There is a familiar tension in any public service. Do you keep improving step by step, or occasionally pause, look at the whole system, and make more substantial changes?
For most of the OIA’s two decades, our Scheme has evolved through careful, incremental development. That has been a strength. It has allowed the sector to understand how the Scheme works, enabled consistency to build over time, and helped the OIA respond to new issues without losing sight of what matters most: fair outcomes, independence, and a process that students can access without cost.
But the context we are operating in has shifted, and it has shifted decisively.
Our 2025 operating report showed demand at record levels. Complaints were up 17 per cent on 2024 and rose above 4,000 in a single year for the first time. At the same time, the number of days taken to resolve complaints has reduced. That combination tells an important story. The OIA is coping with unprecedented volume, and our people are delivering. It also tells us that the way students and providers engage with complaints is changing, and that the Scheme needs to be ready for what comes next.
That is why, during 2026, we will be undertaking a comprehensive review of the OIA Scheme rules and, alongside it, a review of our casework process and how we support early resolution.
This is not a rejection of what has come before. The current Scheme has served students, providers and the wider sector well, and it is respected for good reason. Our aim is to take the Scheme’s core strengths and present them in a clearer, more navigable, more future-proof way. Some of this will involve a change of language, some a change of substance. We want a scheme that remains rigorous and independent, while being easier for students to understand, easier for providers to work with, and more efficient for the OIA to operate at scale.
A move away from talking about “rules” to referencing the scheme as a whole, and with it a more principles-based approach, supported by clearer guidance, will help people understand how decisions are made and what to expect. It will also give greater clarity about how discretion is used, including in cases we decide not to consider.
Why we are doing this now
The first reason for the review is that the Scheme is being used by more students than ever. Behind every complaint is a person who has reached the end of their provider’s process and is looking for an impartial final review. Many students who come to us are doing so at a difficult moment, often while balancing study, finances, health, family responsibilities, or the stress that complaint processes can bring.
A significant proportion are disabled, and many are international students. Some will be engaging with formal systems for the first time, or coming from backgrounds where challenging decisions feels unfamiliar or intimidating. We have a responsibility to make the Scheme as approachable and understandable as possible, while maintaining the high standards of review and decision-making that fairness requires.
Second, we need to modernise how the Scheme is expressed and the language we use. At the moment we talk about “the rules”, which include a great deal of operational and process detail. Over time, that can become hard to follow, particularly for people who only encounter the Scheme when something has already gone wrong. We hear from students, providers and advisers that parts of the Scheme can feel dense, overly procedural, or difficult to interpret. Changing how we talk about and present the scheme will make a difference.
Third, our operating environment is evolving. Our planned expansion in Wales, and changes in the wider regulatory and consumer landscape, mean we need a Scheme that can adapt without constant heavy rewriting of the rules. Creating a clearer separation between core principles and operational detail will give the OIA more flexibility to improve processes, while maintaining transparency about how and why decisions are reached.
What will the review seek to achieve?
We want the refreshed Scheme to:
- set out, in plain language, the principles that guide our casework and the exercise of discretion
- provide a clearer explanation of our role and the boundary between what we can and cannot do
- improve confidence and consistency, for students, providers, and our own people
- support a more flexible and user-focused process, including a thoughtful approach to early resolution
- strengthen learning for the sector, so that complaints lead to improvement as well as redress.
A faster process is in everyone’s interests, but speed is not the only measure that matters. Students and providers need decisions they can understand. They need a process that feels fair, compassionate and proportionate. And the OIA must maintain the independence that underpins trust in the Scheme.
For the sector as a whole
Some things will not change. The Scheme will remain free for students to use. The OIA will remain independent in its decision-making. Our commitment to learning from complaints and supporting improvement across the sector will remain central. Our subscriptions-based funding model will continue.
We are also very conscious that the OIA does not operate in isolation. The Scheme shapes, and is shaped by, provider complaints processes and the work of students’ unions, guilds and student advice services. The interdependence here matters. A scheme that is clearer and easier to navigate should help the sector as a whole, not just the OIA. That is why we want input, challenge and ideas from those who work with students every day, and from providers who are managing complex decisions in a difficult financial climate.
We will run a formal consultation during the spring. I would encourage organisations across the sector, and especially student-focused bodies, to take part. We will bring our own evidence and two decades of practice to the table, but consultation is not a formality. It is a chance to shape a Scheme that remains trusted, fair and effective for the next 20 years.