically channelled away from academic pathways.

    On the Lifelong Learning Entitlement, the document is pointedly sceptical. The LLE legislation does not apply to Welsh providers or Welsh student support, and Welsh government has decided not to follow England.

    The Welsh Government has considered that introducing the LLE in Wales would come with significant opportunity cost, with significantly increased complexity required in legislation, regulation, and provision of funding via SLC.

    There’s a pointed dig at England here too:

    It remains unclear whether there will be significant demand for loan-funded modular higher education provision, and pilot modular courses ‘significantly lacked demand’ according to a former DfE minister.

    Wales will “monitor the delivery of the LLE in England through 2026 and 2027” – civil service for “we’ll watch you try this and see if it works before committing ourselves.”

    Wales – with its stronger part-time infrastructure and more mature student population – would be well placed to pilot something innovative on credit recognition and transfer, building on its existing strengths rather than importing English complexity. The document doesn’t go there, but the foundations are present.

    The pipeline problem

    The critical constraint, as in England, is the transition between Level 3 and Level 4 – and here the document reveals how interconnected the challenges really are.

    Welsh 18-year-old UCAS application rates are 32.5 per cent, compared to 41.2 per cent UK-wide – and the gap is growing. The 18-year-old entry rate for Wales in 2025 was 29.2 per cent, the lowest in the UK. The document traces this back to Level 3 attainment – only 68.6 per cent of working-age adults in Wales are qualified to Level 3 or higher, against a target of 75 per cent by 2050, and Wales has a higher proportion of post-16 learners undertaking vocational pathways at Level 2 and below than elsewhere in the UK.

    But the headline figures mask a messier picture. Welsh participation looks lower at 18 partly because more Welsh students enter later – by age 30, the Higher Education Initial Participation measure reaches 55 per cent, which was actually higher than England’s last comparable measure, 54.2 per cent versus 51.9 per cent in 2018/19. The part-time and mature student participation that Wales has successfully expanded doesn’t show up in the 18-year-old statistics that dominate sector discourse.

    What’s feeding this pattern is a structural shift in post-16 education that the document traces in detail. The proportion of learners progressing to FE colleges at age 16 has increased from 48 per cent in 2017/18 to 56 per cent in 2024/25, while the proportion in school sixth forms has declined from 42 per cent to 37 per cent. Overall pupil numbers at school sixth forms have declined by a quarter since 2013/14, and the number of schools with sixth forms has fallen by a fifth over that time.

    This matters because of what happens next. A growing proportion of learners are entering lower-level vocational courses at Level 2 and below, and a declining proportion are undertaking Level 3 courses – especially AS and A levels. Students on lower-level courses are more likely to drop out and less likely to progress to sustained continued education or employment. The Education Policy Institute has highlighted that young people in Wales are less likely to be undertaking AS/A Levels and other Level 3 courses than elsewhere in the UK – and that this is particularly true of Welsh learners from more deprived backgrounds.

    39 per cent of pupils eligible for free school meals in Year 11 enrolled onto Level 3 qualifications, which compared with 72 per cent of Year 11 pupils not eligible for FSM.

    So the pipeline into higher education is constrained before students ever reach the point of applying, and the inequality data is bleak.

    Welsh boys have the lowest levels of higher education participation across all UK nations, and Wales has the widest higher education participation gap between men and women.”

    Tertiary education cannot alone counteract long-established social inequalities, which require a range of responses across education, social and economic policy.

    This is honest – and a useful corrective to the tendency in English policy discourse to load ever more social mobility expectations onto universities while cutting the funding they need to deliver. But it also illustrates the trap.

    If you redirect higher education finance toward fixing the Level 3 pipeline, you may improve progression rates in the long term, but you risk undermining the institutions that are supposed to receive those progressing students – and the part-time, mature student participation that has been Wales’s actual success story.

    The graduate premium

    Section 2.5, on delivering for communities and the economy, contains perhaps the most interesting data in the document – and certainly the finding that most challenges conventional UK policy wisdom.

    The standard narrative, particularly from OfS and the “low value degrees” discourse, is that the UK has produced too many graduates, the premium is eroding, and too many people are going to university for courses that don’t pay off. This framing has driven English policy toward crackdowns on recruitment, minimum outcome thresholds, and defunding of provision deemed “low value.”

    Wales tells a different story:

    In Wales, the supply of graduates has not outpaced demand, as seen in other UK countries and English regions except London. This points to a lack of graduates, not only in STEM degrees but others such as Law, Finance and Management. Overall, this may constitute a binding constraint on economic growth in Wales unlike elsewhere in the UK.

    The graduate wage premium has declined over time in most UK regions as supply increased – but not in London, and not in Wales. In Wales, there aren’t enough graduates. The constraint on economic growth isn’t “too many media studies degrees” but insufficient graduate supply across the board, including in supposedly high-value subjects.

    And then the sting:

    However, the mobility of more highly educated people means that some benefits of increasing education attainment levels might accrue to other regions, particularly London. In 2022/23, 27 per cent of Welsh graduates… worked outside of their original country of permanent address.

    Wales bears the cost of educating graduates. London, primarily, captures the productivity benefit. This creates a difficult policy problem – produce more graduates and hope enough stick around, focus on retention rather than production, accept that a small nation in an integrated UK labour market will always be partly educating for export, or align provision more tightly to specifically Welsh economic needs in the hope of creating stickier employment?

    The document doesn’t resolve this tension, but naming it is more honest than the English debate has been.

    Research and innovation

    On research funding, the picture is one of managed decline and desperate pivoting. EU structural funding has ended – a major loss for Wales – and universities must now compete more effectively for UKRI grants. There has been some success, with research council grants to Welsh universities increasing by £27m, or 42 per cent, between 2019/20 and 2023/24.

    But Wales remains structurally disadvantaged.

    It still receives a disproportionately low amount of UKRI competitive grants, at 3 per cent compared to 4 per cent of research active staff and 5 per cent of the population.

    The proportions are even lower for the largest UKRI councils – EPSRC and BBSRC – where scale matters for competitive bidding. And the underlying economics of research remain broken across the UK:

    UKRI grants are expected to cover only 80 per cent of the full economic cost of activity. However, cost recovery has fallen over the last number of years across the UK to 67 per cent, and research has become increasingly reliant on cross-subsidy from universities’ other income sources – primarily international student fees.

    With international fee income under pressure from visa restrictions, the cross-subsidy model that has propped up UK research is crumbling – and Wales, with fewer research-intensive institutions and less capacity to absorb losses, is especially exposed.

    The limits of devolution

    Reading this carefully, what emerges is a case study in the limits of devolution when you share a labour market, a student market, a research funding system, and a loan book with a much larger neighbour who makes decisions without necessarily consulting you.

    Wales has formal powers over higher education policy, but the constraints are formidable – the money for loans comes with HMT strings, and the biggest funding stream is controlled by Treasury parameters; the uncapped UK student market means Welsh institutions sink or swim based on UK-wide dynamics; immigration policy, which determines international recruitment capacity, is reserved to Westminster; competition law is reserved, shaping what collaboration is possible; research funding is split between devolved QR and UK-wide competitive grants Wales struggles to win; and graduate mobility means Wales educates workers that other regions employ.

    Many of the problems are not Welsh specifically – they are UK-wide or English problems that Wales experiences acutely because of its scale and fiscal position. The demographic cliff, the market redistribution toward higher-tariff providers, the research cross-subsidy crisis, the exhaustion of the student loan credit card – all of these are hitting RUK too. Wales has just chosen to say it out loud.

    So what is this, really? It is partly a cry for help – an honest statement that the current settlement is not sustainable and that Wales cannot solve these problems alone. It is partly a beg for more joined-up policymaking with DfE – the repeated references to English policy changes that Wales must “respond to” carry an implicit plea for consultation before decisions are made.

    It is partly a cast around for ideas – the call for submissions is genuine, and officials will presumably welcome evidence they haven’t considered. And it is partly an attempt to inform the Senedd election, giving candidates and voters a more sophisticated picture of the choices ahead than the usual campaign slogans allow.

    The document does make some effort to consider what would make Wales more attractive as a place to study and a place for graduates to remain. The analysis of graduate retention, the attention to Welsh-medium provision, the recognition that local availability of courses matters more as students increasingly live at home – all of this points toward a more place-conscious policy agenda.

    But the analysis is not consistently place-based – there’s relatively little on how these challenges play out differently in Cardiff versus Bangor versus the Valleys, despite the economic contribution arguments that run through the document.

    While student hardship and cost of living pressures are documented in bleak detail, students as agents in the system are largely absent. And while it references Medr’s system-level steering role repeatedly, it’s hard to see how meaningful system shaping happens without either student number controls – which would require agreement with Westminster given the UK-wide market – or substantial new funding to direct toward strategic priorities. Wales has neither.

    The call for submissions closes in March 2026, the Diamond evaluation is due in Spring 2026, Medr’s subject provision mapping will be published in February, and a prospectus for vocational education and training is promised for Spring 2026. The Senedd election follows in May.

    Welsh government has done something valuable here – it has produced an honest, sophisticated, technically detailed analysis of problems that much of UK higher education faces but few governments have been willing to articulate clearly.

    Whether that honesty leads to better policy – in Wales, and perhaps by example in England – remains to be seen. But as a baseline for informed debate about the future of tertiary education, this document sets a standard that other administrations would do well to notice.

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  • For a stronger, fairer Wales HE belongs in every manifesto

    For a stronger, fairer Wales HE belongs in every manifesto

    Wales stands on the cusp of significant political change. With an expanded Welsh Parliament and revised voting system, the 2026 Senedd election will mark a new chapter in Welsh democracy.

    May’s election will also be the first where 16- and 17-year-olds can cast their vote. This is a generation whose recent experience of education, and their future university and career aspirations, could be central to the choices they make at the ballot box.

