The Post-18 Project is recruiting its first Director

Date:
12 January 2026
01

About us and the role

The Post-18 Project is a new think tank founded in 2025 to shape the policy environment around universities and colleges and provide practical solutions for anyone with a stake in the success of post-18 education in the UK. We bring new thinking, ideas and analysis from experts around education to drive reform of post-18 education in the UK.

Founded by the team behind Wonkhe – the home of the UK higher education debate – The Post-18 Project was initially set up to offer the Labour government in Westminster policy and ideas and solutions, and to develop the most exciting original thinking around the sector. Read the launch essay from our founders: why the time is right for new thinking in post-18 education.

Supported by an established advisory board and group of fellows, we are now looking to appoint our first full-time Director, to lead the project into its second phase of life. We have a plan to grow our footprint and influence to become one of the leading Westminster education-focused think tanks.

We are looking for a talented individual with a keen passion for higher and further education policy and strong understanding of the world of Westminster – the think tanks and other organisations that inhabit it. But as a new organisation, this role requires someone who is comfortable being “chief cook and bottle washer!” We want someone who is a self-starter who shares our ambitions, and is comfortable moving between audiences: talking to policymakers, civil servants, politicians as well as sector audiences, and also with a strong eye on commercial opportunities.

The organisation is currently part of Wonkhe, a private limited company, which would be your employer, and as such you will enjoy the camaraderie and support from the busy and passionate Wonkhe team, as well as our systems and back office functions. You will report to Mark Leach, Chair and co-founder of The Post-18 Project and also Editor in Chief of Wonkhe.

02

How you’ll be spending your time

Writing and publishing

Having established a pipeline of essays and research, we now need to build that out across our areas of focus with further commissions and additional ideas for content. As the Director, and the organisation’s only employee, you will be a central focus of this work: writing, editing, commissioning, publishing and promoting everything we do. Although you will be able to draw on some support from the Wonkhe team, fellows and advisors, you will be primarily responsible for delivering our programme of work (including writing and editing everything from short briefing documents to long form research reports).

Politics and influence

We are not a politically neutral think tank, and are clear that our primary focus is on the current Labour government in Westminster – its policies, ideas and cast of characters. Knowledge about who’s who and a contact book to match would be desirable. Everything The Post-18 Project does should have an eye on influencing policy, and you will have a keen awareness of how to achieve this and ideas for how to get our ideas heard – from organising and hosting roundtables, to liaising with the press and building engagement on social media. You will also be the spokesperson for the Project in the media, so should be comfortable dealing with journalists on and off record and providing insightful analysis to the media about our own work, and in response to government activity too.

Fundraising and commercial

The Post-18 Project is being backed by Wonkhe but we hope in time for it to stand on its own two feet. As such, the Director will be responsible for raising funds for supporting the organisation, with targets mutually agreed and an expectation that commercial income will grow over time to support further growth of the organisation, and other fundraising opportunities will be fully explored.

Other

In conjunction with colleagues, you will be responsible for liaising with the advisory board, keeping them informed and triangulating feedback and arranging meetings.

  • The role is remote, with frequent (twice monthly) travel to London
  • Salary: £DOE
  • Reporting to Mark Leach, Chair
  • The role is imagined as full time but could be part time to suit those with existing commitments, with 0.8 FTE at a likely minimum. We are also open to secondments or loans from organisations for a fixed period of time.

How to apply

To apply please send a CV and covering letter to mark@post18.co.uk by 5pm on Friday 30 January.

Get in touch if you would like an informal chat, and don’t delay in applying – we may appoint if we find the right person before the deadline.

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Earning the license: How to reform university governance in the UK

In a time of increasing challenge for boards, we ask how higher education might reimagine its governance arrangements, learn from models abroad that involve greater participation from different communities, and look to help restore the social licence between universities and the people they serve.

Date:
10 November 2025
Authors:
Mark Leach MBE

“The government is clear that there needs to be a focus on and improvement in providers’ governance. Planning and strategy development within higher education providers, including financial planning, should be supported by the highest standards of governance to ensure realistic planning, robust challenge and the development of sustainable business models”

– Secretary of State for Education Bridget Phillipson in her letter to the chair of the Commons Education Committee in May 2025

“Nothing will be solved if government continues to do things for people, rather than with people”

– Steve Reed, Secretary of State for the Ministry of Housing, Communities and Local Government in his introduction to the government’s Pride in Place strategy

01

Introduction

University governance in the UK has never been under so much pressure. Institutional leaders and their boards face unprecedented challenges – between financial volatility, regulatory complexity, and intense public scrutiny, the volunteer role of governor has become exponentially more demanding. Most governing bodies navigate these pressures admirably. But the structural vulnerabilities exposed by recent high-profile cases suggest that even capable, well-intentioned boards lack the institutional architecture to prevent being blindsided by events.

Meanwhile, policy pressure is pulling the system to greater state interference and pressure. In England, the Westminster government’s post-16 education and skills white paper calls for “stronger governance” and backs the Office for Students’ (OfS) plans to strengthen its management and governance conditions. In Scotland, the Scottish Funding Council (SFC) has published detailed expectations on governance. It is against this backdrop that the Committee of University Chairs (CUC) has launched a review of its governance code.

Across the UK policy system, university governance has moved from technical concern to strategic priority. This attention is unsurprising. High-profile governance issues at some institutions have raised questions about board effectiveness. Franchising partnerships have exposed weak oversight of high-risk arrangements. OfS identifies financial sustainability as a “significant and urgent risk to the sector,” with multiple institutions requiring scrutiny interventions. Student recruitment challenges, inflation pressures, and over-dependence on international student fees have all contributed to creating a volatile operating environment for our current system of governance.

Yet the policy response follows a familiar pattern. The white paper argues that “governing bodies must ensure they have the diverse skills and capability to oversee strategy, plan prudently, understand and manage risk.” OfS proposes stricter regulatory tests, enhanced monitoring, and expanded data audits. The SFC mandates external reviews and systematic breach reporting. All three focus on skills, compliance, and professional expertise – the traditional reform playbook.

But this orthodox approach risks misdiagnosing the problem. Recent governance breakdowns suggest things went wrong not because boards lacked commercially skilled members, but because boards were systematically “managed” by executives, were not provided complete information, and lacked structural mechanisms to access independent perspectives on institutional realities. The real challenge may not be technical capability but structural vulnerability to capture.

This raises more fundamental questions. Much debate on governance concerns what governors are accountable for, but there is much less discussion and reflection about who governors are accountable to. Higher education institutions are neither solely commercial enterprises requiring corporate governance, nor are they public institutions needing bureaucratic oversight. Instead, they are something distinctive: quasi-public organisations serving multiple constituencies with complex accountability relationships. There will rightly continue to be a lively debate about the public or private nature of all forms of higher education provision. We take as axiomatic the principle that where organisations receive public funding or subsidy and exercise public powers they require public legitimacy in which autonomy is appropriately balanced with accountability.

Autonomous higher education institutions’ quasi-public character requires governance approaches distinct from traditional bureaucratic oversight or commercial structures. This paper draws on comparative analysis, particularly governance reform in similar quasi-public institutions in the Netherlands, alongside research on nonprofit governance and UK universities’ own internal dynamics. The evidence suggests that embedding further stakeholder participation within governance arrangements – not as consultation but as structural elements creating countervailing power – may strengthen rather than compromise governance effectiveness.

With governance prominent on policy agendas and all major regulatory bodies publishing new strategies, there is space for serious thinking and the articulation of alternatives to orthodox approaches. The following analysis seeks to contribute to that debate and expand the space for discussion about what the sector can achieve on its own before the march of greater external regulatory pressure gathers additional pace.

02

Recent governance challenges

Understanding governance reform requires examining recent institutional difficulties. This is not to paint a picture of a sector in crisis – most universities remain well run and governed – but it is also true that, in the cases of recent challenges that have made it to the public domain, patterns emerge that illuminate broader structural issues that could cause problems for any shape or size of university.

The University of Dundee provides the clearest example of governance breakdown in recent times. Despite multiple warning signs – including banking covenant breaches, unrealistic budget assumptions, and systematic misreporting – an independent report found that the institution’s senior management and governing body failed to take corrective action until the crisis became unavoidable. The subsequent Gillies investigation found that “the Principal either was aware or should have been aware” of the deteriorating position from March 2024 onwards – yet continued to provide reassuring public statements, while being privately aware of an £8 million budget deficit.

Particularly problematic was the cultural dimension. Staff reported that challenge and dissent were actively discouraged, with few daring to “speak truth to power” in an environment described as exhibiting senior leadership “hubris.” The pattern – defensive cultures and weak challenge – appears across multiple recent governance issues.

De Montfort University faced significant governance questions around financial management and strategic direction. The University of Buckingham experienced leadership instability and questions about board oversight of institutional direction. Franchising arrangements have exposed particularly acute governance weaknesses across a number of other universities, prompting Universities UK, GuildHE and the Committee of University Chairs to publish a framework specifically addressing governance of franchise relationships. Years of inadequate board oversight of high-risk partnerships with private colleges have led to detailed OfS interventions, the possibility of new legislation, new reporting regimes, and tighter restrictions that erode institutional discretion.

The cases reveal boards that failed to understand or adequately scrutinise complex commercial arrangements with significant reputational and financial risks. These are not isolated incidents suggesting universal dysfunction. Many institutions govern themselves effectively. But neither are these outliers easily dismissed as uniquely problematic contexts. They represent structural vulnerabilities in current governance arrangements.

Common threads across these cases include boards being “managed” by executives rather than effectively overseeing them. This management takes multiple forms: control of information flows, discouraging of challenge through cultural pressure, and warning signs missed or dismissed. It is enabled by governing body members lacking independent sources of insight about institutional realities. The current model “works” when vice chancellors are confident, transparent, and competent, and boards are empowered and informed. It falters when executives are weak, insecure, incompetent, or occasionally dishonest – and when boards lack structural mechanisms to recognise they’re being given the runaround.

03

The view from inside governing bodies

Recent survey evidence suggests governance challenges extend beyond high-profile cases. Most governors, understandably, feel loyalty to their institutions and may be reluctant to voice public criticism. Student governors, however, tend to be more candid about their experiences.

In mid-2025, Wonkhe surveyed student governors across 41 UK universities. The findings revealed patterns that illuminate broader governance dynamics. When asked about leadership that “routinely dominates discussions, controls narratives, or makes it difficult for governors to raise concerns,” 95 per cent reported experiencing this to some degree – 68 per cent “a lot” and 27 per cent “a little.” One governor noted: “You are told your job is to manage the VC and SMT but they manage the governors.”

The survey found systematic suppression of dissent, with over half reporting being “shut down, spoken over, or dismissed as obstructive” when challenging decisions. Information control proved critical – 54 per cent frequently experienced late papers or missing documentation, while 37 per cent received unclear financial reports.

Multiple respondents described a disconnect between meetings and reality: “The university that gets presented isn’t the university I was at as a student.” Crucially, only 32 per cent felt confident their governing body could identify serious institutional risks. One captured the dysfunction: “We’re not governors. We’re an audience.”

Further evidence comes from research by Steven Jones and Diane Harris for the Council for the Defence of British Universities. Interviewing governors across more than forty institutions, they found recurring cultural patterns: decision-making concentrated in the hands of a small inner circle of lay chairs and senior executives, information filtered or withheld, and formal meetings stage-managed around pre-determined outcomes.

While governing bodies are formally charged with holding leaders to account and ensuring compliance with regulatory requirements, in practice, their cultures can reinforce hierarchy and maximise compliance rather than enable robust scrutiny. Interviewees described being overwhelmed with paperwork and regulatory obligations that crowded out discussion of academic purpose, community engagement, and values. The result was not robust scrutiny but performative governance in which dissent was marginalised and executive control reinforced.

