Pathway programmes and English for Academic Purposes (EAP) provision play a critical role in UK higher education, particularly in supporting international students’ access to and progression into degree study. Yet this work often sits at the edges of institutional structures: essential to quality assurance and progression outcomes, but administratively misaligned and easily overlooked.
This marginalisation is not incidental. My doctoral research into EAP practitioner career trajectories and professional identity has repeatedly highlighted this pattern. Across institutions, pathway and language-based provision is frequently treated as peripheral, even as universities become increasingly reliant on it. That marginal positioning is reflected in the frameworks used to govern and resource this work, which have not kept pace with the scale or significance of this part of the sector.
Last autumn, I found myself trying to untangle a familiar but increasingly unmanageable example of that gap: how external examiner payment is interpreted, administered and taxed across different parts of the sector. I hold examining roles across several pathway and EAP programmes, and the inconsistencies between them have become so stark that they now raise a genuine question about the sustainability of this work.
Inconsistent and contradictory
The immediate catalyst was a major pathway provider informing me that all external examiner payments must now be processed through PAYE. The reasoning given was that “HMRC requires it”, despite the fact that HMRC has issued no sector-wide instruction of this kind. For those of us with an existing university salary, the impact is straightforward: if a provider uses a D0 tax code and does not adjust fees, the net pay for a full day of examining can fall to a level that no longer reflects the time, expertise or responsibility involved.
The wider issue, however, is not whether PAYE is inherently right or wrong. It is the absence of a coherent, sector-appropriate category for pathway and EAP examining within HMRC’s guidance. The current rules draw a distinction between undergraduate examining (usually PAYE) and postgraduate thesis/viva work (usually treated as self-employment), but pathway and language-based progression programmes fit neither model. They involve sustained moderation, alignment with degree-entry standards, and high-stakes progression decisions across large and internationally diverse cohorts, yet they sit in a policy space that was never designed with them in mind. With no clear HMRC category to fall into, providers are left to interpret the rules in their own way.
As a result, this creates inconsistent and sometimes contradictory practices. One of my roles, delivered through a university-provider partnership, has always been paid via the university’s payroll. The fee is set at a level that makes PAYE workable, even if not ideal. By contrast, provider-operated centres pay significantly lower fees but have now imposed PAYE without adjusting those rates. The result is that identical work, requiring comparable expertise and responsibility, can produce completely different financial outcomes depending solely on which administrative route happens to be used.
All of this is happening at a time when pathway and language-based progression programmes have become integral to the international recruitment strategies of many universities. Decisions made within these programmes shape progression, retention and institutional risk at scale.
Yet the systems that underpin their quality assurance structures have not kept pace with that responsibility. The mismatch between the operational importance of this provision and the legacy tax categories governing external examining only widens the gap between how the sector now functions and how it continues to be administratively regulated.
Clarity is needed
These inconsistencies are more than an irritation. They have real consequences for the external examining workforce in areas of provision that are already structurally undervalued. Pathway and EAP programmes rely heavily on examiners with specialist knowledge: language assessment, curriculum alignment, transnational learning contexts, and the academic transition needs of international students. These are not incidental skills, and they are not easily replaced.
If providers adopt a risk-averse interpretation of HMRC guidance and move to PAYE without adjusting fees, it will increasingly become unviable for experienced examiners, particularly those in higher-rate tax bands, to continue taking on these roles. For colleagues on fractional or fixed-term contracts, the impact may be even more significant. The sector cannot assume that goodwill alone will sustain a system where the financial model no longer bears any relationship to the labour required.
There are some practical steps that would bring much-needed clarity. First, HMRC needs to update its guidance to reflect the types of examining now common in international pathway and EAP provision. Second, providers need to recognise that if they choose (or feel obliged) to adopt PAYE, the associated fees must be set at a level that reflects the tax consequences for examiners. Finally, organisations like BALEAP, QAA and UUKi are well positioned to lead a sector-wide conversation about a clearer and more consistent approach, rather than leaving each provider to interpret the rules alone.
At a time when international recruitment is critical to institutional sustainability, and when progression standards are under increasing scrutiny, the external examining system cannot depend on inconsistent interpretations of outdated tax categories. The work is too important, and the stakes too high, to leave it in a policy gap that undermines both fairness and quality assurance.