    For those of us working in higher education, these changes present both a challenge and an opportunity. The new proportional voting system will likely result in a more diverse Senedd that will require greater collaboration across parties in order to be effective. For Universities Wales, this means we must continue to engage constructively with all political groups, building consensus around the vital role universities play in shaping a stronger Wales.

    A larger Senedd also means expanded committees and greater capacity for policy scrutiny. This is a welcome development that offers more space for detailed debate on the issues that matter, from economic growth and skills, to research, innovation, and community wellbeing. It also means more elected representatives who can champion higher education.

    Against this context, Universities Wales has launched a manifesto that sets out a clear vision for the future. It is a vision rooted in national renewal; one that sees universities as the essential infrastructure needed for Wales to thrive. Our message is simple: when universities succeed, Wales succeeds.

    Building jobs and skills

    In an age of rapid economic and technological change, Wales’ economy demands a flexible and highly skilled workforce. With Wales estimated to need 400,000 more graduates by 2035, universities will be central to supporting the next Welsh Government in meeting future economic needs and building a more skilled and prosperous nation.

    However, delivering on this ambition will require greater recognition of the role universities already play in delivering skills – including through the degree apprenticeships system – alongside a renewed focus on financial sustainability.

    A sustainable university sector is key to unlocking investment, productivity, and growth across Wales. Given recent challenges, an independent review of university funding and student support will be an essential step in ensuring universities can continue to deliver for Wales, now and into the future.

    Driving opportunity

    Wales’ future prosperity depends on our ability to nurture talent and equip people with the skills to thrive in a fast-moving world. Graduates are the backbone of our economy and the drivers of our future success. Put simply, there will be no growth without graduates.

    However, in Wales, we are seeing a worrying decline in the percentage of 18-year-olds choosing to go to university.

    We cannot afford to keep recycling old arguments about the value of a university education. We need to be stronger in demonstrating its essential role in shaping future prospects. If we fail, we risk leaving the next generation less qualified and with fewer pathways to success.

    Taking action to understand and reverse this trend through an independent commission on participation could unlock the potential of thousands of people, upskilling the economy and driving social mobility.

    Supporting research, innovation and local growth

    Equally as important is ensuring there is recognition and appropriate support for the full spectrum of work carried out by our universities, both here at home and through their international activities, which strengthen Wales’ global presence and influence.

    For example, while university research and innovation benefits people, business and public services across the nation and beyond, it is an area that continues to be significantly underfunded; pro-rata to population size, in 2024–25, the funding allocations made by HEFCW (now Medr) for R&I in Wales were £57m lower than those made by Research England for England, and £86m lower than in Scotland.

    Consequently, our manifesto pushes for greater investment in research, innovation and commercialisation within the current system of R&I funding. This means increases to QR funding, as well as further investment through the Research Wales Innovation Fund. This will be crucial to unlocking productivity and growth across all parts of Wales.

    We are also calling for greater support for the important work universities do within their communities to drive economic growth, attract investment, support public services, and shape the places where people live, work and thrive.

    The cliff-edge of funding caused by the loss of EU Structural Funds – which Wales particularly benefitted from – and the inadequacy of replacement funding, has had a detrimental impact on universities’ activity in this area. This is why long-term regional investment funding, channelled through the Welsh government, will be vital to supporting universities’ roles as anchor institutions, and encouraging private co-investment.

    Wales’ national renewal

    These priorities are not partisan. Every political party wants to see a thriving, prosperous Wales – and that vision depends on a strong, resilient and effective university sector. We know that the next Welsh government, whatever its composition, will face tough choices. But investing in universities is not a luxury, it is a strategic necessity that strengthens our economy, builds resilience, and transforms lives.

    As chair of Universities Wales, I believe our sector stands ready to play a central role in Wales’ future. The political system may be shifting, but our aim remains the same: to support a strong, fair, and successful Wales. This is a pivotal moment for our sector and for the nation. Now is the time to recognise the full value of Welsh universities,­ and to place them at the heart of Wales’ national renewal.

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  • Students in Wales deserve better protection from Medr

    Students in Wales deserve better protection from Medr

    Medr, the new higher education regulator in Wales, carried out an initial consultation around a year ago on its regulatory system.

    It has now produced more detailed proposals in this area and is inviting consultation responses. In the proposed regulatory approach, most requirements will apply from August 2026, with some coming into force a year later.

    Medr aims to “establish minimum expectations for compliance” and to ensure ‘that non-compliance is addressed with proportionate intervention’. Despite this, on the basis of what is in the consultation documents, Medr’s proposed regulatory approach does not outline minimum expectations for compliance in relation to gender-based violence in HE.

    The regulatory condition on “staff and learner welfare” within Medr’s proposed regulatory system covers “policies, procedures and services that promote and support staff and learner wellbeing and safety”, the latter term encompassing “freedom from harms” including harassment, misconduct, violence (including sexual violence) and hate crime (all defined in Medr’s Glossary of Terms).

    But mandatory regulatory action on addressing sexual harassment, or gender-based violence more widely, is not mentioned in the proposals and any requirements for data collection are left unclear.

    Nor does it appear that Medr are planning to publish a stand-alone regulatory condition on gender-based violence or carry out independent data collection in this area. This is particularly surprising as Medr has previously requested data reporting from HEIs on policies, training, prevention activities, and definitions used in this area (in November 2024).

    The data reported to them was, they stated, going to be used (among other things) to “inform our policy and registration developments”. In the documents shared as part of the consultation, it is not clear whether or how this data has been drawn on to develop the draft regulatory strategy.

    Nor has there been any mention of a forthcoming regulatory condition on gender-based violence, and indeed it would be counter-intuitive to introduce a regulatory system now only to amend it in a year or two’s time. We have to assume, therefore, that this is the totality of Medr’s proposed regulation in this area.

    By contrast, the Office for Students in England – Medr’s regulatory sibling – has introduced a specific regulatory condition (E6) for addressing ‘harassment and sexual misconduct in higher education, in force since 1st August 2025. It has also gathered and published data to inform this approach (which both Jim and I have written about on Wonkhe).

    But from what has been published so far on Medr’s proposed regulatory approach, there will be nothing comparable to what is in place in England, let alone to stronger frameworks such as in Australia.

    This is an urgent public health issue. There are around 149,000 students in Wales. Extrapolating from these numbers using Steele et al.’s study of Oxford University – the most robust we have methodologically in the UK at present – we would expect that around 29,800 students would experience attempted or forced sexual touching or rape every year.

    This figure does not include students who may experience stalking, sexual harassment (online or offline) or non-sexual forms of intimate partner abuse – so the total number of students who experience gender-based violence would be higher than this.

    Indeed, the Crime Survey of England and Wales consistently finds that students are roughly twice as likely as other occupational group most likely to experience stalking, sexual violence and domestic abuse.

    If Medr’s proposals are implemented in a similar form to the consultation version, a two-tier system will come into force between England and Wales. Requirements will be in place for English universities to train all staff and students, prohibit staff-student intimate relationships, and implement ‘fair’ processes for handling complaints, among other provisions. In Wales, none of these provisions will be required.

    Linking up with Wales’ national strategy

    These gaps are especially surprising in the context of a strong Welsh national strategy on Violence against Women, Domestic Abuse and Sexual Violence (VAWDASV), which has a lot of material that is relevant to higher education institutions.

    For example, Objective 2 is to “increase awareness in children, young people and adults of the importance of safe, equal and healthy relationships and empowering them to positive personal choices” and objective 4 is to “make early intervention and prevention a priority”.

    Overall, the strategy takes a public health approach to VAWDASV, prioritising data-driven efforts in this area.

    Unfortunately this approach is not clearly linked up with Medr’s regulatory approach. Medr’s consultation document does state that:

    To comply with this condition, providers must […] take account of other expectations such as those of Welsh Government (Annex B, p.71-2)

    However, the objectives of the national VAWDASV strategy do not appear to have informed the development of the proposed regulatory system. There is no discussion, for example, of early intervention and prevention, nor any clear route through which Medr could require HEIs to take action in this area.

    Staff and learner welfare

    As noted above, staff and learner welfare is the regulatory category that covers “harassment, misconduct, violence (including sexual violence) and hate crime”. The regulatory conditions Medr proposes are that:

    • All tertiary providers must conduct an annual staff and learner welfare self-evaluation
    • The annual staff and learner welfare self-evaluation must be approved by the providers’ governing body or equivalent

    These provisions demonstrate the reliance on self-evaluation in Medr’s approach. But Medr will not scrutinise or even see the self-assessments that are carried out by HEIs, only asking for the action plans produced as a result of these self-evaluations to be submitted to them. Medr “will only call in self-evaluations if concerns and risks are raised or identified.”

    This creates a catch-22 situation. It allows gender-based violence to remain invisible within HEIs if they choose not to collect data or self-evaluate in relation to it. The only consistent data collection in this area is the Crime Survey of England and Wales, which does not disaggregate data by institution, or allow for urgent risks to be identified, so this is not helpful for assessing an institution-level approach.

    Other than that, there is currently no mandatory data collection within or across higher education institutions in Wales relating to gender-based violence experienced by students or by staff.

    As a result, within the existing data landscape, there is no way in which concerns or risks can be raised or identified by Medr. Under the proposed regulatory system, HEIs will have discretion as to whether or not they choose to include issues relating to gender-based violence in their self-evaluation.

    If they choose not to include gender-based violence, they will be able to self-evaluate and create an action plan that does not mention this issue – and still remain compliant with Medr’s regulatory approach.

    Perhaps people can report “issues and concerns” directly to Medr? Unfortunately not. Medr states on their website that:

    We might become involved in issues with regulated institutions: which charge excess full-time undergraduate fees; which fail to comply with fee and access plan requirements; whose quality of education is inadequate; which don’t comply with the Financial Management Code; or which don’t comply with their Prevent duty.