Composition emerged as a concern. Despite progress on diversity, positions of real influence were most often held by wealthy, retired men from corporate backgrounds. Recruitment to boards was frequently informal – the “tap on the shoulder” rather than open competition – raising questions about transparency, independence, and accountability. As one interviewee put it, appointments were often “convenient for the executive” rather than for the wider university community. Jones’ research suggests that even well-intentioned governors often find themselves sidelined, frustrated by opaque protocols and disempowering cultures.

These findings don’t suggest every institution experiences severe dysfunction. But they reveal how current structures create vulnerability to executive capture of governance processes. When boards depend entirely on management-filtered information, when challenge can be informally discouraged, when those experiencing institutional realities have limited voice, the conditions exist for governance breakdown even where individual governors possess relevant skills and good intentions.

04

The orthodox policy response

The policy response to governance challenges follows a predictable pattern.

The post-16 education and skills white paper states that “governing bodies must ensure they have the diverse skills and capability to oversee strategy, plan prudently, understand and manage risk, challenge, deliver change and put in place sustainable business models.” It suggests governors should be “actively involved in financial management” and “challenge plans robustly where needed.” It adds that “all governing bodies should be “clear on their statutory and fiduciary responsibilities” with “focus on balancing teaching, research and civic activity.”

OfS’ draft strategy proposes ensuring “initial and ongoing regulatory tests are appropriately calibrated,” working with the sector to support “stronger understanding of our management and governance requirements,” and adopting “focused approach to monitoring and compliance where management and governance risks are most acute.” OfS will “increase regulatory requirements placed on institutions engaged in significant partnership activity” and “expand our data audit programme.”

The SFC’s expectations require mandatory external governance effectiveness reviews at least every five years, institutions must self-refer Financial Memorandum breaches, and the SFC will “increase engagement with both internal and external auditors to surface concerns early.” The framework emphasises Audit Committee independence, clear whistleblowing policies, and board training that may become mandatory.

Yet none of this would have been unfamiliar to readers of the Jarratt Report of 1985, which documented structural weaknesses that correspond closely to contemporary governance challenges – fragmented resource allocation, weak strategic planning, passive oversight bodies, and governing body authority eclipsed by executive dominance.

The emphasis on “robust challenge” is crucial – effective governance requires boards capable of challenging executive proposals rather than merely endorsing them.

This orthodox approach rests on three assumptions. First, that governance failures stem primarily from insufficient commercial expertise or financial management capability. Second, that enhanced monitoring and compliance systems can prevent future breakdowns. Third, that sector-led improvement through better training, clearer guidance, and professional development can strengthen governance culture.

These aren’t unreasonable responses. Skills matter. Monitoring serves purposes. Training has value. The Committee of University Chairs’ governance code review may generate useful recommendations. Supporting institutions to “assess and improve their own capabilities” addresses real needs.

Yet this approach has significant limitations. Most fundamentally, it misdiagnoses the core problem. Governance failures haven’t occurred because boards lacked commercially skilled members. The failures occurred because boards were systematically managed by executives, provided with incomplete or misleading information, and lacked structural mechanisms to access independent perspectives on institutional realities.

The emphasis on skills also reflects conceptual confusion about higher education institutions’ character. If they are fundamentally commercial enterprises requiring corporate governance the skills agenda makes sense. But if, as this paper argues, they are quasi-public institutions serving multiple constituencies with complex accountability relationships, commercial expertise may be insufficient or even inappropriate for governance work.

The regulatory intensification that accompanies skills-focused reform creates further problems. Each governance failure triggers more detailed reporting requirements, enhanced monitoring frameworks, and increasingly prescriptive guidance. In England, OfS has evolved from the light-touch market regulator envisioned in 2017 to an increasingly interventionist overseer. OfS strategy’s proposals for stricter regulatory tests, focused monitoring “where risks are most acute,” and expanded data audits continue this trajectory.

This regulatory ratchet reflects a fundamental policy dilemma. Higher education institutions can either develop genuine accountability through governance that commands public trust, or face escalating bureaucratic control as regulators respond to each crisis with expanded oversight powers. The current path leads toward greater direct state management of higher education – precisely the outcome that university autonomy was designed to prevent.

The persistence of governance challenges also creates acute political problems around future sector funding. Ministers facing pressure to support struggling universities confront a classic moral hazard dilemma – without governance reforms that command public confidence, securing additional investment becomes politically challenging.

Universities must make a fresh case for governing themselves responsibly if arguments for increased public investment are to be heard. Governance reform thus becomes a necessary condition for any future funding settlements, not merely an administrative improvement.

05

Why skills aren’t enough: The problem of perspective

The traditional emphasis on recruiting governors with better skills and commercial expertise rests on a flawed theory of governance failure. It assumes the problem is technical capability, and so the solution follows logically – recruit more skilled governors, provide better training, ensure boards include members with “necessary business background.”

Evidence from recent governance breakdowns tells a different story. Dundee’s governing body included financially literate members. They had access to financial reports and risk assessments. Yet the board failed to prevent the crisis because executive management controlled information flows, discouraging challenge through cultural pressure, and board members lacked independent sources of insight about institutional realities.

This reveals the actual mechanism of governance failure. Boards can be “managed” through several interconnected dynamics:

  • Information asymmetry: Governing bodies depend almost entirely on management-provided information. External governors typically visit campus for quarterly meetings, receiving papers prepared by executives. They have limited capacity to verify whether reports accurately reflect institutional conditions or independently assess strategic proposals. When management systematically presents optimistic scenarios or filters negative information, boards lack mechanisms to identify this.
  • Cultural capture: Effective governance requires active challenge of executive proposals. Yet board cultures often discourage dissent, framing questions as disloyal or obstructive. Executives can reinforce this through subtle signals – responding defensively to questions, praising “constructive” governors who support proposals, creating meeting dynamics where challenge feels uncomfortable. Over time, board culture shifts from robust scrutiny to executive deference.
  • Agenda control: Management typically sets board agendas, decides which issues warrant papers, and frames strategic choices. This procedural power enables executives to direct governing body attention toward preferred topics while limiting discussion of areas where scrutiny might prove uncomfortable. Governors may not even realise significant issues aren’t reaching the agenda.
  • Social dynamics: University governing bodies typically include 20+ members meeting 4-6 times annually. This creates dynamics favouring cohesion over challenge. Dissenting voices can be isolated or marginalised. Individual governors may hesitate to question proposals when other board members appear supportive, particularly if they lack independent information suggesting problems.

The problem isn’t that governing bodies need better skills – it’s that they need different perspectives and independent information sources. Someone who has recently experienced the institution as a student or staff member brings fundamentally different knowledge than someone reviewing financial reports. They know when management presentations don’t match operational realities. They have networks providing information independent of executive channels. They experience different social pressures and incentives.

Recent polling reveals universities’ deepening disconnect from the communities they claim to serve. Public First research shows higher education ranking among the lowest public spending priorities, with only six per cent supporting increased university funding compared to 68 per cent prioritising the NHS. The UPP Foundation’s study of public attitudes to higher education exposes the underlying cause – 34 per cent of people have never visited a university, rising to 53 per cent among working-class communities.

This isn’t a failure of communication that can be remedied by better marketing. When a majority of the DE social group has never set foot on a higher education institution’s campus, the problem reflects a fundamental isolation from ordinary people’s lives and priorities. If higher education institutions expect to enjoy public legitimacy, they must embed genuine community participation within governance structures, creating institutional accountability mechanisms that give local voices real power over decisions affecting their areas.

Current governance arrangements create perverse incentives that deepen this disconnect. As documented in our paper Tooling Up, the sector rewards growth in numbers rather than alignment with national or local priorities – pushing institutions toward cheap-to-teach popular degrees over costly but strategically vital subjects, privileging full-time undergraduates over flexible or technical routes, and creating competition that destabilises regional providers without delivering the skills employers need.

This has been the natural consequence of what previous governments had asked for, but governing bodies now dominated by commercial expertise are likely to reinforce these market-driven behaviours, rather than challenging whether institutional strategies serve public purposes.

The post-16 white paper articulates a vision for higher education as “anchors for place, responding to local priorities and needs, working with partners locally.” Yet governing bodies dominated by external experts with limited connection to local communities or institutional realities are likely to struggle to achieve this. If higher education institutions are to function as genuine civic anchors, their governance must reflect that public character through structural participation of students, staff, and community members.

Traditional university governance operates on a fiction – that governors are objective independent figures serving only the institution’s interests. New governors are told they don’t represent students, staff, or their profession, but should exercise independent judgment. This sounds principled, but it obscures a crucial reality: different legitimate interests cannot be wished away.

Students have interests in educational quality and career prospects. Staff have interests in working conditions and academic freedom. Local communities have interests in graduate skills and institutional behaviour. These interests are real, legitimate, and sometimes conflicting.

The current model doesn’t eliminate these interests – it arguably privileges some while excluding others. When boards consist primarily of business leaders, their corporate assumptions about good governance and strategic thinking naturally shape decisions. These aren’t neutral judgments but reflect particular worldviews.

By insisting that governors don’t “represent” anyone, current arrangements prevent open recognition and reconciliation of different legitimate interests. Conflicts get suppressed rather than addressed. Executives can more easily claim proposals serve the institution when no structural voices articulate alternative perspectives.

Higher education institutions are not for-profit companies with clear shareholder interests – they’re quasi-public institutions serving multiple constituencies. The traditional induction process actually captures new governors into existing power structures. “You’re not here to represent X” can really mean “accept management’s framing as the only legitimate one.”

If we set the annual turnover of all of Liverpool’s universities alongside that of Liverpool City Council, the scales are strikingly similar. Yet, while city residents have the vote, scrutiny committees, and multiple ways to hold the council to account, students and staff at universities have no comparable stake in their institutions. That asymmetry matters. If universities expect to enjoy public legitimacy, they must walk the talk – renewing their social licence not just through glossy strategies but by embedding meaningful participative accountability.

A governance model that recognises, articulates, and creates processes to reconcile different legitimate interests would be more honest about what governance actually involves. It would enable boards to make genuinely informed decisions, balancing competing considerations, rather than pretending conflicts don’t exist until they erupt into crises that governing bodies failed to anticipate.

06

Lessons from across the North Sea

The Dutch experience offers instructive parallels. Before comprehensive governance reforms, Dutch educational institutions faced similar patterns – governance crises exposing weak oversight, executive dominance, and boards struggling to provide effective challenge.

The Netherlands’ quasi-public sector emerged from the country’s “pillarised” society, where religious groups built schools and hospitals serving public functions while remaining formally private. After 1945, the Netherlands expanded its welfare state through these hybrid institutions – operating with public money but with formal independence. Over time, that independence proved problematic.

In 2012, a massive Christian education conglomerate called Amarantis serving 30,000 students went bankrupt, requiring an €18 million government bailout. The parallels to recent UK cases are striking. Chairman Bert Molenkamp created an “angstcultuur” (fear culture), suppressing challenge. Multiple oversight bodies failed simultaneously. Financial mismanagement followed familiar patterns – unrealistic projections, inadequate board scrutiny, warning signs dismissed or ignored.

Dutch academic Rienk Goodijk’s analysis of such failures revealed the core problem. Private sector governance models were “blindly copied” to organisations operating in entirely different contexts. Unlike private companies with clear ownership and market disciplines, quasi-public organisations lacked ultimate accountability structures.

Goodijk identified four interconnected structural weaknesses. Information asymmetry left governing bodies dependent on management-filtered reports. A systematic lack of checks and balances enabled dominant management to operate without effective constraint. Uncertainty about governance purpose led to a narrow financial focus rather than a broader assessment of public value. An accountability vacuum meant governing bodies themselves faced little scrutiny of their performance.

