Tag: Wales

  • 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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  • Podcast: Banned algorithms, Schools curriculum, Wales student finance

    Podcast: Banned algorithms, Schools curriculum, Wales student finance

    This week on the podcast we examine the Office for Students’ (OfS) renewed scrutiny of degree classification algorithms and what it means for confidence in standards.

    We explore the balance between institutional autonomy, transparency for students and employers, and the evidence regulators will expect.

    Plus we discuss the government’s response to the Francis review of curriculum and assessment in England, and the Welsh government’s plan to lift the undergraduate fee cap in 2026–27 to align with England with a 2 per cent uplift to student support.

    With Alex Stanley, Vice President for Higher Education of the National Union of Students, Michelle Morgan, Dean of Students at the University of East London, David Kernohan, Deputy Editor at Wonkhe and presented by Mark Leach, Editor-in-Chief at Wonkhe.

    Algorithms aren’t the problem. It’s the classification system they support

    The Office for Students steps on to shaky ground in an attempt to regulate academic standards

    Universities in England can’t ignore the curriculum (and students) that are coming

    Diamond’s a distant memory as Wales plays inflation games with fees and maintenance

    What we still need to talk about when it comes to the LLE

    You can subscribe to the podcast on Apple Podcasts, YouTube Music, Spotify, Acast, Amazon Music, Deezer, RadioPublic, Podchaser, Castbox, Player FM, Stitcher, TuneIn, Luminary or via your favourite app with the RSS feed.

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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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  • Higher education policy: the lie of the land in England and Wales on the cusp of England’s post-16 white paper

    Higher education policy: the lie of the land in England and Wales on the cusp of England’s post-16 white paper

    • This speech was delivered by HEPI Director Nick Hillman at the University of Cardiff on Thursday, 16 October 2025.

    Introduction

    The other day, I was speaking to the University of Liverpool Council at the Ness Botanic Gardens on the Wirral, which as you know is four hours due north of here, pretty much on the Welsh / English border. I started my speech there by noting that I only exist because of the University of Liverpool, as my maternal grandparents met there in the early 1930s. Well, I also only exist because of the Welsh university system, as my parents met while they were students here in Wales in the early 1960s, just as my own children only exist because I met my wife in the early 1990s at university. 

    The fact that three generations of my family originally met while at university is a powerful reminder, at least to me, that higher education change lives. And at HEPI, we had another powerful reminder of that during our first event of this academic year, when – last month – we hosted the UK launch of the OECD’s Education at a Glance publication.

    Education at a Glance

    In case you have not come across it before, this is the most useful but worst titled publication on education that appears anywhere in the world each year. It is a vast 541-page compendium of comparative data that you need to pore over rather than glance at.

    This year’s OECD report had a particular focus on tertiary education. While we have become used to people beating up on the UK higher education sector, the OECD actually painted a picture of a very successful sector playing to its strengths. When you look in from the outside, it seems the UK’s higher education institutions are not so bad after all.

    For example, the OECD showed that, among the many developed countries covered in their report, the UK has:

    • higher than average participation in higher education;
    • lower than average graduate unemployment, irrespective of whether the individuals studied STEM, business or humanities; and
    • among the very highest undergraduate completion rates anywhere in the world, vying with Ireland for the top spot.

    I recognise the OECD is looking at averages for the UK as a whole and the position of Wales is not necessarily the same but, in general, the weaknesses the OECD found in were on the lack of good opportunities for people who do not succeed in education first time around.

    Specifically, the OECD found a profound problem among young men, a rising proportion of whom are classified as NEETs (Not in Employment, Education or Training). While the OECD use historic data for a year or two past, last week’s brand new NEET data for Wales confirms the depressing picture. Indeed, it was even more salutary, noting:

    The proportion of young people aged 16 to 24 in Wales who were not in employment, education or training (NEET) was 15.1% in the year ending June 2025, an increase of 3.6 percentage points over the year.