    Gender-based violence is not included in areas in which Medr will “become involved”. Complaints made directly to Medr will not, therefore, provide any basis on which Medr will assess HEIs’ compliance on staff and learner welfare relating to gender-based violence.

    To sum up, the approach outlined in the consultation document means that cases of gender-based violence may not be visible in institutional or sector-level data. They will only emerge via survivors and activists raising issues via mainstream media or social media after failures have already occurred, as is currently being exemplified in mainstream media reporting.

    Complaints

    Often, the only way in which gender-based violence becomes visible to an institution is through complaints. The regulatory approach to complaints policies and data reporting is therefore important to scrutinise.

    Medr’s proposed condition of regulation on complaints procedures states that:

    …All providers registered with or funded by Medr must have in place a procedure for investigating complaints made by learners and former learners about an act or omission of the provider, and take reasonable steps to make the procedure known to learners.

    That’s all. There is no provision in the regulatory approach that requires such complaint processes to be demonstrated to be effective. Furthermore, the “primary source of monitoring for this condition” will be providers’ self-declaration they have met the compliance requirements.

    There is no requirement for regular review of complaints processes on the basis of feedback or information-gathering to assess their effectiveness. This is inadequate.

    There is a brief mention of the Office for the Independent Adjudicator for HE (OIAHE):

    Medr will consider data relating to complaints numbers, patterns and trends. For providers within the complaints scheme of the Office of the Independent Adjudicator, data will be sourced via the scheme.

    This is to be welcomed, especially as the OIAHE is currently consulting on its guidance for handling harassment and sexual misconduct complaints. But it is insufficient as the sole mechanisms for gathering data on complaints, and it is important to note its limitations.

    My research has demonstrated that in relation to complaints of staff-student sexual misconduct – a serious risk to student welfare and to equality of opportunity – students have been unable to access the services of the OIAHE to escalate their complaint because they are unable to complete the complaints process at their own institution.

    This leads to risk to student welfare (both those reporting and others who might be targeted by the same staff member); and reputational risks for the sector as well as individual higher education institutions, as students who are unable to gain safety or remedy by using existing complaints and regulatory structures are obliged to remain in unsafe, harmful situations (or drop out), and may turn to the media to raise awareness of their situation and protect others.

    This is a particularly urgent issue in Wales due to a recent High Court case from the Royal Welsh College of Music and Drama (RWCMD) taken out by two students, Sydney Feder and Alyse McCamish, where the RWCMD was found to have failed in its duties to follow its own policies or to investigate issues with a reasonable duty of care. This case was unusual in that the two students who took forward this case had the resources and knowledge to do so and were willing and able to fight a six-year battle to get their case through the courts.

    Based on my research with students and staff who have reported gender-based violence to their institutions, there are many other failures from higher education institutions across the UK that could lead to similar legal challenges, but with very short time limits, insufficient legal aid, and the absence of a culture of taking legal action in the UK in this area, these cases have tended not to be taken forward.

    Student complainants should not have to go through multiple rounds of complaints process at their HEI and then the OIAHE, taking months or – more often – years, in order to access safety and remedy during their studies.

    A further issue is the need for a mechanism for students, staff, and their advocates to be able to alert the regulator to issues of serious concern with safety, where they have not been able to raise issues within complaints processes.

    For example, where a staff member is targeting students with sexualised or harassing messages, but the university are failing to stop the behaviour, leading to students being unable to safely access teaching and learning, with serious risks to student welfare. There are also potential situations where safety concerns could lead to student or staff suicide, where urgent action may be needed to prevent very serious outcomes, in line with the crucial campaign for a duty of care in UK HE by #ForThe100.

    If sufficient action is not being taken by the institution to address student/staff safety, there needs to be a mechanism via which these concerns can be escalated. There is no provision for this in current regulations.

    Reportable events

    More familiar concerns from across UK HE are also evident in the proposed regulatory system. Universities in Wales, as “exempt charities” are regulated by Medr instead of the Charity Commission.

    However – as we have previously raised as an issue in England, and as Mary Synge has outlined in detail in relation to broader legal arguments – this has led to HEIs being much more lightly regulated than the rest of the charity sector.

    In relation to in relation to safeguarding and sexual harassment/abuse, this is a particularly urgent issue. Unfortunately, the regulatory proposals embed these different standards of regulation for HEIs compared to other charities in relation to “reportable events”, i.e. incidents that the regulator needs to be informed about.

    Charity Commission guidance states that “you should report an incident if it results in, or risks, significant harm to people who come into contact with your charity through its work […or] harm to your charity’s work or reputation”.

    A related document gives examples of what to report including an allegation that a staff member has physically or sexually assaulted or neglected a beneficiary whilst under the charity’s care; or an allegation that a trustee, staff member or volunteer has been sexually assaulted by another trustee, staff member or volunteer.

    Medr’s proposed regulatory approach retains the language of “significant harm” without defining what this means, without giving examples of what to report, and without naming sexual assault or safeguarding issues. It does, however, outline a separate category of “notifiable events” that include “a matter relating to the provider’s compliance with the Prevent duty”.

    This approach – as with the Office for Students’ approach in England – is unjustifiable given the high levels of gender-based violence occurring in higher education. The regulatory approach should be amended to align with the Charity Commission guidance.

    The issues outlined in the Charity Commission guidance would constitute a serious risk to the operation of an HEI in its charitable function, and as such must be overseen by the regulator. At the very least, Medr’s regulatory approach needs to clarify what constitutes ‘significant harm’. This should include incidents that could constitute serious sexual harm.

    Furthermore, it is unclear why “notifiable events” include breaches of compliance relating to the Prevent duty, but not other legal duties such as breaches of equalities, health and safety, or safeguarding legal duties.

    Moving beyond self-regulation of HEIs

    The proposed regulatory approach states that “monitoring activity” will allow Medr to ascertain “whether providers are meeting their Conditions of Registration and/or Funding, and whether any regulatory concern or risk is emerging”.

    As the regulatory approach stands, this claim is inaccurate in relation to gender-based violence – without any data being reported to Medr in this area, or even gathered by HEIs in many cases, there is no way in which Medr will be able to assess any risks in this area.

    There can be no charitable institutions in the UK where the risks of sexual violence, exploitation and abuse are higher than in universities. Gender-based violence in higher education is a major public health concern and should also be a high priority when considering equal access to education. As such, HEIs should be subject to the most stringent regulation.

    If Medr considers that the regulatory strategy more broadly is not the right place to set out these more detailed requirements, a further regulatory condition from Medr in this area on HEIs’ responsibilities in relation to gender-based violence should be published.

    However, the Office for Students already have an explicit regulatory condition in this area and I can’t see a good reason why Medr should wait any longer before taking such a step. Either way, within this consultation document, the foundations need to be laid to enable this work to be done. The regulatory strategy proposed, as it stands, will leave the higher education sector to continue to self-regulate around issues of gender-based violence, despite evidence of high prevalence.

    A further point that should be considered in a regulatory approach is transparency. This is crucial because transparency and openness are a primary concern for students who report gender-based violence to their HEI. But HEIs are unlikely to take these steps towards transparency without the regulator requiring them to do so.

    In recognition of this need for regulators to require transparency, in a recent review for the Higher Education Authority of the Irish Government’s national framework for Ending Sexual Violence and Harassment (ESVH), the Expert Group (which I chaired) have recommended that

    Institutions publish information on ESVH work as part of their public EDI reporting, including anonymised data on formal reports and outcomes, good practice case studies, an evaluation of education and training initiatives, and other relevant data.

    This recommendation looks likely to be adopted nationally in Ireland, requiring all HEIs to take this step in the coming years. However, in the Medr regulatory strategy, “transparency, accountability and public trust” is only discussed in relation to “governance and management”.

    While Medr states more generally that they “encourage a culture of openness and transparency” this appears to only relate to reporting from HEIs to Medr – not to relationships between HEIs and their staff and student body. A fundamental shift is therefore needed in order to move towards greater transparency around institutional data reporting and actions on gender-based violence.

    Overall, Medr appear to be relying on data on gender-based violence to emerge via existing, inadequate, data sources, or to allow HEIs to choose whether and how they gather this data. Such an approach will not be effective – if you do not directly and explicitly gather data about gender-based violence, it will remain invisible, not least because those who experience even the most severe forms of gender-based violence often do not label their experiences as such.

    More generally, this approach goes against the direction of travel internationally in higher education policy in relation to gender-based violence, leaving Welsh students and staff underserved compared to their peers in England, Ireland, France, Australia, and elsewhere.

    This means that future generations of students and staff will continue to be at risk. Medr must be much bolder in order to fulfil its stated approach to regulation of “clear, enforceable rules that establish minimum expectations for compliance” in relation to gender-based violence in HE.

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  • Wales stands firm against international fee levy, minister says

    Wales stands firm against international fee levy, minister says

    During a a visit to the University of South Wales’s (USW) Pontypridd campus, Wales’s minister for further an higher education Vikki Howells reaffirmed that the country will not introduce the levy – details of which were set out in last week’s Autumn Budget.

    Instead, Howells reiterated that international students coming to Wales would find a warm welcome. “We want to send a clear message that Wales is open, inclusive, and committed to providing an outstanding student experience,” she said after the visit.

    “International students are an integral part of our higher education community. They not only boost our economy but also bring cultural diversity and global outlooks that benefit all of us. Wales is proud to be a place where students from around the world feel welcome and supported,” said Howells.

    We want to send a clear message that Wales is open, inclusive, and committed to providing an outstanding student experience
    Vikki Howells, member of the Senedd

    Louise Bright, USW’s pro vice-chancellor for enterprise engagement and partnership, added: “Our international students contribute enormously to the life of our universities and of Wales. Their skills, insights and experiences help us create a stronger, more outward-looking and connected nation.”

    Universities Wales said the move underscored the Welsh government’s commitment to supporting international education in Wales.