Crucially, Goodijk argued that orthodox solutions alone couldn’t address these failures. The problems lay fundamentally in human behaviour and organisational culture rather than technical deficiency. Effective governance requires “courage, time, and practical wisdom rather than just professional knowledge” – a fundamental shift from traditional emphasis on commercial expertise toward capabilities suited to quasi-public contexts.

The Netherlands’ Scientific Council reinforced this analysis. Governance failures weren’t caused by lack of commercial skill, but absence of meaningful internal challenge. The remedy wasn’t more commercial expertise – it was more countervailing power.

The 2016 Amendment of Education Laws to Strengthen Governance Power of Educational Institutions represented the Dutch government’s systematic response to failures like Amarantis. Rather than simply tightening regulatory oversight or demanding better skills, the legislation embedded stakeholder participation and transparency requirements directly into institutional governance structures.

The law introduced several key reforms reflecting stakeholder governance principles. Board appointments must now occur “based on publicly announced appointment profiles” with “involved participation bodies having an advisory voice in establishing those profiles and in appointment and dismissal of board members.” A “reporting obligation for internal governors to the Education Inspectorate when there is reasonable suspicion of mismanagement” created formal whistleblower protections.

Most significantly, the legislation strengthened student and staff participation rights beyond mere consultation. Education councils (similar to UK academic boards) became formal participation bodies with real decision-making power. Student representation councils gained consent rights over key budget lines. These changes reflected recognition that effective governance requires genuine stakeholder engagement rather than tokenistic representation.

The 2021 evaluations of this legislation provide crucial evidence about stakeholder governance potential. The evaluations found that “since implementation… a positive influence on the quality of governance culture could be observed.” Specific improvements were documented across multiple areas, with “consent rights on budget main lines” developing “positively in recent years,” giving students and staff genuine influence over institutional financial decisions – precisely the kind of early intervention mechanism that might have prevented disasters like Amarantis.

The Dutch experience demonstrates that embedding stakeholder participation doesn’t paralyse decision-making or compromise institutional effectiveness. Rather, it creates structural mechanisms for challenge that don’t depend on executive good faith, diversifies information sources beyond management channels, and grounds governance in operational realities rather than abstracted financial models.

The UK’s international commitments through the Bologna Process provide an additional lens on reform. Despite Brexit, the UK remains a member of the European Higher Education Area alongside 48 other countries, committed to shared fundamental values. These explicitly link institutional autonomy to democratic participation, committing member states to ensure staff and student representation as full partners in the governance of autonomous higher education institutions. Rather than leading European thinking on governance, the UK risks becoming a non-compliant outlier, undermining commitments it has formally endorsed while other nations embrace and embed the democratic principles that give institutional autonomy its legitimacy.

07

An alternative approach

The Dutch experience offers principles for governance reform that differ fundamentally from orthodox approaches. Rather than adapting private sector templates or intensifying regulatory compliance, this alternative recognises distinctive requirements of organisations serving public purposes while maintaining operational autonomy.

Central to this approach is understanding that effective governance of quasi-public institutions requires countervailing power, not just better skills. When boards depend entirely on executive-filtered information and lack structural mechanisms for independent challenge, adding more commercially skilled governors doesn’t solve the problem. What’s needed are governance arrangements that create multiple information sources, diverse perspectives that resist executive capture, and stakeholder voices that ground decisions in institutional and community realities.

Strategic partnership between governing bodies and senior management differs from traditional arm’s-length oversight. It involves substantive engagement with policy development while maintaining independence through diverse information sources and stakeholder connections. Governors function as partners in developing organisational strategy rather than distant monitors of management performance. But this partnership works only when boards have the structural capacity to challenge executive proposals through access to independent information and perspectives.

Triangular governance systematically incorporates stakeholder voices as structural elements rather than consultative additions. Students, staff, and community representatives have genuine influence over governance processes, not tokenistic representation. This creates the countervailing power necessary for effective oversight. When executive management knows their proposals will face scrutiny from representatives who experience institutional realities firsthand and have independent information networks, the dynamic shifts from board management toward genuine accountability.

Societal anchoring recognises that quasi-public organisations derive legitimacy from public trust and social value creation rather than purely financial performance. Governing bodies must assess whether institutions serve public purposes and respond to community needs, not merely whether they generate operating surpluses. Community representatives chosen for understanding of local needs and public service commitment ground governance in this broader accountability.

In this model, governing bodies would include substantial student and staff representation with real influence over key decisions. Community representatives would be chosen for understanding of local needs and public service commitment. Academic staff would have stronger voices in governance processes affecting educational and research activities. Information flows would be diversified beyond management-provided reports.

Polling data from Power to Change provides compelling context. Involvement in participatory organisations increases trust in government by 16-17 points, with the effect strengthening through multiple memberships. This demonstrates why governance reform isn’t just an internal university matter but connects to broader issues of legitimacy and trust.

The case for stakeholder participation is strengthened by governance research challenging conventional assumptions about board effectiveness. Academic work on nonprofit governance identifies three distinct modes boards must perform: fiduciary (oversight, compliance, financial stewardship), strategic (setting priorities, deploying resources), and what scholars term “generative” governance.

Generative governance involves critical thinking, questioning assumptions, and framing problems in insightful ways. It asks probing foundational questions: “What is our fundamental purpose?” and “How does this decision align with our core values?” Rather than addressing symptoms, this mode delves into root causes to find more effective, long-term solutions. It involves scenario planning, ethical reflection, and active consideration of how decisions affect employees, students, and communities.

The concept is introduced in Governance as leadership: reframing the work of nonprofit boards, which explores the dangers of preferring harmony and congeniality over productivity and candour, and the way that inhibits the type of meaningful discussions necessary for addressing complex issues. It looks at exploring sensitive subjects, probing, testing, and debating propositions and maintaining civility – all while avoiding dysfunctional politeness and groupthink: “As the board becomes more experienced and comfortable with the generative mode, there will be less need for such ‘contrivances,’ and robust discussions will occur more naturally.”

Crucially, the Dutch research suggests that governors whose experience centres on being students, staff, or community members are particularly suited for generative governance because it requires creativity, deeper engagement, and ability to see beyond apparent metrics in dashboards or risk registers. Their lived experience of institutional realities provides exactly the grounded perspective enabling boards to move beyond superficial monitoring toward genuine understanding of organisational purpose and challenges.

The financial and regulatory pressures facing universities make generative governance more essential, not less. When institutions face unprecedented challenges, boards need fundamental questioning and root-cause analysis that stakeholder governors are uniquely positioned to provide. Systematically including student and staff voices in governance processes improves rather than compromises board effectiveness by bringing exactly this generative capacity to institutional decision-making.

08

Box out: Participation at the University of Twente

The University of Twente is a technical university located in Enschede, Netherlands, serving approximately 12,000 students. Founded in 1961, UT positions itself as an entrepreneurial university focusing on technology, engineering, and applied sciences, with strong emphasis on innovation and practical application.

UT operates a comprehensive multi-level participation system with extensive institutional support. Students and staff democratically elect representatives to bodies ranging from programme committees in each degree course through faculty councils to the institution-wide university council.

Each participation body holds three fundamental rights: consent (some proposals cannot proceed without approval), advice (bodies can provide binding recommendations on some issues), and initiative (they can propose new policies independently on some issues).

The university provides substantial infrastructure to make participation effective:

  • Training and development: Open enrollment courses cover meeting techniques, participation legislation and regulations, and effective council operation. Tailored courses are available for specific councils, with central funding for open programs and council-funded customised training.
  • Resources and support: Each participation body receives dedicated budgets, independent secretariat support, and statutory information rights. The university provides facilities and administrative backing to enable councils to function effectively.
  • Annual participation events: UT hosts yearly conferences bringing together management, council members, and support staff for workshops on participation themes, networking, and idea-sharing.
  • Communications: A dedicated participation magazine showcases stories of student and staff representatives, explains how participation works, and profiles council activities.

Among students, elections generate substantive policy debate between two student parties. UReka campaigns on detailed education policy positions including study requirements, mental health services, and entrepreneurial identity. DAS (De Ambitieuze Student) represents “ambitious students” seeking development beyond studies, emphasising flexible pathways and campus community culture.

This participatory infrastructure creates institutional capacity for what governance scholars identify as generative governance – representatives who understand operational realities while bringing external perspectives and accountability.

09

Participative principles

Enhanced participation would accelerate sound governance – while initial debates might extend meeting times, representatives’ forensic budget analysis would prevent expensive reversals and legal challenges that plague top-down decisions. Student and staff oversight would regularly identify financial discrepancies, procurement irregularities, and compliance breaches early in the decision-making process, enabling swift corrections rather than expensive regulatory interventions later.

When participation councils deployed impact assessments for strategic decisions, they would engage directly with external stakeholders – local communities, employers, and civic organisations – ensuring decisions reflected genuine public needs rather than internal institutional assumptions. The external engagement would create robust accountability mechanisms that strengthened public trust and prevented the reputational damage that comes from decisions made in isolation from community concerns.

Participation would streamline academic governance by incorporating diverse expertise from the outset, reducing the need for costly policy reversals when implementation revealed unforeseen problems. Participative scrutiny would enhance decision quality – students’ evidence-based challenges to curriculum decisions would often identify pedagogical improvements and accessibility issues that saved resources later, while staff oversight would prevent discriminatory practices that trigger expensive legal challenges.

The participatory process would mandate regular engagement with external professional bodies, employers, and community groups, ensuring academic programmes responded to real-world needs and maintained professional accreditation standards. This external accountability would create ongoing public value debates about university priorities, with participation councils regularly hosting public forums where community members directly questioned institutional decisions about local impact, environmental commitments, and social responsibility.

Participatory oversight would create proactive compliance systems – student and staff representatives’ systematic auditing would catch problems early, avoiding the massive costs of formal investigations, funding clawbacks, and reputational damage that resulted from hidden misconduct. Research governance through participation would dramatically improve institutional efficiency by preventing research misconduct, ethical breaches, and funding misuse before they escalated into regulatory sanctions.

These bodies would stage regular public engagement sessions where research priorities faced direct community scrutiny, ensuring academic work addressed genuine social challenges and maintained public support for university funding. Local residents, patient groups, environmental activists, and industry representatives would participate directly in research strategy discussions, creating dynamic public value debates about institutional priorities.

This community engagement would transform universities from ivory towers into responsive public institutions, with participation strategies providing statutory mechanisms for citizens to challenge research directions, demand transparency about commercial partnerships, and ensure academic resources served broader social goods rather than narrow institutional interests.

10

Toward an education governance framework

Such an approach could be phased in with a draft higher education governance framework that would allow for learning and improvement along the way to a new model. A pilot programme of 5-10 volunteer universities could trial different models over three years, backed by capacity-building funding.

The framework would apply to all degree-awarding providers – including private institutions, alternative providers, and overseas campuses – on the principle that public powers require public accountability.

Then a roadmap to implementing a new framework across the sector could look like the one below.

Rather than legislating, government could publish clear expectations covering representation, transparency, and accountability. Higher education institutions would be encouraged – and supported – to adopt the framework voluntarily, and the success or otherwise of this approach will inform government about whether further legislation would be needed in the future.

Under a central new model, allowing for some variation in different types of providers, governing bodies would remain legally responsible for institutional strategy, finances, and compliance, but would be slimmed to no more than 16 members. Membership would be rebalanced to include around 20 per cent student representatives elected democratically, 20 per cent staff representatives spanning academic, professional, and support staff, and 20 per cent community representatives chosen for local knowledge and public service commitment. Remaining members would be appointed for expertise but required to demonstrate understanding of educational purposes. All governors would serve staggered four-year terms with mandatory training on governance, stakeholder engagement, and public value creation.

Education councils would replace senates and academic boards, shifting from advisory forums to bodies with genuine decision-making power over academic matters. Their composition would be one-third students (UG, PGT, PGR), one-third academic staff, and one-third professional staff, all democratically elected. Councils would hold consent powers over academic regulations, degree standards, curriculum frameworks, academic appointments and promotions, and key policies affecting teaching and research. They would hold statutory rights to information.