    The OECD additionally found that the UK has the biggest gap of all developed countries when it comes to the difference in earnings between low-skilled adults and those who leave school with A-Levels (or equivalent). This should perhaps worry Wales even more than the rest of the UK, given that Wales scores the worst for schoolchildren’s academic performance for any part of the UK. Indeed, Wales is the only part of the UK to perform worse than the OECD average in all three areas of Mathematics, Reading and Science.

    When it comes to funding of higher education, the OECD found the UK spends more than most other countries … but the shift to loan-based finance means direct government spending on each student in higher education is only half the OECD average and only half the amount spent ‘at primary to post-secondary non-tertiary levels’ ($13,000). Of course, the UK’s figures are distorted by England’s numbers because England is much larger than the other parts of the UK and has moved towards loans to a greater degree than Scotland, Wales or Northern Ireland. That is one reason why we have worked with London Economics and the Nuffield Foundation to look at the picture in each part of the UK separately.

    There are three profound differences. First, the Exchequer cost is lowest in England, which also has the highest per-student income for institutions. Scotland is at the other end of the scale, with the largest Exchequer cost but the lowest unit-of-resource for institutions. Wales is, as you may expect, somewhere in the middle, with an Exchequer cost and a per-student income for institutions that lies between those in England and Scotland. 

    There is a similar picture when we look – secondly – at the balance of who is paying the costs of higher education. In England, it is mainly former students via the loan system; in Scotland, it is entirely taxpayers (and then some). In Wales there is a more even split approaching 50:50 between the Exchequer and graduates, arguably reflecting the public and private benefits of higher education more accurately. There are probably lessons from Wales for the rest of the UK here, though seemingly not for Kemi Badenoch, who complained at the Conservative Party Conference last week that higher education in England still costs taxpayers too much.

    The third big difference is on student maintenance, where the system in Wales is more generous and more logical than those elsewhere in the UK. Each student gets more and the non-repayable grants are more generous in Wales than elsewhere – all undergraduates have at least a small grant whereas no one currently gets a grant in England, where grants were abolished in 2016. (Ministers promised the return of grants in England at the Labour Conference a fortnight ago, but only for some students on some courses, meaning it is likely to prove a mouse of an intervention and a very complicated one at that. It is certainly set to be nothing like the Welsh system.)

    Many people I know are fans of the system in Wales for the way that it tries to strike a balance. However, while there are certainly far worse systems even within the rest of the UK, I personally think the benefits of the Welsh system are sometimes oversold. For example, I think the structure of student support in Wales is excessively generous to students who come from wealthy households. In other words, it is not means tested enough, perhaps explaining the need for the recent cuts to postgraduate support.

    I have held this view consistently since the current Welsh funding system was introduced on the back of the Diamond review in 2018, but it has got me in trouble. After my concerns reached the front page of the Western Mail, I got not only an official rebuke from the Welsh Government but HEPI also received a formal complaint that came jointly from Universities Wales and NUS Wales. Rather than persuading me to change my view, I must admit this mainly had the effect of making me wonder if higher education debates in Wales are sometimes a little too cosy and stifled.

    Boys, Boys, Boys

    One other area where the OECD painted a less positive picture is on the differential educational performance of young men and young women. Women are more likely to obtain tertiary education across the developed world but the gap between men and women is bigger in the UK than elsewhere and has been growing while it has stayed the same on average across the OECD as a whole. According to the OECD:

    In the United Kingdom, they [women] accounted for 56% of first-time entrants in 2023, up from 55% in 2013. Across the OECD, women make up 54% of new entrants on average, the same share as in 2013.

    This is a convenient segue into some more of HEPI’s recent output because we have long worried about the educational performance of boys and young men and have published a number of papers on the topic over the years, with the most recent one appearing in March 2025. As Mary Curnock Cook wrote in the Foreword:

    Something has surely gone wrong with education if boys – in aggregate at least – do worse than girls at all stages of education from early years to higher education and beyond.

    Overall, out of every 100 female school leavers, 54 proceed to higher education by the age of 19; out of every 100 male school leavers, just 40 do so.