    It comes just a weeks after Howells recorded a video for international students assuring them that they would find “a place where you’ll truly belong” if they chose Wales as a study destination. The country has been positioning itself as a regional hub for international education – with interest in studying in Wales rising most sharply in Indian and American students.

    According to HESA data, Wales was home to some 27,795 international students in the 2023/24 academic year, with most of those coming from non-EU countries.

    The University of South Wales had the most, with 6,635 international students, followed by Cardiff University with 6,480 and Swansea University with 4,780.

    The international student levy – which will come into force in England in 2028 – has been controversial, with stakeholders warning that it could severely impact international enrolments.

    Large metropolitan universities stand to lose the most money from the policy, which will see a £925-per-student flat fee for all institutions in England with more than 220 international students. The cash raised will be used to fund domestic maintenance grants.

    According to the latest available HESA data, University College London would have to pay the most money – over £25 million – followed by the University of Manchester and the University of Hertfordshire.

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  • Five challenges faced by the Welsh tertiary sector

    Five challenges faced by the Welsh tertiary sector

    Wales’ tertiary education and research sector is something we should all be proud of.

    This is why I want to ensure it not only remains sustainable but continues to build on the achievements of the past five years.

    These achievements include our progressive higher education funding policy, which has ensured financial barriers do not hold back talent and ambition. Welsh full-time undergraduates studying away from home outside London are entitled to £12,345 in maintenance support, with up to £8,100 in grants for those from the lowest income household.

    Our financial package for part-time study has opened higher education to thousands more students since 2018.

    Welsh universities led the UK for the proportion of their research whose impact is considered internationally excellent or world-leading in REF 2021.

    The pandemic had a tremendous impact on every aspect of education, but the tide has started to turn. Further education has seen a revival in participation in recent years, helped by increased funding for colleges and the continuation of the Education Maintenance Grant and Welsh Government Learning Grant. Last year there was an 8.5 per cent increase in school leavers progressing to college and it is promising that early data suggests a similar increase this year.

    A time of challenges

    But I am mindful that there are significant challenges facing tertiary education, not just in Wales, but across the UK.

    Yesterday in the Senedd I set out what I believe are now the five most pressing challenges for higher and further education in Wales in the coming years, and how I will use the remainder of the Senedd term to work with the sector to address them.

    Increasing participation must continue to be a priority. Wales has a smaller proportion of young people attaining level 3 (A Levels and equivalent) than other UK nations. Our higher education entry rate at age 18 is also the lowest in the UK at 30 per cent, and although a larger proportion of students appear to enter HE in Wales in their twenties, we want more to see university as part of their future at 18.

    The Welsh Government has a long-standing goal of 75 per cent of working age people being qualified to level 3 or higher by 2050. To achieve this, we need to expand access to a full range of vocational, technical, and academic pathways from age 16, which is why we are already reforming both 14-16 and post-16 qualifications.

    And our tertiary education sector must be ready for a significant decline in the numbers of young people. The number of 16-year-olds in Wales is expected to fall by 17 per cent between 2027 and 2037. As a result, demand for university places across the UK could fall by almost 20 per cent in the 2030s.

    Lifelong learning is already well ingrained in Welsh higher education. In 2022-23, 36 per cent of Welsh students studied part-time, compared with 23 per cent of English students, and 44 per cent of Welsh students were aged 25 and above compared with 36 per cent of English students. And during this Senedd term we have been able to increase the numbers of part-time learners in further education for the first time in a decade.

    This is a platform to build from, but we will need to go further to enable adults to upskill around work and family commitments, at all levels, by providing more flexible, part-time and lifelong learning opportunities.

    Unintended consequences

    Another challenge relates to the unintended consequences of growing competition between providers. The competition in student recruitment is fundamental to the financial challenges now facing our universities and it will only intensify from 2030.

    The removal of student number caps has permitted some UK universities to grow their domestic enrolments – often by lowering entry requirements – at the expense of the rest of the sector, including many of our excellent universities here in Wales. A future where higher-tariff providers continue to expand their enrolments at the rate of the past few years cannot be sustainable for the wider UK sector.

    So I agree with the UK Government’s white paper that the future for tertiary education lies not in greater competition, but in increased collaboration. We have already worked with the Competitions and Markets Authority (CMA) to clarify the position on collaboration between universities. Medr is working to map subject provision so we can better understand which subjects may be at risk in the future from growing competition and changes in student preferences. Now we must look at how we enable closer collaboration in practice, and create the right incentives in funding and regulation for institutions to act more collaboratively.

    I believe working in partnership will also be key to addressing the financial challenges facing not only institutions, but also students.

    Our financial support for tertiary education and students is significant, totalling over £1.2bn this year alone. Despite taking the difficult decision to increase tuition fees in the past two years and again next year, education must remain affordable. This is why we provide generous student support and a more progressive repayment policy in Wales. We will therefore consider cost-of-living pressures for students and learners in the ongoing evaluation of the Diamond reforms. But the challenges facing the public finances are likely to last, and we need to consider how every penny spent to support institutions and students is delivering the greatest value possible.

    Delivery

    Finally, a thriving tertiary education sector must deliver for our economy. There are already excellent examples of this – such as the role of Cardiff University to support the compound semiconductor manufacturing hub, or the work of the North Wales Tertiary Alliance to power the new reactors at Wylfa with a skilled workforce. But we will need to change our approaches to vocational skills and research and innovation, both to respond to UK Government reforms, and to ensure that our economy has the skills and ideas to boost productivity and reduce inequality.

    We have begun some of the work needed to meet these five challenges but must go further. In the coming weeks, we will publish an evidence paper, alongside a call for submissions from stakeholders, which will set out the challenges in much greater depth, and call on the sector to comment and advise on what more we need to understand about them.

    I have also invited representatives from across the Welsh sector to join a new Ministerial Advisory Group, to consider these challenges in depth and in the spirit of social partnership.

    Together, this work will provide a comprehensive evidence base upon which to deliver further reform, and help us to secure a thriving future for our tertiary education sector in Wales in these challenging times.

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  • Can regulation cope with a unified tertiary system in Wales?

    Can regulation cope with a unified tertiary system in Wales?

    Medr’s second consultation on its regulatory framework reminds us both of the comparatively small size of the Welsh tertiary sector, and the sheer ambition – and complexity – of bringing FE, HE, apprenticeships and ACL under one roof.

    Back in May, Medr (the official name for the Commission for Tertiary Education and Research in Wales) launched its first consultation on the new regulatory system required by the Tertiary Education and Research Wales Act 2022.

    At that stage the sector’s message was that it was too prescriptive, too burdensome, and insufficiently clear about what was mandatory versus advisory.

    Now, five months later, Medr has returned with a second consultation that it says addresses those concerns. The documents – running to well over 100 pages across the main consultation text and six annexes – set out pretty much the complete regulatory framework that will govern tertiary education in Wales from August 2026.

    It’s much more than a minor technical exercise – it’s the most ambitious attempt to create a unified regulatory system across further education, higher education, apprenticeships, adult community learning and maintained school sixth forms that the UK has yet seen.

    As well as that, it’s trying to be both a funder and a regulator; to be responsive to providers while putting students at the centre; and to avoid some of the mistakes that it has seen the Office for Students (OfS) make in England.

    Listening and responding

    If nothing else, it’s refreshing to see a sector body listening to consultation responses. Respondents wanted clearer signposts about what constitutes a compliance requirement versus advisory guidance, and worried about cumulative burden when several conditions and processes come together.

    They also asked for alignment with existing quality regimes from Estyn and the Quality Assurance Agency, and flagged concerns about whether certain oversight might risk universities’ status as non-profit institutions serving households (NPISH) – a technical thing, but one with significant implications for institutional autonomy.

    Medr’s response has been to restructure the conditions more clearly. Each now distinguishes between the condition itself (what must be met), compliance requirements that evidence the condition, and guidance (which providers must consider but may approach differently if they can justify that choice).

    It has also adopted a “make once, use many” approach to information, promising to rely on evidence already provided to Estyn, QAA or other bodies wherever it fits their purpose. And it has aligned annual planning and assurance points with sector cycles “wherever possible.”

    The question, of course, is whether this constitutes genuine simplification or merely better-organised complexity. Medr is establishing conditions of registration for higher education providers (replacing Fee and Access Plans), conditions of funding for FE colleges and others, and creating a unified quality framework and learner engagement code that applies across all tertiary education.

    The conditions themselves

    Some conditions apply universally. Others apply only to registered providers, or only to funded providers, or only to specific types of provision. As we’ve seen in England, the framework includes initial and ongoing conditions of registration for higher education providers (in both the “core” and “alternative” categories), plus conditions of funding that apply more broadly.

    Financial sustainability requires providers to have “strategies in place to ensure that they are financially sustainable” – which means remaining viable in the short term (one to two years), sustainable over the medium term (three to five years), and maintaining sufficient resources to honour commitments to learners. The supplementary detail includes a financial commitments threshold mechanism based on EBITDA ratios.

    Providers exceeding certain multiples will need to request review of governance by Medr before entering new financial commitments. That’s standard regulatory practice – OfS has equivalent arrangements in England – but it represents new formal oversight for Welsh institutions.

    Critically, Medr says its role is “to review and form an opinion on the robustness of governance over proposed new commitments, not to authorise or veto a decision that belongs to your governing body.” That’s some careful wording – but whether it will prove sufficient in practice (both in detail and in timeliness) when providers are required to seek approval before major financial decisions remains to be seen.

    Governance and management is where the sector seems to have secured some wins. The language around financial commitments has been softened from “approval” to “review.” The condition now focuses on outcomes – “integrity, transparency, strong internal control, effective assurance, and a culture that allows challenge and learning” – rather than prescribing structures.