Alongside this, institutions would be expected to adopt transparency and accountability practices, including publishing governing body papers, decisions and minutes (only narrowly redacted), conducting annual culture audits through independent stakeholder surveys, producing detailed executive pay disclosures, and publishing regular community impact assessments.

To deepen participative accountability, the framework would require annual public meetings where governing bodies report to local communities, student and staff assemblies with direct questioning rights for senior management, and statutory consultation processes on major local decisions. Some of this already happens in the sector, but far from consistently across institutions and issues. These participatory mechanisms would bring universities into line with wider quasi-public bodies where direct accountability is already embedded.

Implementation would be phased, beginning with the largest universities (25,000+ students) where failures have the most systemic impact, and extending to all providers within three years. Universities would submit governance transition plans showing how they intend to adopt the standards in ways that fit their traditions and contexts. To support this, around £10 million in capacity-building funding should be provided for training new governors, building participation systems, resourcing independent secretariats, and strengthening governance culture.

Enforcement would be gradual and proportionate. Initially, non-compliance would trigger support and enhanced monitoring. Over time, persistent failure could escalate to public censure, financial penalties, or – ultimately – suspension of degree-awarding powers. To protect those exercising oversight, stakeholder governors would have legal immunity for good-faith performance of duties, alongside whistleblower protections for reporting governance failures.

The overall aim is to balance autonomy with accountability. By starting with a voluntary standards framework, the reforms create the conditions for institutions to strengthen governance themselves. But the threat of mandation ensures this isn’t optional window dressing – if progress stalls, governments will legislate. The framework therefore preserves institutional diversity while embedding the principles of stakeholder governance, transparency, and public value that are essential to renewing universities’ social licence.

11

A choice, not a crisis

Neither the sector nor its governance is experiencing a universal crisis. Many institutions govern themselves effectively, navigate financial pressures competently, and maintain strong relationships with their communities. But recent challenges at several high-profile institutions, combined with broader financial pressures and changing public expectations, have brought governance to the centre of policy attention.

This creates an opportunity for serious thinking about the fundamental questions that orthodox reform avoids, about who higher education serves, to whom it should be accountable, and how governance structures can create genuine rather than performative oversight while balancing operational autonomy with public accountability.

These proposals may seem radical in the higher education context but they align with changes in the wider public realm.

The Westminster government’s Football Governance Act hardwires fan participation into club governance in a way long absent from English football. It mandates the creation of “shadow boards” of supporters at every club, gives them formal consultation rights over key decisions such as stadium moves or changes to club identity, and ensures ownership and governance structures cannot bypass the communities whose loyalty sustains the sport. The legislation reframes supporters not as passive consumers but as legitimate stakeholders with rights to be heard and respected. The government’s willingness to mandate stakeholder participation in football demonstrates this isn’t a radical idea – it’s becoming mainstream in how we govern institutions with public functions.

The Pride in Place strategy goes further. “This is about local people calling the shots,” the Secretary of State writes. The strategy requires all local authorities to establish effective neighbourhood governance, with decision-making sitting with neighbourhood boards that include residents, local businesses, and community organisations. “Policies are too often done ‘to’ communities, rather than ‘with’ them,” the document states. The solution is structural participation with genuine power.

Higher education institutions are quasi-public bodies. Integrating balance into their funding models, accountability systems and corporate governance structures shouldn’t be something we wait for think tanks to funnel through into Labour policy in a second term. It should be something the sector accelerates now, to prove it has the imagination and courage to embody public service delivery.

The choice facing higher education is whether to seize this moment for serious thinking about governance, or to continue the familiar cycle that has characterised the sector for decades. The latter path is well-worn and leads toward de facto state control disguised as regulatory compliance. The former requires imagination and political will, but it’s the only path that preserves what makes higher education institutions valuable – their capacity to serve public purposes while maintaining the independence that enables them to challenge, question, and advance understanding.

References

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Wetenschappelijke Raad voor het Regeringsbeleid (WRR) (2013) Toezien op publieke belangen: Naar een verruimd perspectief op rijkstoezicht [Safeguarding Public Interests: Towards a Broadened Perspective on National Oversight]. Den Haag: Amsterdam University Press.

Wetenschappelijke Raad voor het Regeringsbeleid (WRR) (2014) Van tweeluik naar driehoeken: Versterking van interne checks and balances bij semipublieke organisaties [From Diptychs to Triangles: Strengthening Internal Checks and Balances in Semi-Public Organisations]. Amsterdam: Amsterdam University Press.

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Mark Leach MBE
Founder & Chair
Mark Leach is the founder and Chair of The Post-18 Project. Mark is also Editor in Chief of Wonkhe – home of the higher education debate – a platform he founded in 2014 after the first part of his career in higher education policy and as a Labour adviser. Mark was appointed MBE for services to higher education in the King’s Birthday Honours in 2023.

Marking the course: Realising the ambitions of the post-16 white paper

On the publication of the government’s post-16 white paper, Debbie McVitty and Mark Leach respond to the challenges it poses both to universities & colleges as well as policymakers, if the ambitions are going to to translate in to real and lasting reform

Date:
27 October 2025
Authors:
Dr Debbie McVitty, Mark Leach MBE
Image: Ikon

Our reforms will bring stability to the sector through a commitment to sustainable funding. And in return we ask universities to focus on their strengths, to specialise and collaborate, and align what they do closely with the needs of the country.

– Bridget Phillipson, Pat McFadden & Liz Kendall. Ministerial foreword to the post-16 education and skills white paper

01

Introduction

Labour came into power with an offer to business, industry, and civil society: work with us to turn the challenging conditions we have inherited into a future we have reason to feel optimistic about. The Labour government’s plan for post-16 education and skills draws on two of the party’s fundamental purposes in government: growth and opportunity.

These are not merely abstract terms; they are about people, and the degree of confidence they can have that if they put their mind to it, they can achieve a bright future for themselves and their families. Inclusive economic growth raises living standards, it increases the amount of secure and fulfilling work available, and it extends people’s opportunities to be part of the new ideas, creativity and innovation that are making exciting things happen around the country.

The Prime Minister’s eye-catching pledge to work towards two-thirds of young people under 25 participating in some form of higher level learning is emblematic of the government’s efforts to work towards a wider distribution of education opportunity across social classes and the country as a whole.

These are values and goals that are (in a non-partisan way) shared with much of the post-18 sector, grounded, in many cases, in direct and deep experience of serving educationally disadvantaged groups.

On a very practical level, leveraging the transformative power of education equates to individuals developing the relevant knowledge and skills to secure good work and careers. But it also means building personal confidence, new social ties and capability to shape the world around them – preparing them to solve problems, and create novel ideas of their own. These aspects of higher education transformation are not in opposition to each other; in the best kinds of education settings they are mutually reinforcing.

As we explored in Tooling Up, long term policy incoherence across FE and HE over the years, combined with policy efforts over the last two decades to drive greater competition in the higher education market, leaves the government with two critical problems: a fragmented post-18 sector with low trust in government and its regulator, and a lack of positive incentives it can offer, beyond further regulation, to unite the sector around its agenda, thanks to the economic conditions it has inherited.

Conscious, perhaps, of the weak hand the government has to play, from the outset Labour ministers have been by turns emollient and combative with the HE sector: sympathetic to the financial pressures facing institutions, supportive of the goals and aspirations of higher education, while being clear that the government expects the sector to fall in with its plans for a tertiary post-16 skills-led system – with a deeply unpopular planned levy on international fees thrown in for good measure.

Even so, as Post-18 Project fellow Debbie McVitty has argued, the sector should be seeing the Prime Minister’s two-thirds participation target as a win – not only because the government has made its aims explicit and trusted higher education institutions to find ways to fall in behind, but also because the priorities the government has chosen are areas in which many heads of institution feel they have much to offer.

The government’s skills agenda is ambitious: a coherent post-16 skills system, spanning everything from young people whose prior educational experience have already left them at high risk of NEET status, to aspiring postgraduates and PhDs, that delivers on national industrial priorities, and makes the UK as a whole more secure, but is rooted in the specific needs and challenges of places and coordinated through strategic (mayoral) authorities.

This new system involves several critical changes in how post-18 education is currently configured:

  1. Collaboration between institutions whether “vertical” FE-HE collaborations or “horizontal” collaborations among post-18 institutions (some of which are, of course, FE colleges) are to be considered desirable where there are opportunities to capture efficiencies, enhance the offer to the region, or realise economies of scale.
  2. Greater specialisation combined with active coordination within regions around defined skills gaps and future skills needs, supported with data and insight from Skills England, and grounded in the presumption that it will in most cases be clear which institution(s) are best placed to meet those needs.
  3. A gradual pivot towards a “building block” approach to education and training, with short courses, skills bootcamps and standalone modules, and defined degree “exit” points at levels four and five, as well as “apprenticeship units,” primarily funded through the Lifelong Learning Entitlement and Growth and Skills Levy offering greater notional flexibility to students and employers on accessing post-18 education opportunity and acquiring skills.

Colleges and universities via the Association of Colleges and Universities UK have signalled to government that they are open to this shift from a competitive framework to a more coordinated one, showcasing in advance of the publication of the white paper various existing FE-HE collaborations and analysing the barriers to building these kinds of collaborative partnerships across the whole system. But an institutional openness to working with government to enact this shift can only ever be the first step – both government and institutions need a detailed understanding and grasp of the material and practical implications of this shift and how that change can be supported.

The post-16 white paper should, then, be the government’s roadmap for the sector, outlining the steps it will take to incentivise or otherwise enable higher education institutions to support and deliver the government’s agenda. As it stands, though, it’s not clear that the government has fully got to grips with the scale of realignment that this might involve, or how this realignment might be incentivised.

Much activity will arise from the measures outlined in the white paper – taskforces, consultations, and even (“when parliamentary time allows”) legislation. Many of these initiatives are undoubtedly desirable in the abstract, such as a taskforce on tackling HE cold spots, the creation of a postgraduate access resource hub, or work to improve the quality of public information for prospective students. But without a systematic route towards systemic change, many of these activities will remain sector busywork, unlikely to deliver material impact – and some of the measures discussed are equally likely to serve to distract from the government’s core agenda.

The policy critique is one thing; but there is arguably a larger issue with the white paper’s technocratic approach in that while it bristles with statistics and evidence, it does not read as being meaningfully grounded in the real concerns of students, communities, or employers as these manifest in lived experience, or introduce significant measures to explore how those concerns might inform the development of post-16 provision on an ongoing basis, for example, through strengthening learner and student voice, community engagement in institutional governance, or incentivising further employer investment in training.

This matters because in difficult economic times, especially for a sector treated, in the words of Secretary of State Bridget Phillipson, as a “political football” by the last government, and now bruised by the international levy proposals, as wrangling commences over the policy detail of the government’s proposals government and sector will need to return to a common sense of the most critical problems holding back individuals, communities, and businesses, and agree a shared mission to tackle these.

Our analysis of the white paper focuses on the most significant policy challenges, requiring the deepest thinking and toughest conversations in the coming months. These are the areas we’ll be focusing on as part of The Post-18 Project in our mission to introduce new thinking, ideas and policy solutions to the post-18 education policy debate.

02

Collaborating, coordinating and specialising

“The government’s vision is that providers will be able to leverage their individual comparative advantage whilst working more closely together to create a compelling regional offer that supports students and drives growth, building on existing good practice across the sector. This could be as simple as providers that are based in the same city sharing back-office functions and estates. More importantly, it could also extend to allowing groupings to emerge which will support more structured regional offers across research, skills, teaching, and research and development.”

The white paper makes no distinction between collaboration and coordination, though both are absolutely material to the delivery of the government’s objectives in different ways.