    Again, the problems are worse in Wales than elsewhere. Over half of Inner London school leavers eligible for Free School Meals reach higher education by the age of 19; it is hard to get directly comparable figures for Wales but it seems the numbers are less than half as much for FSM Welsh-domiciled school leavers. Overall, while the gap in school leavers’ entry rates to higher education between men and women is dire in England, it is even worse in Wales. In fact, the proportion of young men who make it to higher education in Wales is lower than in every other part of the UK. It has been a known problem for at least 20 years yet for whatever reason, and perhaps because of misplaced fears of seeming politically incorrect, it has not been addressed.

    Yet if male educational underachievement is not tackled, it seems certain that we will store up further societal problems for the future – including having more under-educated men veering towards the political extremes. Here, I note in passing the high polling of Reform for next year’s Senedd election. It is not rocket science to solve the boy problem, however, to take just one example, some schools following a ‘boy positive’ approach have managed to equalise their results for boys and girls and there is some great work underway in our own sector – for example, at Ulster University and the Arts University Bournemouth.

    What remains completely absent, however, is any concerted interest at a national and ministerial level – certainly at Westminster and as far as I can tell in the Senedd too. People who did not want to take the Black Lives Matter protests seriously a few years ago sought to deflect attention from them by saying ‘All Lives Matter’, as if that was ever in doubt. Similarly, when Ministers wish to deflect attention from the crisis in boys’ education they like to respond by saying things like ‘Opportunity should be available to all’, which is true but it papers over the specific challenges faced by young men.

    Our work on male underachievement sits alongside our work on the disadvantages faced by women, such as our reports on the substantial gender pay gap that remains in higher education as well as our other work on the overall gender pay gap among graduates. It also sits alongside a new HEPI report published just three months ago on the impact of menstruation on undergraduates’ attendance, academic engagement and wellbeing.

    This revealed 70% of female students report being unable to concentrate on their studies or assessments due to period pain and that female students miss an average of 10 study days per academic year due to menstrual symptoms. It also suggested that just 15% of universities have a specific menstruation policy and, for those that do, the policy relates solely to staff rather than students.

    So as I hope you can sense, the topics that tend to work best for HEPI are issues – like boys’ underperformance and the impact of menstruation on learning – that we should be speaking about more than we have done. Another area where that is true is public perceptions of higher education.

    Misperceptions

    A year ago, I had a drink with a neighbour who has a background in banking and two graduate children, meaning – in theory at least – that he knows the value of money and the value of education. However, when it came to universities, he expressed some typical rhetoric about them being too numerous, too big, too expensive and so on.

    I responded by telling him I was on the Board at the University of Manchester and asking him to guess that institution’s financial turnover. His reply was £30 million – which is between 40 and 50 times smaller than the actual number of c.£1.3 billion (and over 20 times smaller than Cardiff’s turnover). Once my hangover had subsided, I contacted Bobby Duffy of the King’s College Policy Institute, who is the UK’s greatest expert on misperceptions – that is, the difference between what is true and what we tend to believe is true. This led over a process of many months to a new research project on what the public think about higher education, which we and King’s College launched the results of last month.

    The findings are worth poring over in detail and we have brought hard copies of the work along for each you. Sone of the results particularly stand out.

    For example, we gave people a list of seven institutions: Manchester City, Manchester United, the University of Manchester, the University of Oxford, the Daily Mail, MoneySupermarket.com and Greggs bakery.

    When the public were asked about the relative financial size of these seven, the University of Oxford came fifth and the University of Manchester seventh, at the very bottom. More than half of respondents said they thought either Manchester City or Manchester United was the biggest in terms of their financial size; only 6% chose the right answer, the University of Oxford. The University of Manchester should be third in that list of seven by the way because, while it easily beats City and United in terms of its financial size, you might be surprised to know that Greggs has a turnover of £2 billion.

    Similarly, when we gave the public a list of five big industries – legal services, accountancy services, aircraft manufacturing, telecommunications and higher education – and asked them to say which is least important in terms of export revenues, higher education was the most popular option. That result could not be any more wrong because higher education actually brings in much more export income than each of the others.