    And for those worried about burden, registered higher education providers will no longer be required to provide governing body composition, annual returns of serious incidents, individual internal audit reports, or several other elements currently required under Fee and Access Plans. That is a reduction – but won’t make a lot of difference to anyone other than the person stiffed with gathering the sheaf of stuff to send in.

    Quality draws on the Quality Framework (Annex C) and requires providers to demonstrate their provision is of good quality and that they engage with continuous improvement. The minimum compliance requirements, evidenced through annual assurance returns, include compliance with the Learner Engagement Code, using learner survey outcomes in quality assurance, governing body oversight of quality strategies, regular self-evaluation, active engagement in external quality assessment (Estyn inspection and/or QAA review), continuous improvement planning, and a professional learning and development strategy.

    The framework promises that Medr will “use information from existing reviews and inspections, such as by Estyn and QAA” and “aim not to duplicate existing quality processes.” Notably, Medr has punted the consultation on performance indicators to 2027, so providers won’t know what quantitative measures they’ll be assessed against until the system is already live.

    Staff and learner welfare sets out requirements for effective arrangements to support and promote welfare, encompassing both “wellbeing” (emotional wellbeing and mental health) and “safety” (freedom from harassment, misconduct, violence including sexual violence, and hate crime). Providers will have to conduct an annual welfare self-evaluation and submit an annual welfare action plan to Medr. This represents new formal reporting – even if the underlying activity isn’t new.

    The Welsh language condition requires providers to take “all reasonable steps” to promote greater use of Welsh, increase demand for Welsh-medium provision, and (where appropriate) encourage research and innovation activities supporting the Welsh language. Providers must publish a Welsh Language Strategy setting out how they’ll achieve it, with measurable outcomes over a five-year rolling period with annual milestones. For providers subject to Welsh Language Standards under the Welsh Language (Wales) Measure 2011, compliance with those standards provides baseline assurance. Others must work with the Welsh Language Commissioner through the Cynnig Cymraeg.

    Learner protection plans will be required when Medr gives notice – typically triggered by reportable events, course closures, campus closures, or significant changes to provision. The guidance (in the supplementary detail from page 86 onwards) is clear about what does and doesn’t require a plan. Portfolio review and planned teach-out? Generally fine, provided learners are supported. Closing a course mid-year with no teach-out option? Plan required. Whether this offers the sort of protection that students need – especially when changes are made to courses to reduce costs – will doubtless come up in the consultation.

    And then there’s the Learner Engagement Code, set out in Annex D. This is where student representative bodies may feel especially disappointed. The Code is principles-based rather than rights-based, setting out nine principles (embedded, valued, understood, inclusive, bilingual, individual and collective, impactful, resourced, evaluated) – but creates no specific entitlements or rights for students or students’ unions.

    The principles themselves are worthy enough – learners should have opportunities to engage in decision-making, they should be listened to, routes for engagement should be clear, opportunities should reflect diverse needs, learners can engage through Welsh, collective voice should be supported, engagement should lead to visible impact, it should be resourced, and it should be evaluated. But it does all feel a bit vague.

    Providers will have to submit annual assurance that they comply with the Code, accompanied by evidence such as “analysis of feedback from learners on their experience of engagement” and “examples of decisions made as a result of learner feedback.” But the bar for compliance appears relatively low. As long as providers can show they’re doing something in each area, they’re likely to be deemed compliant. For SUs hoping for statutory backing for their role and resources, this will feel like a missed opportunity.

    Equality of opportunity is more substantial. The condition requires providers to deliver measurable outcomes across participation, retention, academic success, progression, and (where appropriate) participation in postgraduate study and research. The supplementary detail (from page 105) sets out that providers must conduct ongoing self-evaluation to identify barriers to equality of opportunity, then develop measurable outcomes over a five-year rolling period with annual milestones.

    Interestingly, there’s a transition period – in 2026-27, HE providers with Fee and Access Plans need only provide a statement confirming continued commitments. Full compliance – including submission of measurable outcomes – isn’t required until 2027-28, with the first progress reports due in 2028-29. That’s a sensible approach given the sector’s starting points vary considerably, but it does mean the condition won’t bite with full force for three years.

    Monitoring and intervention

    At the core of the monitoring approach is an Annual Assurance Return – where the provider’s governing body self-declares compliance across all applicable conditions, supported by evidence. This is supplemented by learner surveys, Estyn/QAA reviews, public information monitoring, complaints monitoring, reportable events, data monitoring, independent assurance, engagement activities and self-evaluation.

    The reportable events process distinguishes between serious incidents (to be reported within 10 working days) and notifiable events (reported monthly or at specified intervals). There’s 17 categories of serious incidents, from loss of degree awarding powers to safeguarding failures to financial irregularities over £50,000 or two per cent of turnover (whichever is lower). A table lists notifiable events including senior staff appointments and departures, changes to validation arrangements, and delays to financial returns. It’s a consolidation of existing requirements rather than wholesale innovation, but it’s now formalised across the tertiary sector rather than just HE.

    Medr’s Statement of Intervention Powers (Annex A) sets out escalation from low-level intervention (advice and assistance, reviews) through mid-level intervention (specific registration conditions, enhanced monitoring) to serious “directive” intervention (formal directions) and ultimately de-registration. The document includes helpful flowcharts showing the process for each intervention type, complete with timescales and decision review mechanisms. Providers can also apply for a review by an independent Decision Reviewer appointed by Welsh Ministers – a safeguard that universities dream of in England.

    Also refreshingly, Medr commits to operating “to practical turnaround times” when reviewing financial commitments, with the process “progressing in tandem with your own processes.” A six-week timeline is suggested for complex financing options – although whether this proves workable in practice will depend on Medr’s capacity and responsiveness.

    Quality

    The Quality Framework (Annex C) deserves separate attention because it’s genuinely attempting something ambitious – a coherent approach to quality across FE, HE, apprenticeships, ACL and sixth forms that recognises existing inspection/review arrangements rather than duplicating them.

    The framework has seven “pillars” – learner engagement, learner voice, engagement of the governing body, self-evaluation, externality, continuous improvement and professional learning and development. Each pillar sets out what Medr will do and what providers must demonstrate. Providers will be judged compliant if they achieve “satisfactory external quality assessment outcomes,” have “acceptable performance data,” and are not considered by Medr to demonstrate “a risk to the quality of education.”

    The promise is that:

    …Medr will work with providers and with bodies carrying out external quality assessment to ensure that such assessment is robust, evidence-based, proportionate and timely; adds value for providers and has impact in driving improvement.

    In other words, Estyn inspections and QAA reviews should suffice, with Medr using those outcomes rather than conducting its own assessments. But there’s a caveat:

    “Medr has asked Estyn and QAA to consider opportunities for greater alignment between current external quality assessment methodologies, and in particular whether there could be simplification for providers who are subject to multiple assessments.

    So is the coordination real or aspirational? The answer appears to be somewhere in between. The framework acknowledges that by 2027, Medr expects to have reviewed data collection arrangements and consulted on performance indicators and use of benchmarking and thresholds. Until that consultation happens, it’s not entirely clear what “acceptable performance data” means beyond existing Estyn/QAA judgements. And the promise of “greater alignment” between inspection methodologies is a promise, not a done deal.

    A tight timeline

    The key dates bear noting because they’re tight:

    • April 2026: Applications to the register open
    • August 2026: Register launches; most conditions come into effect
    • August 2027: Remaining conditions (Equality of Opportunity and Fee Limits for registered providers) come into full effect; apprenticeship providers fully subject to conditions of funding

    After all these years, we seem to be looking at some exit acceleration. It gives providers approximately six months from the consultation closing (17 December 2025) to the application process opening. Final versions of the conditions and guidance presumably need to be published early 2026 to allow preparation time. And all of this is happening against the backdrop of Senedd elections in 2026 – where polls suggest that some strategic guidance could be dropped on the new body fairly sharpish.

    And some elements remain unresolved or punted forward. The performance indicators consultation promised for 2027 means providers won’t know the quantitative measures against which they’ll be assessed until the system is live. Medr says it will “consult on its approach to defining ‘good’ learner outcomes” as part of a “coherent, over-arching approach” – but that’s after registration and implementation have begun.

    Validation arrangements are addressed (providers must ensure arrangements are effective in enabling them to satisfy themselves about quality), but the consultation asks explicitly whether the condition “could be usefully extended into broader advice or guidance for tertiary partnerships, including sub-contractual arrangements.” That suggests Medr has been reading some of England’s horror stories and recognises the area needs further work.

    And underlying everything is the question of capacity – both Medr’s capacity to operate this system effectively from day one, and providers’ capacity to meet the requirements while managing their existing obligations. The promise of reduced burden through alignment and reuse of evidence is welcome.

    But a unified regulatory system covering everything from research-intensive universities to community-based adult learning requires Medr to develop expertise and processes across an extraordinary range of provision types. Whether the organisation will be ready by August 2026 is an open question.

    For providers, the choice is whether to engage substantively with this consultation knowing that the broad architecture is set by legislation, or to focus energy on preparing for implementation. For Welsh ministers, the challenge is whether this genuinely lighter-touch, more coherent approach than England’s increasingly discredited OfS regime can be delivered without compromising quality or institutional autonomy.

    And for students – especially those whose representative structures were hoping for statutory backing – there’s a question about whether principles-based engagement without rights amounts to meaningful participation or regulatory box-ticking.

    In England, some observers will watch with interest to see whether Wales has found a way to regulate tertiary education proportionately and coherently. Others will see in these documents a reminder that unified systems, however well-intentioned, require enormous complexity to accommodate the genuine diversity of the sector. The consultation responses, due by 17 December, will expose which interpretation the Welsh sector favours.

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  • Medr is embracing its collaborative role

    Medr is embracing its collaborative role

    “You have two ears, one mouth – use them in that proportion.”