The choice to collaborate, to coordinate and/or to “specialise” is ultimately, as the white paper observes, a strategic choice on the part of individual institutions guided primarily by a combination of mission and market analysis.

It is not, as the white paper points out, for government to direct the actions of autonomous institutions – though many would argue the government or a designated actor on behalf of government needs to play a much more explicit role in brokering outcomes if an autonomous institution becomes insolvent, thus placing public money and public assets at risk as well as leaving students without recourse. But even outside these extreme cases, there is still more the government could do, or cause to be done, to drive forward these agendas.

For our purposes, we take “collaboration” to specifically mean two or more institutions working together to create a jointly owned resource, service, or product, or a new corporate entity. The drivers for collaboration are typically efficiency but the conversations currently live in the sector are also focused on the opportunities for realising value from collaboration. This policy agenda is making progress under the auspices of the transformation and efficiency taskforce which is well-positioned to delineate the limits of what can be achieved within the current landscape and the conditions under which this agenda could move further and faster, though the government may wish to consider how the scale of collaborative activity could be monitored to determine whether it is actually happening and if not, why not.

Coordinating is a potentially different case, and could be defined as two or more institutions making decisions about their market offer – specifically what is offered or how it is positioned – in light of what the others around them are doing. This could happen to some extent without active inter-institutional communication, with, for example, an internal portfolio review taking a decision to withdraw from offering certain subjects on the grounds that these are not competitive in the current market.

It could also happen in ways that are not obviously anti-competitive, for example, in efforts to create regional curriculum mapping demonstrating pathways from one institution to another to build pathways of opportunity in particular subject areas – though purists might view some activity of this nature as market collusion or restrictions to student choice.

In the Labour imaginary, however, there seems to be an expectation for institutions to go even further to, under the auspices of their strategic authority and Local Skills Improvement Plans, broker collective approaches to tackling skills gaps and addressing future skills needs. We’d argue that activity of this nature is absolutely necessary where the market has failed to deliver the necessary provision or there is insufficient student demand to support multiple providers to offer provision in specific areas, but that there will need to be much more clarity from government and regulators about the contexts in which active market coordination of this nature is permitted and deeper thinking about how it can be incentivised.

Institutions cannot realistically be expected to act against their own interests – and yet it is the institutional pursuit of market share that to some extent has created the instability we currently see in the sector. The government has a role, therefore, not only in removing barriers to collaboration, or coordination, where they are shown to exist – the white paper pledges, for example, to seek clarification from the Competition and Markets Authority on what lawful collaboration means in the post-16 context – but to consider where there are prospective policy interventions to support innovative collaborative efforts to grow the market – particularly in areas of defined skills need. There is also a corollary need for monitoring of provision across regions and the equality impact assessment – while the notion of specialisation may create space for diverse institutions and diverse educational offers to flourish, not every institution is ready to accept every student. There are already subjects that are very hard to study outside the research-intensive part of the sector, and there is always a risk that even with multiple institutions involved none is prepared to add difficult, expensive, or hard to recruit to subjects in their portfolio. It is very hard to see how to sustain a broad portfolio across a group of institutions without some degree of coordination or planning.

Beyond the core question of lawfulness, there are questions of whose interests are served in regional coordination, and what expertise and knowledge is available to inform strategic decision-making. The FE case is instructive here: FE colleges have a duty to have due regard to local skills improvement plans in making decisions about the provision they will offer. But in practice, if a college does not see how it can sustain demand for provision from students it is not in a position to offer it. Knowing there is a skills gap based on labour market intelligence is not necessarily sufficient to cause a response. Providers working together may be able to find ways to share costs, risk, teaching staff or even students through a joint offer. That coordination work will be strengthened still further by involving relevant industry and employer representatives in the oversight of these joint arrangements.

The principle extends to general governance: institutional boards of governors, as the white paper argues, need to be able to have the strategic capability to secure institutional financial sustainability, which may include collaborative ventures and/or coordination with other providers. For individual institutional boards of governors to have due regard for regional needs they arguably need direct engagement and representation from regional stakeholders who are empowered to advocate for the strategic execution of the institutions’ regional development mission, as well as a reasonably well developed knowledge of how regional economic development works in order to understand the material and non-material risks and potential rewards attached to innovation.

“Specialising” appears in the white paper as a corollary to the potential for collaboration and coordination – the assumption being that regional and national needs are better served by diverse institutions doing fewer things to a high standard. The white paper signals that government intends to exercise its prerogative to allocate public funding in line with a revised definition of excellence (in the case of research funding) and strategic imperative (in the case of the Strategic Priorities Grant) that is likely to have material impacts on the sustainability of some research or education provision in particular institutions, which leaders will have to take into consideration in their financial planning.

However, beyond this ominous prospect, this notion of “specialisation” is offered only at the conceptual and speculative level, with some text wondering whether some institutions may “specialise” in a specific type of research, in particular subject areas, or in teaching, while still protecting “important links between research and teaching.” Seen from one perspective these proposals simply describe the system we have already – different kinds of institutions managing a diverse portfolio of research and teaching with, undoubtedly, some provision subsiding other parts. It is also worth noting that institutions that are specialist can face distinctive challenges especially if the costs of delivery exceed the unit of resource – cross subsidy can in some cases make it possible for broad-based institutions to sustain high-quality specialist provision.

If, however, the white paper is pointing towards a more radical reframing of the post-18 ecosystem then there needs to be reckoning with the incentives in which HE providers operate – particularly the dominance of league tables as perceived indicators of institutional prestige and quality and the role of research outputs and reputation in driving the league table positions on which institutions depend to support their recruitment of international students. Government has no direct control over league tables, but if it wants to move towards a more distinctively mixed economy in institutional mission and offer then it will need to offer alternative incentives to balance their powerful draw.

A further undercooked element of this notion of specialisation is the relative homogeneity of the academic contract, specifically in universities, and – as the white paper lightly acknowledges – the narrowness of recognition and reward frameworks for academic performance, which can prioritise research publications at the expense of wider, albeit less easily measurable, impacts. This is a long standing challenge, and is not one that institutions can tackle individually – it requires some level of collective assessment of the changing conditions of academic work, and collective action on future workforce planning to effect systemic change.

Finally, the market effects of private sector provision need to be more fully understood – there is undoubtedly much good quality private provision, including highly specialist and innovative provision, but there is also the observable phenomenon of private providers offering the kind of generic provision on which they can realise significant margins for shareholders, without having to contend with the broader mission-led costs that face providers in the public sector, such as civic engagement. Plans in the white paper are restricted to tackling low quality (in whatever part of the sector that it manifests) through applying restrictions to growth and fee uplifts, and requiring providers of franchised higher education to register with the regulator, but these measures do not really address the ways that the private sector can substantially invest in capturing particular parts of the HE market while not sharing the costs of delivering an HE system that is attuned to public policy objectives.

03

Stackability and portability

“We will expect providers to offer more flexible, modular provision and strengthen progression routes from further education into higher education, supported by transferable credits. We will consult on making student support for level 6 degrees conditional on the inclusion of break points in degree programmes. This marks a significant shift towards a more inclusive and adaptable model of learning, empowering individuals to tailor their educational journey.”

This, it hardly needs pointing out, is not the first time a government has confidently set the ball rolling on credit portability, only to watch that ball swiftly disappear down a rabbit hole of principle-based and practical issues. The Higher Education and Research Act 2017 tasks OfS with a duty to monitor and report on provision for student transfers and the extent to which this provision is used. Additionally, OfS “may” facilitate, encourage, or promote awareness of provisions to enable student transfers. While OfS’ annual reporting has accordingly included available data on the numbers of students who transfer to another provider within a year of starting their course – 1.7 per cent on the last annual count – OfS has not made facilitation of transfer a priority since its inception.

What is now the Lifelong Learning Entitlement provision for flexible student finance was originally proposed in the Augar review of post-18 education and funding – which also recommended the automatic award of level 4 and 5 qualifications for those pursuing a full level 6 degree, noting that this would support credit transfer. The 2021 Skills for Jobs white paper which sought to implement the planned student finance reform included an announcement that the government would “determine how we can best stimulate credit transfer between institutions and courses” – without, ultimately, delivering on that intention, possibly because the operational arrangements for delivering a student finance system organised around credit rather than elapsed time has been the main area of focus ever since.

In that time, however, the financial situation of higher education providers has materially worsened, meaning that the appetite to take a gamble on offering courses in a chunked-up form for lower guaranteed income is likely to be low, especially as early signals suggest the student demand for this kind of modular provision may not be especially high, increasing the risks to institutions. It is wise, therefore, to roll out the LLE over a number of years, focusing on priority areas where there is an appetite to innovate on a smaller scale.

The saga of policy efforts to facilitate “credit transfer” fail, in our view, because “credit” functions admirably to validate the comparability of awards at different levels, but has almost no value as educational currency in the UK system when it comes to determining whether a student has the prior educational attainment that would prepare them to take up a course of study at the next level.

Simultaneously, the notion of breaking higher education programmes into discrete “chunks” of value goes against the pedagogic grain to some extent. Current thinking on best practice in learning design tends towards taking a programme-based approach – this allows for a reduction in the overall volume of assessment, the distribution of critical skills development provision across programmes (rather than trying to cram a wider range of skills into every single module) and the use of synoptic assessments that can allow students to demonstrate accumulated learning across different programme elements.

Increasingly, education leaders tell us, their thinking is that offering a plethora of module choices can create a fragmented experience, increasing the likelihood that students struggle to form connections, both with each other, and between their various learning opportunities. Streamlining the programme – perhaps in tandem with offering greater opportunity for exercising of choices and pursuing interests within particular programme elements – increases the experience of studying as a cohort, ensures students have a more consistent experience, and gives programme leaders a much greater degree of confidence that students are developing the skills and knowledge they were promised.

None of this is a reason to abandon the notion of building a flexible lifelong offer based on discrete but stackable elements across the whole of level 4 and above provision, but it requires much more than simply building the funding infrastructure, complex though that is, and assuming that institutions and students will rally round. To move such provision from the margin to the centre of provision across level 4 and above requires creative thinking about programme design, curriculum, and assessment, as well as integrating flexible modular provision fairly and robustly into arrangements for assessing quality and standards – not to mention tackling the various complexities involved in student data collection and reporting, managing admissions, and logging of awards.

Additionally, as Jim Dickinson has argued in Doing better, getting better a mass higher education system has to be prepared to accommodate the lived realities of diverse students’ learning experience. This principle appears throughout the white paper in discussions on access, inclusion, and general opportunity, but it does not show up in any meaningful sense in a coherent policy agenda to reimagine the full-time student experience to align with the kind of higher education ecosystem the white paper envisages. Paid work, health (not only mental health), academic support for navigating education choices, and designing meaningful learning communities in which students can develop critical self-efficacy, agency, and interpersonal and intercultural skills are all part of a high-quality system, and need to be collectively taken on as an accountability to the nation’s young people.

Whether there needs to be an independent review of higher education, or post-16 education, is now a moot point, but there would be a strong case for convening an independent expert panel on curriculum, assessment, quality, and student experience in a “stackable” post-18 system, not only to work through some of the knottier issues but to cause the kind of productive, creative conversation across the FE and HE sectors that can build real support for executing the shift.

04

Regulation

“The Office for Students will act as a primary regulator for all higher education providers, including Further Education Colleges delivering higher education…We will support the Office for Students in developing a reformed regulatory framework that focuses on driving out pockets of poor performance, strives to continue to improve quality and safeguards the financial health of the system in a balanced and proportionate way…We will empower the Office for Students and UK Research and Innovation to work together to develop a risk-based, coherent approach between the Office for Students’ regulatory and UK Research Innovation’s research responsibilities that delivers the strategic aims and ambitions set out in this paper.”