    Let me share three other fascinating data points from the survey with you too:

    • people greatly overestimate the level of graduate regret about going to higher education – on average, the public guess 40% of graduates would opt not to go to university if they had their again, when the actual proportion of graduates who say this is only 8%;
    • on average, the public guess half (49%) of graduates say their university debt has negatively impacted their lives – in reality  only 16% of graduates feel this way; and
    • a majority of people, including a majority of Reform voters at the 2024 general election, have positive feelings about universities.

    Oversight and regulation

    Over the past decade, the oversight of tertiary education and research has been transformed in England, though not necessarily for the better. When I worked as a Special Adviser in Whitehall a dozen years ago, there was one Minister for Universities and Science who sat in one Government Department and who had oversight of one regulator that oversaw both teaching and research (known as the Higher Education Funding Council for England). But in recent years we have had different regulators, different Ministers and different Departments for the teaching and research functions of universities, meaning coordinated oversight has been missing.

    Moreover, while the Westminster Government has promised more ‘clarity and coherence’, the latest Machinery of Government changes have made the current situation even more of a dog’s dinner. The Minister for Skills, who has responsibility for higher education, now has one foot in the Department for Education and another in the Department for Work and Pensions, which has just taken on the responsibility for ‘skills’, while the Minister for Science has one foot in the Department for Science, Innovation and Technology and another in the Department for Energy Security and Net Zero. Split ministerial posts tend to be a recipe for chaos, as I saw close up during my own time in Whitehall.

    So while I know that the new Medr (the Commission for Tertiary Education and Research) here in Wales has had some teething challenges, on paper it makes a lot more sense than what England has. At one point, it was thought England’s long-awaited post-16 skills white paper was likely to be heavily influenced by Wales; given the latest reshuffle and associated changes, that now – perhaps regrettably – seems less likely.

    International students

    Finally, I want to end by touching on the issue of international students. The majority of the really big projects HEPI has undertaken over the past few years have focused on international students. Perhaps that is not surprising, given the OECD data I started with, which shows that, while there is one international student for every thirteen home students across the OECD as a whole, the ratio in the UK is completely different at 1:3.

    That helps to explain why we have calculated (more than once) the net economic benefits of international students to the UK. The latest iteration found a gross benefit of £41.9 billion for just one incoming cohort of students and a net benefit (after taking account of the impact on public services and so on) of £37.4 billion. We split up this total to reveal a number for each one of the 650 parliamentary constituencies across the UK, including Cardiff South and Penarth, which is the top-performing constituency in Wales and one where international students contribute significantly over £300 million a year.

    We have separately calculated the positive tax contributions of those former international students who stay in the UK to work after completing their studies, undertaken detailed studies on the Graduate Route visa and looked specifically at the experience of Chinese students in the UK. In addition, we produce each year a Soft-Power Index that looks at how many very senior world leaders have been educated to a higher level outside of their own home country. If they return home with fond memories of their time in the UK and a better understanding of our country, then this tends to bring real benefits. We will be launching the results for 2025 next week but last year’s Soft-Power Index, which is regularly quoted by Ministers, showed that, across the globe’s 195 countries, there were 58 serving world leaders who received some higher education in the UK, second only to the US.

    I am going to stop here because I started the speech on a positive – on the way higher education changes lives for the better. And despite all the numerous political, financial and geopolitical challenges facing higher education across the UK, the continuing immense soft-power benefits delivered by UK higher education institutions is another area where there is a huge amount of which we can be proud.

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  • Podcast: Wales, Franchising, Graduate Jobs

    Podcast: Wales, Franchising, Graduate Jobs

    This week on the podcast we look at Wales’ emerging higher education settlement, as Universities Wales publishes its manifesto for the May 2026 Senedd elections amid polling that points to a potential Plaid-led administration.

    Plus we discuss new Office for Students’ data on subcontracted (franchised) provision showing weaker continuation, completion and progression outcomes relative to sector averages, and assess the Institute of Student Employers’ latest survey, with graduate hiring down overall but highly variable by sector amid persistently high applications per vacancy.