    The words of my mother seem to have gained relevance and resonance for me, as I reflect at the end of my tenure as CEO responsible for overseeing the launch of Medr, the new tertiary funding and regulatory body in Wales.

    As we arrive at our first birthday as an organisation, my mother’s words ring true in the approach we have tried to nurture with partners to help tackle the challenges and embrace the opportunities facing the sector.

    And this is perhaps particularly true during the well-established perfect storm of headwinds facing our higher education institutions at present, prompting understandable deliberations and concern around staffing, provision and campus restructuring.

    Wonkhe readers will be well versed in the plethora of pressures facing even the most long-established and most renowned universities across the UK. Put simply, the pressures of increasing costs are currently not being met by an increase in income for too many, and our institutions in Wales are no different (further context and a Medr perspective were provided to the Senedd’s Children, Young People and Education Committee a few short weeks ago, if it’s of interest).

    For the long-term viability of the post 16 sector to thrive in Wales, finding strategic, joined-up solutions is imperative. As a regulator and funder and having engaged extensively with the sector since day one, our analysis is that no institution in Wales is at immediate risk of collapse, but that medium-term outcomes do cause us concern if well thought-through changes are not made.

    Beyond “competition with a smile”

    What’s also clear to us in Wales is that many of these pressures are also affecting other parts of the tertiary sector – local authorities, schools, further education colleges, apprenticeship providers, adult education providers as well as universities and everything in between.

    This, however, can create opportunities.

    Back to the words of my mother – “two ears and one mouth” – during our first year of operation as Medr, we have had to quickly get on top of the tertiary issues in Wales. In Stephen Covey’s words, we must “seek first to understand”. We must understand the extent and context of the challenges and why certain actions are being proposed. Through a genuine commitment to engaging with a range of stakeholders and considering how we can facilitate a culture of listening, learning and collaborating across the post-16 sector, we have a great opportunity to build on the solid foundations of a shared ambition and purpose to build resilience for the future.

    Being a regulator and a funder is not an end in itself. To be honest, I had underestimated the importance of our role in convening and facilitating conversations between different stakeholders whilst respecting institutional autonomy. Colleagues must be bored of me telling the story of an ex-colleague of mine who challenged me after a meeting when I talked about collaboration. He said:

    Do you mean collaboration? Or are you talking about competition with a smile?

    We’ve all been there! We smile and nod in a meeting when we talk about working together – and then go back to our respective ranches and nothing changes.

    However, if we genuinely place learner need ahead of institutional need, we have an opportunity to create a system that is better than the sum of its parts. Don’t get me wrong, as a former CEO of a post-16 provider, I’m fully aware of the accountability to a governing body and the need to protect the viability of the organisation. But I also acknowledge that I was probably more comfortable in exploring growth and new opportunities, rather than thinking about stopping some things we did because someone else was in a better place to provide that service to our community or region. Collaboration is also not an end in itself – there is no point in collaborating if it just appeases everybody but doesn’t improve the breadth or quality of provision for learners or improves the system as a whole.

    A course through the headwinds

    At Medr, we have tried to live our values and engage, listen and collaborate with the sector. For example, our first strategic plan has developed considerably through consultation. We have recently launched a consultation on our draft regulatory framework, a hugely important piece of work for the sector, and we will continue to listen throughout that process.

    What I hope shines through in that work, and which I equally hope isn’t lost in wider discussions around headwinds and pressures, is the positive everyday impact that all parts of the tertiary sector have on our learners and our communities. I have a huge respect for the learner focussed people who work in our wonderfully diverse post-16 sector. Developing that mutual respect amongst all parts of the sector is vital if we are to develop a better system in the future that can tackle some of the challenges, such as the numbers not in education, employment or training, and our desire to improve participation rates in higher levels of learning.

    This isn’t easy. If it was, we would have solved these challenges by now. It has taken decades to create these issues and they won’t be solved overnight. And true collaboration – not competition with a smile! – takes time to build trust, requires a great deal of commitment along with a good dollop of inspiring and tenacious leadership.

    Yes, it’s challenging – but therein lies opportunity for innovation. In my experience, when the going gets tough, leaders demonstrate two basic types of behaviour. They either sharpen the elbows and dig in and become even more competitive or they reach out to others and work collectively to find joined up solutions to problems. To achieve the latter, we need to look at ways we can remove the barriers to this approach. Get it right and we can build prosperous futures for our learners and the tertiary education system and for Wales.

    There may often be differing views on how best to achieve outcomes but by working together to identify challenges and opportunities, consulting and engaging in solution-based conversations that benefit our learners, we can and will overcome them. Nelson Mandela said that education is “the most powerful weapon you can use to change the world” – we are fortunate in Wales to have some brilliant people coming together to try to deliver that change for good.

    Indeed, the name Medr itself is not an acronym. It’s a Welsh word which roughly translated straddles ability, skill and capacity. It’s a name that acts as a reminder of what we’re here to achieve: to ensure all learners can access opportunities to learn new skills and expand their opportunities for the greater good.

    And, of course, that greater good extends beyond learners and their immediate surroundings. I continue to be impressed by the work many of our universities deliver through groundbreaking research and innovation. Research Excellence Framework recently recognised 89 per cent of Welsh research as internationally excellent or world leading in its impact. Successful recent spin-outs such as Draig Therapeutics are further examples of world-class research leading to significant impacts of R&I and serve as a reminder that our universities are critical to our economy, society and culture – both now and in the future.

    And we are very proud too of our commitment to the Welsh language. The legislation identifies the Coleg Cymraeg Cenedlaethol as the designated advisor to Medr on Welsh language delivery in the post-16 sector. Our two organisations have developed a strong working relationship and through engagement with the sector, we will deliver a national plan for Welsh language delivery.

    Reaching out

    All this can all only be successfully achieved by working together. It is easy to be a spectator sniping from the sidelines but we must focus on having the right people and systems in the arena to make positive collaborative change. Across the board we must think beyond borders – sectoral, governmental, regional, national and international – listening to and reaching out to others with similar challenges to us. I am heartened by the willingness we’ve seen across the tertiary sector to do just this.

    For our part we will continue to facilitate progress by working with stakeholders to understand risks and plans, provide support and challenge based on different situations, ensure governments are well-informed and understand the challenges and opportunities as early as possible – and a whole host besides. It’s both an opportunity and a duty to bring people together and think about how we can do things differently and how we can do things better.

    I’ll finish where I started, by talking about my Mam and my upbringing. Growing up in an area that would be described as “socially deprived”, and losing my Dad while still at primary school, it’s very clear to me now the difference a few key educational touchpoints made to my life. I was fortunate to have some teachers along my journey who could see something in me when I couldn’t see it myself. Medr wants to be part of ensuring that such positive educational experiences can be felt by all.

    Medr is celebrating its first birthday. We are new kids on the block. And as I hand over to the excellent James Owen, Medr’s new CEO, I recognise that we have launched at a particularly challenging time for the sector.

    But among all the noise around business resilience, longevity and political headwinds, it’s absolutely imperative that every conversation comes back to what is right for our learners, the ones who will determine our future successes or failures. Now the exciting bit begins. If we work together to get the system right for our learners – and that’s absolutely at the forefront of what we are trying to shape at Medr – the rest can and will stem from there.

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  • Wales can lead the way on student engagement – if it chooses to

    Wales can lead the way on student engagement – if it chooses to

    Imagine studying in a Wales where every student understands their rights and responsibilities.

    Where module feedback drives real change, where student representatives have time, resources and power to make a difference, and where complaints drive learning, not defensiveness.

    Where every student contributes to their community in some way – and where decisions can’t be made about students without students.

    When the Tertiary Education and Research (Wales) Act 2022 was being drafted, the inclusion of a mandatory Learner Engagement Code was important – Wales resolved to put into primary legislation what England had buried in the B Conditions and Scotland had largely left to institutional discretion.

    Section 125 now requires the Commission to prepare and publish a code about learner involvement in decision-making that’s not optional, or best practice – it’s law.

    This year the newly formed commission (MEDR) has been informally consulting on it – but it’s now been so long since the original debates that there’s a danger everyone helping to develop the thing will forget what it was supposed to do.

    Nobody will benefit from something that emerges as something weak or vague. The opportunity is for Wales to lead the way with some crunchy “comply or explain” provisions for universities in Wales that reflect the fact that this has been put in primary legislation.

    The cost of getting it wrong

    We know what happens when learner engagement is treated as an afterthought. In England, providers often silence critique on reputational grounds – the Office for Students’ (OfS) free speech guidance had to explicitly state that students have the right to publicly criticise their institutions. Imagine needing regulatory clarification that criticism is allowed in a democracy.

    Meanwhile, Scottish institutions celebrate their “partnership” approach while student representatives struggle to influence decisions that matter. Sparqs frameworks look good on paper, but without regulatory teeth, they rely on institutional goodwill. And goodwill, as any student rep will tell you, tends to evaporate when difficult decisions need making.

    When module evaluation becomes a tick-box exercise rather than genuine dialogue, problems fester. When student reps are excluded from decisions about their own education, drop-out rates climb. When complaints are buried rather than learned from, the same issues affect cohort after cohort.

    I’ve seen a lot of it over the years. The disabled student who gave up trying to get adjustments implemented because every lecturer claimed the central service’s plans were “merely advisory”. The international PGT student who couldn’t complain about teaching quality because they feared visa implications. The part-time student who couldn’t access support services because everything was designed around full-time, on-campus students.

    The student facing disciplinary proceedings who wasn’t allowed an advocate and faced a panel with no student members – in contrast to the support available to staff in similar situations.

    These aren’t edge cases – they’re systematic failures that a robust Code could prevent. Wales has a genuine opportunity to do something different – to create a Code with teeth that makes learner engagement mandatory, measurable and meaningful.

    Learning from what works

    The most effective student engagement systems require common features. They’re comprehensive, covering everything from module evaluation to strategic planning, and are backed by resources, ensuring student representatives aren’t expected to volunteer countless hours without support. And crucially, they have consequences when institutions fail to comply.