When it comes to executing the provisions of the white paper for higher education provision all roads lead to OfS. Actions the regulator will need to take as a result of the white paper include:

  • Reviewing degree awarding powers, including developing new higher technical qualification awarding powers
  • Consulting on a new framework for registration incorporating FE colleges offering provision at level 4 and above
  • Implementing new high-level regulatory objectives around supporting beneficial collaboration
  • Creating a more robust process for market entry
  • Strengthening management and governance conditions of registration
  • Strengthening financial monitoring and data collection processes
  • Joining the task and finish group to tackle HE cold spots
  • Reforming regulation of equality of opportunity, including extending access work to postgraduate taught and research provision and otherwise becoming more risk-based
  • Exercising new powers to conduct quality investigations and intervene in cases of low quality
  • Implement tougher standards for franchised provision
  • Work with UCAS and the sector to improve the quality of information available to students
  • Working with government to develop measures of progress in higher education (ie education gain)
  • Assessing the impact of generative artificial intelligence on maintenance of degree standards

Additionally, the OfS quality regime will become toothier, with material impacts on provider finances in the form of recruitment limits and restrictions to inflationary fee uplifts.

This shopping list of regulatory actions is unlikely to raise the spirits of the HE sector, which generally has low trust in the regulator and is deeply sceptical in particular of the legitimacy of using the proposed new integrated quality regime as a basis for determining fee levels.

OfS is clearly on a journey in its efforts to demonstrate regulation that is reasonable, transparent, fair, and proportionate. It is not, in the final analysis, obliged to take the regulatory approach that the sector might prefer, though there is a strong practical case for introducing a greater degree of formal co-regulation in areas where OfS is likely to struggle to sustain the capacity to act at the pace and scale required, or produce regulatory guidance at the level of sophistication that the sector would find valuable.

However, the wider risk for government is arguably less from sector cavilling at aspects of the regulatory regime, than that OfS in focusing on developing and strengthening direct regulation, fails to support the wider sector change and transformation the white paper has set out.

To achieve some of the core objectives of the white paper requires a body that can convene development activity around collaboration and innovative provision, as well as define and enforce regulatory expectations. Much of OfS’ current output actually already exists in the broad “development” space, offering insight and guidance to inform the sector in developing good practice, though it may not be having the impact it could have if OfS had a better relationship with the sector in general.

The white paper seems to indicate that if the only body available to do that developmental work is a regulator then it should be the regulator’s objective to do that work, and proposes to reframe the general objectives of the regulator to accommodate that approach. If that is the case, then government and OfS should jointly consider how OfS can more actively and visibly differentiate between its oversight and accountability functions, and its development and insight functions. This could potentially create space for the sector to engage in shaping the latter, put forward ideas, and frame significant developmental structural challenges without fear of triggering unwarranted regulatory attention or coming up against existing regulatory shibboleths.

05

Conclusion

The Labour government is facing significant political and economic headwinds and any optimism that a return to a technocratic approach to policymaking will reassure the public has long since dissipated.

If Labour is looking for a compelling story to tell it could do worse than embracing the potential of its post-16 sector to make a real difference in the lives of individuals, communities and regions.

The government has offered an ambitious agenda in the post-16 white paper. But for those changes to manifest in people’s lives it will need to enlist the support of the sector to tackle the longstanding and deep challenges that have stymied policymakers with similar ambitions in the past.

References

Department for Education (2025) Post-16 Education and Skills. CP 1412. London: Crown copyright.
UK Parliament (2017) Higher Education and Research Act 2017. London: The Stationery Office.
Office for Students (n.d.) Evaluation of the higher education short course trial. Available at: https://www.officeforstudents.org.uk/publications/evaluation-of-the-higher-education-short-course-trial/

Augar, P. (Chair) (2019) Independent panel report to the Review of Post-18 Education and Funding. CP 117. London: Department for Education.

Office for Students (2025) Annual report and accounts 2024-25. London: Office for Students.
Department for Education (2021) Skills for jobs: lifelong learning for opportunity and growth. CP 380. London: Crown copyright.

The Post-18 Project (n.d.) Tooling up. Available at: https://post18.co.uk/tooling-up/

Association of Colleges and Universities UK (n.d.) Universities and colleges unite to call for overhaul of post-16 education system. Available at: https://www.aoc.co.uk/news-campaigns-parliament/aoc-newsroom/universities-and-colleges-unite-to-call-for-overhaul-of-post-16-education-system

The Post-18 Project (n.d.) Doing better, getting better. Available at: https://post18.co.uk/doing-better-getting-better/

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Marking the course

Dr Debbie McVitty
Fellow
Debbie McVitty is Editor of Wonkhe and an honorary fellow of the School of Education at the University of Birmingham. Debbie is a former chief of staff at Universities UK, director of policy at the University of Bedfordshire, and head of policy at the National Union of Students.
Mark Leach MBE
Founder & Chair
Mark Leach is the founder and Chair of The Post-18 Project. Mark is also Editor in Chief of Wonkhe – home of the higher education debate – a platform he founded in 2014 after the first part of his career in higher education policy and as a Labour adviser. Mark was appointed MBE for services to higher education in the King’s Birthday Honours in 2023.

Doing better, getting better: Getting a grip on the full-time student experience

How ten foundational rights for UK university students including a liveable income, affordable housing, flexible study to accommodate work, and genuine power in decision-making, could transform the student experience.

Date:
7 July 2025
Authors:
Jim Dickinson
Image: Ikon
01

Introduction

The UK’s higher education system enjoys global respect for its academic standards, research innovation, historic institutions, and consistent high rankings. This global standing, however, sits in contrast to the lived student experience — with the highest domestic tuition fees in Europe, low levels of satisfaction with value for money, growing levels of regret, and increasing concerns about mental health and financial sustainability.

The current system was designed for a world that no longer exists. Today’s students juggle competing demands – 68 per cent work during term time to supplement living costs, with 24 per cent of home domiciled full-time students working to provide financial support to family members. Tightening finances mean many live increasingly far from campus, with 63 per cent of financially comfortable students reporting satisfaction with their academic experience compared to just 21 per cent facing major financial difficulties.

Students today navigate a fundamentally different world than previous generations. The extended “middle stage” of life that higher education now occupies has stretched beyond traditional expectations. While past generations typically achieved key adulthood markers (marriage, homeownership, parenthood) shortly after graduation, today’s graduates face these milestones much later, with average marriage ages exceeding 38, and both first-time buyers and new parents average around 35.

This extended middle stage displays specific characteristics – identity exploration as students decide who they are and what they want from work, education, and relationships; instability marked by repeated residence changes and multiple careers; self-focus as they explore options before lifelong commitments; feeling in-between – taking self-responsibility without completely feeling adult; and belief in possibilities for upward mobility.

Throughout the waves of higher education expansion, particularly since the 1992 conversion of polytechnics to universities, we’ve paid little attention to how massification affects the fundamentals of student experience. The traditional model, designed for a small elite transitioning quickly to careers and adult independence, is now expected to serve a mass system of diverse students navigating a much more complex and extended transition.

The pandemic, too, exposed fundamental contradictions in our approach to higher education. When institutions ran at 30 per cent campus capacity but 100 per cent residential occupancy, the focus on facilities rather than lives betrayed a misunderstanding of what students actually need. While universities remain resistant to change, clinging to entrenched assumptions around and models of academic delivery and assessment, successive governments have clung to an outdated coming-of-age experience. Yet simultaneously, voices argue for unbundling, convinced students would embrace pick-and-mix approaches if available.

Both miss the point. The persistent demand for full-time student status isn’t just about qualifications or “growing up”, it’s about what being a student offers in this middle stage – a structured yet flexible environment and socially rich settings to explore identity and relationships, all within a framework that postpones rather than accelerates the seemingly bleak pressures of full adulthood.

Our traditional understanding of the full-time student has collapsed, and will continue to collapse further. Many students now work nearly full-time hours alongside their studies, with average working students spending 50 hours per week on work and study combined – well above the 36.6 hours the ONS reports for the working population in general. When combined with long commutes, rising living costs, and insufficient maintenance support, the result is a student body unable to engage with their education in the ways our system idealises.

Student communities have become more diverse – in background, experience, and need – but our systems haven’t kept pace. The student finance system lacks connection to real living costs. Representation structures persist from an era when surveys were on paper. Urban areas strategies fail to incorporate students as citizens rather than economic assets. And safeguarding approaches remain piecemeal rather than strategic.

This matters not just for students themselves, but for the UK’s broader economic challenges. As productivity stagnates and skills gaps widen, a higher education system that fails to develop human capital to its full potential represents a profound economic vulnerability. Our competitors are investing in higher education structures that develop not just academic skills but social capital, civic engagement, and practical competence. If the UK fails to adapt, our international standing will rapidly erode – despite our historic advantages.

The benefits of transforming the student experience extend far beyond individual satisfaction. For government, it means more productive graduates with stronger civic commitment; for universities, it offers improved engagement, better alumni support, and stronger community integration; for employers, it provides graduates with practical skills and adaptability; for society, it generates problem-solvers who bridge social divides rather than exacerbate them.

The solution isn’t making the experience cheaper, faster, or more episodic – but making it richer, more meaningful, and better suited to the realities of this extended “middle stage” of life. It requires a fundamental and comprehensive reimagining of what full-time students are entitled to expect from a higher education experience and who bears responsibility for delivering it. It’s not about indulging student demands – but ensuring that higher education fulfills its purpose in a society that has fundamentally changed since our current structures were established.

02

Getting a grip – the case for government intervention

For decades, ministerial engagement with higher education has been dominated by market management and reactive responses to newspaper headlines about “low value” courses or grade inflation. This approach has created a regulatory architecture built around principles of choice, rules, information, and complaint – assuming consumer power and competition will naturally produce diversity and excellence. Students expect and deserve more comprehensive stewardship – not just oversight that punishes deviation, but a positive vision for what the system should deliver and how it should nurture students’ potential to contribute to society.

Just as laws safeguard citizens in other markets, students deserve legal protections for their significant investment. Government should shape a regulatory framework that ensures that universities deliver on core entitlements – not as state interference but legitimate expectation-setting for institutions benefiting from public financial mechanisms. Cross-departmental coordination is also essential to address challenges extending beyond education – including health, housing, and financial sustainability, ensuring students’ rights are protected across all domains of public policy.

The great paradox of recent ministerial approaches is that supposed autonomy of market-based policies have produced striking conformity rather than diversity. Institutions compete on the same metrics, chase the same rankings, and increasingly offer similar educational experiences. True stewardship requires encouraging genuine diversity – not just in institutional types but within degree structures themselves, enabling students to craft educational journeys that reflect their unique aspirations and society’s diverse needs.

Research consistently shows that students regret the extreme subject specialisation that characterises UK higher education. The narrow focus contributes to the perception that graduates lack practical skills and workplace readiness. Ministers should actively work to reverse this trend, encouraging more flexible, interdisciplinary approaches that maintain intellectual rigour while reducing graduate regret and enhancing adaptability. In a rapidly changing world, the ability to integrate knowledge from multiple domains is increasingly valuable, yet our system pushes students into narrower and narrower channels.

If we truly seek a level playing field, we must consider the whole student experience. Currently, socioeconomically advantaged students supplement their thinning curriculum with extensive extracurricular activities, internships, and networking opportunities – building cultural capital and social connections alongside their academic credentials. Meanwhile, disadvantaged students often receive just the curriculum while juggling work commitments and financial stress. Ministers must intervene (including with professional and statutory regulatory bodies) to rebalance the system, prioritising breadth of access over depth of specialisation. In a mass higher education system, it’s arguably more important that more students develop some understanding of a foreign language, for example, than producing fewer language specialists with exhaustive knowledge.

Government should establish clear minimum entitlements for all students as a condition of access to the subsidised loan book, while actively encouraging innovation and differentiation between providers and within courses. For instance, European initiatives now enable students to earn degrees by studying at multiple universities – a model that should inspire similar flexibility in the UK. Rather than treating autonomy as an excuse for neglect, ministers should use their influence to shape a more diverse, responsive system that better serves students’ varied needs and aspirations.

