As financial and regulatory pressures on higher education intensify, the once-hypothetical risk of a large-scale provider exiting the market is becoming increasingly likely.
For government, regulators, providers, and students alike, the implications are far-reaching – and the sector needs to be better prepared.
The risk is growing
Following our previous reflections on this issue we received many messages of interest and support for doing some further work in this area. We also felt there was an opportunity to bring together the experiences of colleagues we have worked with on closures and mergers, and to capture the perspectives of receiving providers and learn from their experiences.
SUMS Consulting reached out to us, offering to support a new project on a pro bono basis. Their expertise in supporting student services and change management, combined with the OIA’s experience of student complaints during provider exits, created a unique opportunity to look at the problem from both a practical and student-centred perspective. We also asked the Committee of University Chairs (CUC) to join the project’s steering group, ensuring governance perspectives were built into the work from the outset.
The risks we highlighted last year have only intensified for students. At the OIA we have seen further complaints from students at smaller providers which have closed in recent months. In these scenarios we see staff working quickly to try to support students at both closing and receiving providers, but there is little legal scaffolding to protect students caught in these situations often leaving them with limited redress.
Lessons from experience
Whilst we recognise that there has been significant positive engagement, discussion and reports in this space, the SUMS and OIA report – Putting Students First – Managing the impact of higher education provider closure – focuses on mitigating the impact on students and specifically learning from the closures and cases the OIA has been involved in. If we don’t take these examples seriously, we risk missing a crucial opportunity to improve outcomes for students.
Over the course of the project, there has been increasing discussion about these policy issues and a ‘playbook’ for market exit is frequently suggested. Whilst neither the SUMS nor the OIA has the expertise or role to produce something quite this detailed and comprehensive, SUMS have gathered insights from university leaders, students’ unions, experts, and those who have dealt directly with closures.
Part one of our report provides the context for the study and collates findings on lessons and effective practice for the sector derived from all the research and information gathering for this study. SUMS also provide some conclusions on the gaps identified by the research and make a series of recommendations for Government, regulators and sector bodies and providers to consider to better support providers navigate exit and help mitigate the impact of future closures on students.
Part two is a separately appended framework (in MS Excel format), which is a summary of the key lessons learnt from the study. The framework is not intended as a comprehensive guide for good institutional governance or achieving financial sustainability. Rather it is intended to provide a checklist of key actions that might be taken by providers to mitigate the risk of exit and, if exit is unavoidable, to help prepare for a managed exit.
Several consistent themes emerged across our discussions – notably the practical disconnects between the current legal, regulatory, financial, and student protection processes. What’s clear is the value of early engagement – acting early and being transparent can reduce the impact on students – but we recognise this is difficult when reputational and commercial pressures are in play. Also it is apparent that receiving providers and students’ unions often play a vital role but aren’t always given the resources or support they need.
We found that student protection is too often treated as a compliance task. If the sector is to avoid repeating past mistakes, this mindset must change.
Moving the conversation forward
This report is not the final word. We see it as a starting point — a resource that will grow over time, as more providers engage with it and share their own experiences. We hope that going forward the framework will continue to evolve – helping shape a more student-centred response. We also hope it will support other initiatives in this space, such as the forthcoming updates to the CUC Governance Code.
Above all, we want to encourage providers, governors, and policymakers to engage in open and honest conversations about the risk of market exit — before it becomes an emergency. Used early, the framework can help institutions strengthen their preparedness, build resilience, and ultimately safeguard the student experience.
What happens next?
We encourage providers and others to review the framework and checklist with leadership and governance teams, integrate its guidance into risk and student protection planning, share feedback to help develop the next iteration of the work.
We hope that this work will help enable honest and open conversations about exit, both within and between providers. We all need to understand that student protection isn’t just a compliance issue – it has a very direct impact on the experiences of students in the system, and we must all be ready.
Ultimately, we need a more collaborative whole sector approach – because when a large-scale provider exits the market suddenly, the impact isn’t isolated – it becomes a sector-wide challenge. Ensuring students are protected must be a shared sector priority.