    The key is moving from “should” to “must”, with a comply or explain mechanism that has genuine bite.

    Here’s how it could work. The Code would set out clear standards – not aspirations but requirements. Providers would either have to comply with the standards or publicly explain why they’ve chosen an alternative approach that delivers equivalent or better outcomes.

    But – and this is crucial – explanations wouldn’t be allowed to be boilerplate excuses. They would need to be evidence-based, time-limited, and subject to scrutiny.

    The Commission would assess compliance annually, not through tick-box returns but through triangulated evidence – student surveys, complaint patterns, representation effectiveness metrics, and crucially, the views of student representatives themselves.

    Where providers persistently fail to meet standards without adequate justification, consequences would follow – from improvement notices to conditions on funding.

    There would be an expectation of an annually agreed student partnership agreement – setting out both processes and priority actions – and an expectation that students’ unions would produce an annual report on the experiences of students at that provider.

    This isn’t about micromanaging institutions – it’s about establishing minimum standards while allowing flexibility in how they’re met. A small FE provider might implement representation differently than a large university, but both must demonstrate their approach delivers genuine student voice in decision-making.

    Student rights and democratic education

    The Code should first establish that students are both consumers with enforceable rights and partners in their education. This dual recognition ends the sterile debate about whether students are one or the other. It means providers must respect consumer rights (quality, promises kept, redress) while creating genuine partnership structures.

    Knowing your rights matters. Following Poland’s model, all students should receive comprehensive training on their rights and responsibilities within 14 days of starting. That shouldn’t be an optional freshers’ week session – it should be mandatory education covering consumer rights, representation opportunities, complaints procedures, support services, and collective responsibilities.

    Crucially, the training should be developed and delivered by the SU. There should be written materials in (both) plain language(s), recorded sessions for those who can’t attend, annual refreshers, and staff trained to respect and uphold these rights. When every graduate understands both their rights and responsibilities, Wales will transform not just higher education but society.

    Protected status and academic adjustments

    Following Portugal’s model, student representatives should get protected status. That means academic adjustments for representative duties, just as providers must accommodate pregnancy or disability. No student should face the choice between failing their degree or fulfilling their democratic mandate.

    Representatives should get justified absences for all activities – not just formal meetings but preparation, consultation, and training. Assessments should be rescheduled without penalty, deadlines adjusted based on representative workload, and attendance requirements modified. Reps should get protection from any form of academic discrimination.

    The Finnish model adds another layer – ideally, student representatives in governance should receive academic credit or remuneration (or both). Learning through representation is learning – about negotiation, governance, and strategic thinking. They are skills that matter in any career.

    Module evaluation as universal engagement

    The Estonian approach shows what’s possible when feedback becomes embedded in academic culture. Making evaluation mandatory for module completion ensures universal participation. But it must be meaningful – published results, documented actions, closed feedback loops. Every student becomes a partner in quality enhancement, not just the engaged few.

    Wales should adopt Estonia’s three-part structure – teaching quality, student engagement, and learning outcomes. This recognises that educational success requires both good teaching and student effort. No more blaming students for poor outcomes while ignoring teaching failures, and no more student satisfaction surveys that ignore whether students are actually engaging with their learning.

    Results should be published within modules – not buried in committee papers but visible where students choose modules. Previous evaluation results, actions taken, ongoing improvements – all should be required to be transparent. Future students should be able to see what they’re signing up for, and current students should see their feedback matters.

    Comprehensive scope of engagement

    Sweden’s clarity is instructive – students must be represented “when decisions or preparations are made that have bearing on their courses or programmes or the situation of students.” There’s no weasel words about “where appropriate” or “when practicable” – if it affects students, students must be involved.

    In the Netherlands, where decisions are made by individuals, not committees, information must be provided and consultation must occur at least 14 days in advance. And written explanations should be required when student recommendations aren’t followed – because accountability matters in managerial decisions.

    Beyond academic structures, students should be represented on professional service boards, IT committees, estates planning groups, marketing focus groups. Decisions about campus facilities or digital systems affect students as much as curriculum design – yet these areas often lack any student voice.

    The digital environment deserves special attention. Student representatives should be involved in decisions about learning platforms, assessment systems and communication tools – not after implementation but during planning. Because digital accessibility and usability directly impact educational success.

    Consent not consultation

    Wales could be bold. Following the Dutch model, some decisions should require student consent, not just consultation. The Code could distinguish clearly between:

    Matters requiring consent (cannot proceed without student agreement):

    • Teaching and Assessment Regulations
    • Significant programme structure changes
    • Student charter content
    • Institutional policy frameworks affecting learners
    • Quality assurance procedures
    • Representation structure and changes
    • Elective module options for the following year

    Matters requiring consultation (mandatory input but not binding):

    • Budget allocations affecting student services
    • Campus development plans
    • Strategic planning
    • Staff appointments affecting students
    • Marketing and recruitment strategies

    Matters governed by a council of staff and students:

    • Student accommodation
    • Student employment
    • Student services and mental health
    • Harassment and sexual misconduct policy

    Matters delegated to the students’ union

    • Student engagement and representation
    • Student activities and volunteering

    This isn’t radical – it’s a recognition that students are genuine partners. No other stakeholder group would accept purely advisory input on regulations governing their activities. Why should students?

    From course reps to citizens

    Another area where Wales could be genuinely radical would take Wales’ vision of students as citizens by going beyond traditional representation structures – broadening “engagement” beyond academic quality.

    The European model of subject-level associations – common from Helsinki to Heidelberg – shows what’s possible. These aren’t just academic societies but genuine communities combining social activities, career development, representation, and civic engagement. They create belonging at the discipline level where students actually identify.

    In Tallinn, departmental student bodies aren’t sideshows but partners in departmental culture. They organise orientation, run mentoring, coordinate with employers, feed into curriculum development – and crucially, they’re funded and recognised as essential, not optional extras.

    In some countries there’s even a “duty of contribution” where students volunteer to help run the institution. Green officers, peer mentors, student ambassadors – multiple routes to engagement beyond traditional representation. Not everyone wants to be a course rep. But everyone can contribute something.

    Even if we’re just talking about student clubs and societies, Wales should mandate that providers support and fund these diverse engagement routes.

    Every student should serve somehow during their studies – it’s citizenship education in practice. Some will be traditional representatives, others will mentor new students, run sustainability initiatives, organise cultural events, support community engagement. All develop democratic skills. All should share responsibility for their community.

    Taking part

    Some countries maintain a tripartite principle for major bodies – equal representation of students, academic staff, and professional staff – to recognise that universities are communities, not hierarchies. Maybe that’s asking too much – but even with a minimum of two students in the room, representation means nothing without support.

    Some countries require that student reps receive all documentation at least five days in advance, training on context and background, briefings on complex issues, and support to participate fully – you can’t contribute if you don’t understand what’s being discussed.

    When new committees or working groups are established, there should be active consideration of student membership with default presumption of inclusion. Decisions and justifications should be communicated to student representatives, and there should be annual reviews of representation effectiveness with evidence-based changes.

    Some countries transform meetings from tokenistic to meaningful. Materials distributed five working days in advance means no ambushing student representatives with complex papers. Everything in accessible language, translated where needed, should be a standard too.

    The Swedish innovation of publishing all decisions and rationales builds accountability. Rather than being buried in minutes, decisions get actively communicated. Students can see what’s decided in their name and why – democracy requires transparency. And committees should pick up minimum student membership levels with voting rights, and there should never (ever) be just one student in a room.

    Funded independence

    Latvia mandates that SUs receive at least 0.5 per cent of institutional income, and minimums were agreed as part of the Australian Universities Accord. This isn’t generous – it’s the minimum needed for effective representation. The Welsh Code should set a minimum as a % of income, or fees – ensuring student bodies have resources to train representatives, gather evidence, and hold institutions accountable.

    Funding should come with independence safeguards. There should be no conditions that compromise advocacy, no reductions for challenging decisions, and protected status even when (especially when) relationships become difficult. Written agreements should protect core funding even during institutional financial difficulties.

    Beyond core funding, providers should be required to supply facilities, administrative support, IT access, and time for representatives. The split between guaranteed core funding for democratic functions and negotiated funding for service delivery would protect both representation and student services.

    Complaints as learning and conduct

    Complaints are a really important part of student engagement – and so the OIA’s Good Practice Framework, which learns from them, should be mandatory, not optional. A proper system treats complaints as valuable intelligence, not irritations to be managed.

    Wales should then go further, automatically converting failed appeals containing service complaints into formal complaints. When patterns emerge, compensation should go to all affected students, not just those who complained. And every provider should be required to publish on what it’s learned from complaints over the past year, and what it’s doing about it – with sign off from the SU.

    The Swedish model’s restrictions on disciplinary proceedings protect students from institutional overreach. Proceedings are only allowed for academic misconduct, disruption of teaching, disruption of operations and harassment. And students are given full procedural rights – including representation, disclosure and presence during evidence.

    Wales should go further. Every student facing disciplinary proceedings should have the right to independent support, and any panel should include student members who are properly trained and supported. Peer judgement matters in community standards.

    And neither disciplinary nor funding processes should ever be used to silence criticism, punish protest, retaliate for complaints or discourage collective action. The free speech protections in OfS’ guidance should be baseline – students’ right to criticise their institution is absolute, whether individually or collectively.

    Disability rights are student rights

    Every year, countless disabled students arrive with hope and ambition, only to find themselves trapped in a Kafkaesque system of “support” that demands disclosure, documentation, negotiation, repetition, and often – silence. If Wales is to lead, then it should be unflinching in acknowledging the daily indignities that disabled students face – and bold in tackling the systemic failures that allow them to persist.