Unlike many European counterparts, the UK lacks a council of stakeholders to advise ministers and the Department for Education on system change, priorities, and effectiveness measures. Such a body – comprising students, academics, employers, community representatives, and experts – could provide vital input without yielding to producer capture. By formalising stakeholder consultation, ministers would gain broader perspective while maintaining democratic accountability for final decisions.

The current regulatory landscape is also wildly complex, with responsibilities fragmented across multiple bodies and departments. A new Higher Education Council should advise government on streamlining this system, with ministers articulating clear priorities and universal entitlements required for access to the subsidised loan book. This would bring coherence to what has become an increasingly opaque regulatory thicket.

To create a more effective system architecture, the following structure should therefore be established:

  • Genuine ministerial stewardship with clear articulation of expectations
  • A Higher Education Council with substantial student representation providing independent advice
  • A cross-departmental unit in government that recognises the unique status, role and situation of full-time students across public policy
  • A funding and corporate governance regulatory function housed inside the Department for Education
  • A dedicated student interests regulator coordinating campus ombuds services
  • A peer-based education quality assurance body, operating at faculty/subject level, similar to the former QAA model
  • Required democratic structures and participation mechanisms within public providers
  • A consistent focus on empowering students with rights and entitlements

The approach would separate funding and corporate governance aspects of regulation from both education quality assurance and student rights protection. The latter should be entrusted to a retooled Office of the Independent Adjudicator that coordinates campus ombuds services (shared between institutions where providers are small) and broadens its policy development and enforcement work on student rights.

Above all, ministers should not fear setting out clear conditions for access to the publicly subsidised loan book. This isn’t overreach, but the responsible exercise of stewardship over significant public investment and the interests of students who ultimately bear the financial burden of that investment. Establishing clear expectations while encouraging innovation within that framework means that ministers can shape a higher education system that delivers for students, employers, and society alike – replacing homogeneity with purposeful diversity, and bureaucratic compliance with genuine accountability.

We propose ten foundational entitlements that should form the universal baseline of the full-time student experience in the UK. These entitlements recognise both the changed realities facing today’s students and the continuing importance of higher education as a transformative period of development and growth. They also represent aspects that should be universal, rather than left to providers to compete over. By enshrining these rights and establishing clear lines of accountability for their delivery, we can ensure the UK’s higher education system maintains its global standing while better serving the needs of contemporary students.

1. The right to get in – and support to get on

2. The right to meaningful learning, not meaningless metrics

3. The right to a liveable minimum income

4. The right to earn while you learn (and learn while you earn)

5. The right to safety – not to shrink, but to stretch

6. The right to connect – and to contribute

7. The right to community – not just curriculum

8. The right to be well – because good health makes learning possible

9. The right to power, not just provision

10. The right to shared investment – with shared responsibility

A note on devolution: For brevity and clarity, this paper primarily references Westminster government departments, regulators in England (particularly the Office for Students), and the student finance system as it operates in England. However, the fundamental principles and entitlements outlined here are intended to apply UK-wide.

While Scotland, Wales, and Northern Ireland have their own distinct approaches to higher education funding, regulation, and student support – students across all four nations face similar challenges around housing affordability, employment pressures, mental health support, and meaningful representation.

The ten entitlements proposed should be seen as universal rights that transcend the specific regulatory and funding mechanisms of each nation. Where implementation would differ due to devolved responsibilities, the core principle remains – all full-time students in the UK deserve these fundamental protections and opportunities, regardless of where they study.

03

The right to get in and then to get on

Full-time students should have the right to structured, explicit guidance on the academic, social, and practical competencies necessary for success in higher education.

Students should then have a legal right to structured transitions into higher education, with guarantees of support for academic, social and practical competencies development.

In the last decade, evidence suggests that more and more students aren’t prepared when they arrive at university. They are more socially diverse, and more varied in their educational backgrounds. They’re often recruited on potential rather than achievement, suggesting we need to help them convert that potential into achievement within our frameworks. Students often experience the same “induction” – but not the same preparation. They all get guides on student budgeting – but don’t have the same budgets.

The environments they enrol into are much more complex than before – bigger, more impersonal, more expensive and more demanding. They might get a campus tour, or a timetable, or a library induction – but navigation is about confidence as much as it’s about maps. And the move to massification has made learning from mistakes harder. The pressure to get a First or a distinction is intense. Having space to get something wrong in formative assessment feels like a luxury if you’re working 30 hours a week.

The solutions have typically been pre-course initiatives. International students arrive early. Summer schools exist for first-in-family students. Online interventions – on everything from sexual consent to academic integrity – are hurled at students in August before they start shopping for duvets. They often feel like ways tick boxes rather than deliver development – sometimes literally.

Some initiatives happen at the start of term. Welcome weeks are now so packed with induction activities that they’re often more overwhelming than the socialising. The message is simple – you have seven days to make friends, learn about diversity, navigate the campus and buy books – and then you’ll be “ready”.

Yet thousands still won’t be – especially if they are first in family, entered through Clearing, are from another country, or in any other way deviate from the mythical “normal” student that even diverse campuses default to. When we survey them at the end of their course through the National Student Survey (NSS), in part universities and students learn what they needed when it’s too late to do anything about it.

Across the Atlantic, universities long ago recognised this challenge. In the US, universities require or recommend new student modules – often semester-long and covering everything from campus tours to group work, diversity classes and consent education. Real time and space is made for nurture – for students to discover and make connections, to navigate complexity and build the social capital they need to thrive.

There are many UK and European initiatives reframing the first year as formative. But they’re often piecemeal, poorly funded, subject-specific, or hobbyist in nature, colliding with traditional academic structures developed in a different era.

We need a step change – dedicating significant portions of time, budget and credit to provide support for inexperienced students to realise their potential. Five aspects can make this work:

  • First, we need student attribute frameworks that integrate the knowledge, understanding and skills enabling success at university. These should reveal the secrets typically passed through families with higher education history. This goes beyond mere transition – students need to become something new.
  • Second, incoming students should reflect on where they stand relative to this framework. A national pre-arrival questionnaire and local peer-interview would help course leaders understand their cohort and prompt students to plan their development.
  • Third, developing against this framework should be credit-bearing, with portfolio submission at the end of first year or first term for postgraduates.
  • Fourth, supporting student success should be a community effort involving more experienced students, professional services, students’ unions, community partners and alumni. Students should see aspects of their development as self-directed discovery, potentially supported by apps, badges or gamification.
  • Finally, some aspects should be tested. If we’re serious about consent, diversity, or academic integrity, we need minimum standards. Just as one can fail a driving test or employment probation, it should be possible to fail at being a student – but with the benefit that fewer would then fail to continue, complete or progress.

 

This approach would help all students develop social capital – links with similar people, links with different people, and links with institutions and communities that foster good citizenship.

A student attributes framework would create a fairer level playing field. It’s true that some students know the secret codes to success and have resources to deploy them. But while it’s important for international students to learn idioms and first-in-family students to know the value of societies, it’s equally important that “traditional” students open their minds to others rather than expecting others to become like them.

All students should have the statutory right to a comprehensive student tutoring scheme, funded through combined government, public health and community resources. These structured programmes – facilitated by students’ unions with dedicated funding – see continuing students leading and facilitating groups new students before term begins, providing academic mentoring, social integration, and wellbeing support throughout the crucial first semester.

These proven schemes improve belonging, retention, and outcomes, particularly for disadvantaged students. Beyond orientation, they offer an efficient vehicle for delivering developmental content through trusted peer relationships rather than fragmented institutional initiatives. Universities must be legally required to resource these schemes, while SUs should be empowered to coordinate training and ensure diverse tutor recruitment.

A reformed entry system should include a national entrance exam covering essential PSHE competencies alongside academic requirements. This would be paired with an end-of-first-semester assessment of fundamental “I’m a student” skills and knowledge – from academic integrity to time management, and a deeper understanding of rights and policies.

Students failing this assessment would have their first semester’s tuition debt cancelled and receive guidance on alternatives, creating both consumer protection and accountability for universities to properly support transition. This approach ensures clearer expectations, better onboarding investment, and prevents unsuitable candidates from accumulating debt for educational experiences they aren’t prepared to navigate.

For this entitlement to become reality, students need:

  • Structured, credit-bearing transitions into university life, with pre-arrival surveys, self-assessment tools, sufficient curriculum time, and portfolio submissions at the end of first year – backed by a legal right to guaranteed support for academic, social, and practical competencies.
  • National standards and assessments including a PSHE-based examination, minimum standards testing (e.g. consent, diversity, academic integrity), and end-of-semester evaluations – with debt cancellation protections for students not yet ready.
  • Comprehensive student success frameworks that integrate knowledge, understanding, and essential skills, clearly aligned with institutional expectations and embedded into the first-year journey.
  • Community-supported success models involving students’ unions, professional services, alumni, and local partners working collaboratively to support the student journey.
  • Statutory entitlement to and investment in peer-led support, including fully funded group social mentoring schemes facilitated by students’ unions to ensure academic equity and mutual empowerment.

Government should establish a statutory framework for student transitions that guarantees every student access to structured onboarding programmes with dedicated curriculum time. This should include national standards for transition support, legal protection for students who discover higher education isn’t right for them, and specific funding for peer mentoring schemes. Universities must be required by law to properly resource these transition programmes, with outcomes monitored through retention and progression metrics focused on students from diverse backgrounds.

04

The right to meaningful learning, not meaningless metrics

Full-time students should have the right to an education that prepares them for a rapidly evolving world, focusing on skills that AI cannot replace while ensuring assessment authenticity and meaningful skills development.

The future of higher education depends on nurturing distinctly human capabilities – critical thinking, ethical judgment, and collaborative innovation – rather than competing with machines at tasks they increasingly do better than we do.

One of the things that became very clear as soon as OpenAI launched ChatGPT was that the way higher education tends to assess students is doomed. The asynchronous assessment of digital assets – produced without supervision – as a way of assessing students’ learning will never again be reliable. There’s no way to prove they made it, and even if they did, it’s increasingly clear that it doesn’t necessarily signal that they’ve learned anything when they did.

Even if universities could prove that students made it, the world – the public, employers, parents, professional accreditation bodies – won’t believe it. And if the technology continues to develop at the pace that it is, the uncomfortable truth is that knowledge synthesis and writing may well come to be seen like plate spinning, glass blowing or weaving – interesting specialist skills that neither students nor the public are willing to underwrite 50 per cent of the population to learn.

To the extent to which a “position” on AI has been settling in higher education, universities are keen to stress that AI is the future and keen to embrace it for all sorts of good reasons, albeit tempered by some ethical concerns. They are also keen to rule out some usage of AI where it allows a student to pretend that they have learned something or mastered a skill when they haven’t. There is a clear sense, for the time being at least, that assessment still matters and that it is important for universities to move towards more authentic forms of assessment.

On the “embrace” question, there are important issues surrounding staff development, subject practice and differential levels of access to subscription-based tools. But capacity to keep up is not evenly distributed between students, academic staff or universities. On the “detection” question, those that intend to cheat when producing a digital asset can do so with complete impunity. Detection tools for flagging AI-produced content or verifying identity during remote assessment are either unreliable or produce “false flags” in ways that are unacceptably discriminatory in a system funded by international students.

On assessment authenticity, it is clear that this is easier in some subject areas than others. The prevailing economic model of higher education – involving cross-subsidies from mass participation in “cheap to teach” subjects – prevents authentic assessment where the staff-student ratio is high. The uncomfortable truth is that if universities must persist with assessing and grading students, they’ll need to shift to supervising students’ production of things and/or engaging with them synchronously. And as a result, given the time and resources available to students and staff, they’ll almost certainly need to do less of it.