    With Debbie McVitty, Editor at Wonkhe, Sarah Cowan, Head of Policy (Higher Education and Research) at the British Academy, Sarah Stevens, Director of Strategy at the Russell Group and presented by Jim Dickinson, Associate Editor at Wonkhe.

    Universities Wales election manifesto

    Outcomes data for subcontracted provision

    Graduate jobs and recruitment reality

    You can subscribe to the podcast on Apple Podcasts, YouTube Music, Spotify, Acast, Amazon Music, Deezer, RadioPublic, Podchaser, Castbox, Player FM, Stitcher, TuneIn, Luminary or via your favourite app with the RSS feed.

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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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  • Johnson & Wales University to lay off 91 faculty and staff

    Johnson & Wales University to lay off 91 faculty and staff

    Dive Brief:

    • Johnson & Wales University plans to lay off 91 faculty and staff members — about 5% of its workforce — as it tries to rapidly evolve its operating model, officials said. The cuts will affect its two campuses in Providence, Rhode Island, and Charlotte, North Carolina.
    • The private nonprofit faces an operating deficit of $34 million after more than a decade of enrollment declines. “We simply cannot afford to be the size that we once were, and we believe this reduction will allow us to close a financial deficit and to move forward with a balanced budget,” Chancellor Mim Runey said Monday in a community message.
    • With its cash reserves almost depleted, the university is also delaying salary increases until later this year when officials can “evaluate what is possible,” Runey said.

    Dive Insight:

    To explain why Johnson & Wales is reducing its workforce, Runey pointed to a 54% decline in overall enrollment since fiscal 2012, with headcounts falling from a high of 17,294 to over 8,000 in recent years. 

    The chancellor attributed the shrinking student body to demographic declines, fewer international students and shifting public attitudes about higher education.

    Staffing and budgets, meanwhile, have fallen at a slower pace than enrollment, Runey said, framing the layoffs as rightsizing the university’s operations. 

    “While there is some indication that we are on the right track with enrollment, we do not believe we will return to levels of enrollment that supported a much larger organization and operating budget,” she said.

    The university has already downsized in the recent past. In 2021, Johnson & Wales shuttered its campuses in Florida and Colorado — both of which opened to expand the university during times of growth in the higher education market. 

    Along with reducing expenses, the sale of those former campus buildings added to university’s endowment and reserves. Those reserves, however, have been drained to plug recent budget gaps.

    The university has also pared down the number of senior leaders by about half since 2012, Runey noted. Additionally, it has consolidated academic programs, closed others with low enrollment, reduced jobs through attrition and streamlined aspects of its operations.

    At the same time, Johnson & Wales has invested in a wide array of new programs to try to attract students. Over the past decade, some of those new offerings have “yielded great results while others less so, and some were reduced or discontinued,” Runey said. 

    She also pointed to more recently launched health and wellness programs. Those come with start-up costs such as specialized facilities, faculty and marketing efforts. 

    “These new program investments, while showing great early outcomes, have not yet had time to yield returns that would significantly improve the operational budget,” Runey said.

    That stands in contrast to more rapid enrollment growth other rounds of new programming brought the university in the past, when market conditions were better. 

    “Today we plan with the conservatism that the times demand,” the chancellor said.

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  • Podcast: Wales cuts, mental health, regulation

    Podcast: Wales cuts, mental health, regulation

    This week on the podcast the Welsh government has announced £18.5m in additional capital funding for universities – but questions remain over reserves, job cuts, competition law and student protection.

    Meanwhile, new research reveals student mental health difficulties have tripled in the past seven years, and Universities UK warns that OfS’ new strategy risks expanding regulatory burden rather than focusing on priorities.

    With Andy Westwood, Professor of Public Policy at the University of Manchester, Emma Maslin, Senior Policy and Research Officer at AMOSSHE, Livia Scott, Partnerships Coordinator at Wonkhe and presented by Jim Dickinson, Associate Editor at Wonkhe.

    Read more

    The government’s in a pickle over fees and funding

    As the cuts rain down in Wales, whatever happened to learner protection?

    Partnership and promises are not incompatible

    Student mental health difficulties are on the rise, and so are inequalities

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