    Adjustments, when granted, are inconsistently implemented, and advocacy, if it exists at all, is fractured and under-resourced. In many departments, reasonable adjustments are still treated as optional extras. Central services write the plans, but academic departments dispute their legitimacy, claiming subject expertise trumps legal obligation. Students are asked to justify, to prove, to persuade – again and again. And often in public – as if their access needs were a debate.

    Disabled students can’t be expected to fight these battles alone. Wales should require institutions to facilitate advocacy, embedded close to academic departments, co-located with SUs where possible, and independent enough to challenge unlawful behaviour when necessary. Not every rep can be an expert in disability law. But every student should have access to someone who is.

    The law is clear – providers have an anticipatory duty. That means planning ahead for the barriers Disabled students face, not waiting until they fall. But few providers conduct serious, evidence-based assessments of their disabled student population by type of impairment, by subject area, by mode of study. Without that, how can anyone claim to be meeting the duty? Wales could also set the tone nationally with a mandatory bank of questions in the NSS that probes access, implementation, and inclusion.

    Wales’ code should mandate that providers move beyond warm words to hard strategy – analysing disability data with student input, mapping gaps, and resourcing change. Every provider should be required to publish a Disability Access Strategy – co-designed with students, informed by evidence, and backed with budget. And implementation should be monitored – not through passive complaints, but active auditing. Where there are failures, there should be automatic remedies – and if patterns persist, the Commission must intervene.

    And briefing all students on disabled students’ rights would help too. If every student understood what disabled students are legally entitled to, fewer adjustments would be denied, more peers would offer solidarity, and institutions would face pressure from all sides to comply with the law. Education here is empowerment – for disabled and non-disabled students alike.

    Wales could lead

    If all of that feels like a lot, that’s because it is.

    But that’s why it was put in primary legislation – to show what’s possible when you take student engagement seriously, to create structures that outlast changes in institutional leadership or political climate, and to graduate citizens who understand democracy because they’ve practiced it.

    But most importantly, to lead:

    The Commission will ensure that Welsh PCET providers lead the UK in learner and student engagement and representation.

    Universities Wales isn’t so sure. In its response to the Regulatory System Consultation it said:

    We do have a number of concerns about regulatory over-reach that can be found in several of the pillars. For example, in the Learner Engagement pillar, the demand for investment of resources and support for learner engagement could be deemed to be a breach of institutional autonomy, particularly in light of this being married to ‘continuous improvement’ – if this ends up being a metric on which the sector is judged, it could be particularly contentious in tight financial circumstances.

    Good grief. It really isn’t a breach of institutional autonomy for students to expect that a little slice of their fees (whether paid by them or not) will be allocated to their active engagement and will be under their control. As Welsh Government put it during the passage of the Bill:

    There is already some excellent learner engagement within the sector, but the prize now is to ensure this is the norm across all types of provisions and for all learners.

    Welsh Government talks about civic mission, distinctive Welsh values, and education for citizenship – in universities, the Code is where rhetoric can meet reality.

    Fine words should become firm requirements, and partnership can stop being what institutions do to students and become what students and institutions do together.

    I know which Wales I’d rather study in. The question now is whether MEDR has the courage to mandate it.

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  • A new regulatory framework is more than Medr by numbers

    A new regulatory framework is more than Medr by numbers

    Medr, the new-ish regulator of tertiary education in Wales, is consulting on its new regulatory system (including conditions of registration and funding, and a quality framework).

    You have until 5pm 18 July 2025 to offer comments on any of the many ideas or potential requirements contained within – there’s also two consultation events to look forward to in early June.

    Regulatory approach

    As we are already aware from the strategy, Medr intends to be a principles-based regulator (learning, collaboration, inclusion, excellence) but this has been finessed into a regulatory philosophy that:

    integrates the strengths of both rules-based (compliance) and outcome-based regulation (continuous improvement)

    As such we also get (in Annex A) a set of regulatory principles that can support this best-of-both-worlds position. The new regulator commits to providing clear guidance and resources, transparent communication, minimising burden, the collaborative development of regulations and processes, regular engagement, proactive monitoring, legal and directive enforcement action, the promotion of best practice, innovation and “responsiveness”, and resilience.

    That’s what the sector gets, but this is a two way thing. In return Medr expects you to offer a commitment to compliance and integrity, to engage with the guidance, act in a transparent way (regarding self-reporting of issues – a “no alarms and no surprises” approach), practice proactive risk management and continuous improvement, collaborate with stakeholders, and respect the authority of Medr and its interventions.

    It’s all nicely aspirational, and (with half an eye on a similar regulator just over Offa’s Dyke) one appropriately based on communication and collaboration. Whatever Medr ends up being, it clearly does not want an antagonistic or suspicious relationship with the sector it regulates.

    Getting stuck in

    The majority of the rest of Annex A deals directly with when and where Medr will intervene. Are you even a regulator if you can’t step in to sort out non-compliance and other outbreaks of outright foolishness? Medr will have conditions of registration and conditions of funding, both of which have statutory scope for intervention – plus other powers to deal with providers it neither registers nor funds (“external providers”, which include those involved in franchise and partnership activities, and are not limited to those in Wales).

    Some of these powers are hangovers from the Higher Education (Wales) 2015 Act, which are already in force – the intention is that the remaining (Tertiary Education and Research Act 2022) powers will largely kick off from 1 August 2026, alongside the new conditions of funding. At this point the TERA 22 powers will supersede the relevant remaining HEW 2015 provision.

    The spurs to intervention are familiar from TERA. The decision to intervene will be primarily based on six factors: seriousness, persistence, provider actions, context, risk, and statutory duties – there’s no set weight accorded to any of them, and the regulator reserves the right to use others as required.

    A range of actions is open in the event of an infraction – ranging from low-level intervention (advice and assistance) to removal from the register and withdrawal of funding. In between these you may see enhanced monitoring, action plans, commissioned reports and other examples of what is euphemistically termed “engagement”. A decision to intervene will be communicated “clearly” to a provider, and Medr “may decide” to publish details of interventions – balancing the potential risks to the provider against the need to promote compliance.

    Specific ongoing registration conditions are also a thing – for registered providers only, obviously – and all of these will be published, as will any variation to conditions. The consultation document bristles with flowcharts and diagrams, setting out clearly the scope for review and appeal for each type of appeal.

    One novelty for those familiar with the English system is the ability of the regulator to refer compliance issues to Welsh Ministers – this specifically applies to governance issues or where a provider is performing “significantly less well than it might in all the circumstances be reasonably expected to perform, or is failing or likely to fail to give an acceptable standard of education or training”. That’s a masterpiece of drafting which offers a lot of scope for government intervention.

    Regulatory framework

    Where would a regulator be without a regulatory framework? Despite a lot of other important aspects in this collection of documents, the statement of conditions of registration in Annex B will likely attract the most attention.

    Financial sustainability is front and centre, with governance and management following close behind. These two also attract supplemental guidance on financial management, financial commitment thresholds, estates management, and charity regulation. Other conditions include quality and continuous improvement, regard to advice and guidance, information provided to prospective students, fee limits, notifications of changes, and charitable status – and there’s further supplemental guidance on reportable events.

    Medr intends to be a risk-based regulator too – and we get an overview of the kinds of monitoring activity that might be in place to support these determinations of risk. There will be an annual assurance return for registered providers, which essentially assures the regulator that the provider’s governing body has done its own assurance of compliance. The rest of the returns are listed as options, but we can feel confident in seeing a financial assurance return, and various data returns, as core – with various other documentation requested on a more adhoc basis.

    And – yes – there will be reportable events: serious incidents that must be reported within five working days, notifiable (less serious) stuff on a “regular basis”. There’s a table in annex B (table 1) but this is broad and non-exhaustive.

    There’s honestly not much in the conditions of registration that is surprising. It is notable that Medr will still need to be told about new financial commitments, either based on a threshold or while in “increased engagement”, and a need to report when it uses assets acquired using public funds as security on financial commitments (it’s comforting to know that exchequer interest is still a thing, in Wales at least).

    The quality and continuous improvement condition is admirably broad – covering the involvement of students in quality assurance processes, with their views taken into account (including a requirement for representation on governing bodies). Responsibility for quality is expected to go all the way up to board level, and the provider is expected to actively engage with external quality assurance. Add in continuous improvement and an expectation of professional development for all staff involved in supporting students and you have an impressively robust framework.

    We need also to discuss the meaning of “guidance” within the Medr expanded universe – providers need to be clear about how they have responded to regulatory guidance and justify any deviation. There’s a specific condition of registration just for that.

    Quality framework

    Annex C provides a quality framework, which underpins and expands on the condition of registration. Medr has a duty to monitor and promote improvement in the quality and standards of quality in tertiary education, and the option in TERA 2022 to publish a framework like this one. It covers the design and delivery of the curriculum, the quality of support offered to learners, arrangements to promote active learner engagement (there’s a learner engagement code out for consultation in the autumn), and the promotion of wellbeing and welfare among learners.

    For now, existing monitoring and engagement plans (Estyn and the QAA) will continue, although Medr has indicated to both that it would like to see methodologies and approaches move closer together across the full regulatory ambit. But:

    In due course we will need to determine whether or not we should formally designate a quality body to assess higher education. Work on this will be carried out to inform the next cycle of external quality assessments. We will also consider whether to adopt a common cycle length for the assessment of all tertiary education.

    There is clarity that the UK Quality Code applies to higher education in Wales, and that internal quality assurance processes need to align to the European Standards and Guidelines for Quality Assurance (ESG) – external quality assurance arrangements currently do, and will continue to, align with ESG as well.

    To follow

    Phase two of this series of consultations will come in October 2025 – followed by registrations opening in the spring of 2026 with the register launched in August of that year. As we’ve seen, bits of the conditions of registration kick in from 1 August 2027 – at which point everything pre-Medr fades into the storied history of Welsh tertiary education.

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