But the bigger issue isn’t that assessment won’t work or that our meaning of cheating will change. It’s that if synthesising, processing and summarising existing information is now easily automated, it rips the heart out of almost every undergraduate degree – because it develops skills that society may no longer need.

Surveys suggest students do not understand what AI tools they are allowed to use – not least because guidelines change regularly and may differ between courses. A particular issue concerns tools that assist with cognitive processes before writing begins. If a student automates all research, analysis and critique – but then writes a paper by “electronic” hand – they may only have “learned” how to write, which is one academic skill that vanishingly few people will need to personally master in the future.

The “meritocracy of difficulty” describes a system where academic value is tied to how hard a course is to survive – with dense content, heavy workloads, and high-stakes assessment used to filter and sort rather than support students. Moving away from this model doesn’t mean making things easier, but making success more achievable and meaningful.

That includes reducing reliance on final exams, allowing more than one attempt at summative assessments, and expanding the use of pass/fail credit to encourage risk-taking and focus on learning rather than gaming grades. The aim should be to support deeper engagement, not lower expectations – and to shift from a system that rewards endurance to one that enables progress, with release valves for the build-up of academic pressure.

There is a clear and urgent need for all higher education providers to be mandated to systematically assess the actual workload of modules and programmes against the credit system’s expectations. The current system assumes 20 hours of study per ECTS credit (200 hours per 10-credit module), yet students report studying for only 24.2 hours per week total – a dramatic shortfall from the expected 35-40 hours.

The disconnect between theoretical credit allocations and lived reality is contributing to academic pressure, mental health crises, and potentially fraudulent credentialing. Providers should be required to conduct regular workload audits that capture not just contact hours and assignments, but the actual time students spend on all academic activities including commuting, assessment preparation, and independent study – and should particularly examine assessment clustering, the cumulative impact of “continuous assessment,” and how workload varies by student characteristics and circumstances.

The UK’s narrow specialisation model contrasts sharply with European approaches that balance disciplinary foundations with significant credit for interdisciplinary exploration and transferable skills. These systems explicitly recognise that becoming a student itself requires dedicated learning time, allocating credit for study planning, digital capabilities, and communication development.

The current degree classification system was designed for an elite era where classification signalled that the graduate was better than other people. In a mass system, we should clearly describe the contribution graduates can make to the world rather than signalling how they’re “better”. This shift would also reduce the mental health impacts of students’ panic about “standing out”.

Rather than hundreds of marketed programmes with shrinking actual choice, a system with fewer degree titles but greater internal flexibility would produce graduates with both depth and breadth. Students deserve credit-bearing interdisciplinary learning that creates truly rounded graduates, better preparing them for complex careers while reducing educational regret.

For this entitlement to become reality, students need:

  • Future-facing curricula and assessment, with inquiry-driven learning, pass/fail options to support risk-taking, multiple assessment attempts, and time-efficient methods that reflect real-world skills, support working students, and reduce compliance-led approaches.
  • Better policies on academic integrity and AI use, with institution-wide policies co-created with students, ethical AI literacy embedded in teaching, clear guidance on acceptable AI use, and the rejection of flawed AI detection tools.
  • Flexible, interdisciplinary degree structures, enabling students to explore across disciplines, shift specialisations later, and earn credit for project-based, cross-cutting learning that builds truly rounded graduates.
  • Modernised recognition of achievement, moving beyond outdated grading systems towards competency-based transcripts that better reflect diverse strengths and deeper learning.
  • Student-centred programme design, with formal student roles in shaping education, programmes that account for time pressures, and continuous curriculum updates that respond to developments in AI and pedagogy.

Additionally, students must be guaranteed participation in curriculum design and review bodies. They should have the right to flexible and interdisciplinary study, as well as the ability to switch supervisors and specialise later in their degree. Universities should be required to implement compulsory student module evaluations with visible actions based on feedback. Flexibility in assessment methods and rights to multiple attempts should be standard.

Governments should approve a shorter (and within those subjects, broader) list of degree subjects that students can study for access to student loans, with providers mandated to offer flexibility in credit acquisition within those areas, across subject areas and between providers. National subject benchmark bodies should bring together academics, student representatives and relevant PSRBs. It should mandate graduate attributes-based systems, with enhanced transcripts that reflect students’ skills and competencies rather than traditional classifications, and set a target date for the abolition of the UK degree classification system.

05

The right to a liveable minimum income

Full-time students should have the right to financial support that enables full participation in higher education without excessive debt or in-study poverty.

The current student finance system fails to reflect contemporary realities. Its complexity hinders opportunity, its inadequacy is choking human capital development, and its immediate impacts have normalised food banks on campus – real poverty that universities neither can nor should alleviate with other students’ fees and debt.

In early 2025 on Wonkhe.com, our contributors highlighted an obvious injustice. Universal Credit (UC) reduces by 55p for every £1 earned as income – unless you’re one of the few students entitled to UC, where instead it is reduced by £1 for every £1 you are loaned for maintenance. When UC was introduced, income disregards for books, equipment and travel were rolled into a single figure of £110 a month. Taper rates were introduced to prevent “benefit traps” – and have gone from 65p initially to 55p now. But for students, there’s never been a taper rate – and that £110 for the costs of books, equipment and travel hasn’t been uprated in over 13 years.

And when, in July 2025, the Westminster government debated changes to the Welfare system, neither the Department for Work and Pensions (DWP) nor the Department for Education (DfE) could identify how many students would be affected by the proposals to tighten access to Personal Independence Payments (PIP).

The student finance system in England is full of these problems – probably the most vexing being the parental earnings threshold over which the system expects parents to top up to the maximum. It’s been set at £25,000 since 2008 – despite significant growth in nominal earnings across the economy. The Institute for Fiscal Studies says that if the threshold had been uprated since 2008, it would now be around £36,500 (46 per cent higher) in 2023–24.

In 2007, it was estimated that a third of English students would get the maximum maintenance package. We’re now down to about one in five. The maximums available have failed to increase by inflation – especially during the post-pandemic cost of living spikes. It’s a particular issue for the “squeezed middle” – families earning £25,000 in 2007 now have £4,000 more a year to find in today’s money.

The means test on maintenance doesn’t actually work. The system assumes all 18-24-year-olds are dependent unless they meet rigid criteria – like proving total estrangement for a year. It ignores complex family dynamics, counting absent parents’ income while factoring in step-parents regardless of actual support. The result is students trapped between unaffordable loans and unwilling parents.

How much should students get? Over twenty years ago, Charles Clarke established two policy principles on maintenance. The first was aspiring to make maintenance loans no longer means tested, available in full to all full-time undergraduates – treating students as financially independent from 18. That was never achieved – unless you count its implementation in the Diamond review in Wales twelve years later.

Having received results from the Student Income and Expenditure Survey (SIES), Clarke’s second big announcement was that from September 2006, maintenance loans would be raised to the median level of students’ basic living costs:

“The principle of the decision will ensure that students have enough money to meet their basic living costs while studying.

If we look at the last DfE-commissioned SIES – run in 2021 for the first time in eight years – median living and participation costs for full-time students were £15,561, so would be £18,888 today if we used the Consumer Prices Index (CPI). The maximum maintenance loan today is £10,227.

The third policy principle that tends to emerge from student finance reviews – in Scotland, Wales and Phillip Augar’s Post-18 review of education and funding in England – is that the value of student financial support should be linked to the minimum wage. Augar argued that students ought to expect to combine earning with learning – suggesting full-time students would be unable to work for 37.5 hours a week during term time, and should therefore be loaned the difference (with a parental contribution and assuming PT work is possible for all students, which it plainly isn’t).

As of September 2025, the National Living Wage at 37.5 hours a week x 30 weeks will be £13,376 – some £2,832 more than most students will be able to borrow, and more even than students in London will be able to borrow.

Augar thought someone ought to look at London weighting – calling it a “subject worthy of further enquiry” – and properly examine the costs faced by commuters. Given that the last government failed to even respond to his chapter on maintenance, no such work has been carried out – leaving the uprating of the basic for London (+25 per cent) and the downrating for those living at home (-20 per cent) at the same level as in the 1997 regulations.

Things are worse for postgraduates. Not only does a loan originally designed to cover both now go nowhere near the cost of tuition and maintenance, the DWP still pretends that thirty per cent of the loan should be treated as maintenance “income” for benefits calculations. To put that into context – thirty per cent of the current master’s loan of £12,471 is £3,741. 90 credits represents 1800 notional hours spent studying rather than participating in the labour market. The maintenance component is worth £2.08 an hour – the loan is £16,851 short on maintenance alone for a year with less vacation time.

Carer’s Allowance is available if you provide at least 35 hours of care a week – as long as you’re not a full-time student. Free childcare for children under fives? Only if you’re not a full-time student. Most Covid support? Full-time students excluded.

When ministers outside of DfE give answers on this, they tell MPs that “the principle” is that the benefits system does not normally support full-time students, and that instead, “they are supported by the educational maintenance system.” What DWP ministers really mean is thank God our department doesn’t have to find money for them too. Even our understanding of student poverty is patchy – official government figures count tuition fee loans as income, distorting our understanding of their position at every fiscal event.

Back in 2004, as part of concessions to get top-up fees through, Clarke announced fee remission at around £1,200, a “Higher Education grant” of £1,500 for those from poorer backgrounds, and required universities to offer bursaries to students from the poorest backgrounds. By the end of the decade, universities were spending almost £200 million on financial support for students from lower income backgrounds – with more than 70 per cent for those with a household income below £17,910. By 2020–21, that had doubled to £406m.

Change is needed. HEPI’s Minimum Income Standard for Students work (developed by the Centre for Research in Social Policy at Loughborough) moved the debate from calling for an increase to maintenance to establishing what students actually need to have their basic needs met. The methodology is similar to that used for the Living Wage – which Labour has committed to shifting the statutory minimum wage toward. It’s no good calling for an inflationary increase to maintenance loans if we’re not sure whether the amount we’re increasing from is enough. And the hauntingly modest basket of goods, services and costs that students call for in HEPI’s report shows it manifestly isn’t.

Part of the answer lies in a reimagining of the purpose of the Lifelong Learning Entitlement (LLE) to serve existing full-time students rather than focusing solely on adult learners seeking additional skills through “single module” provision. The current system rigidly defines “full-time” study as 120 credits per year, creating unnecessary barriers for students facing real-life challenges – whether caring responsibilities, financial pressures, disability accommodations, or mental health support needs. A shift is crucial because the current inflexibility forces students to either “drop out” or “struggle on” when life circumstances change, whereas a more flexible system would allow students to reduce their study intensity and better support student success and potentially improve labour market outcomes.

Affordability requires a whole-government approach beyond education alone. The government must establish formal cross-departmental duties to reduce essential costs for students – including subsidised public transport, reduced utilities, healthcare access, and digital connectivity. European models demonstrate this through comprehensive national student discount systems that recognise both economic vulnerability and societal contribution. Each department must incorporate student affordability metrics into its planning with clear accountability measures, acknowledging that student poverty cannot be solved through loans alone but requires coordinated intervention across all public services.

For this entitlement to become reality, students need:

  • Maintenance support that meets real needs, including an entitlement to “full time” student maintenance support at 30 credits or more per year, aligning loans with actual living costs via the minimum wage, raising the parental income threshold to at least £36,500, and reforming means-testing to reflect real family circumstances.
  • A detailed review of the relationship between devolved education funding systems, the reserved Welfare system and institutional support, such as applying the Universal Credit 55p taper rate to maintenance loans, supporting student parents and carers, accounting for London and commuter costs, and extending crisis and hardship funding to international students.
  • Improved and protected funding, with increased postgraduate maintenance support, reform of PG loan treatment in the benefits system, and ringfenced hardship funds, bursaries, and emergency grants as core widening participation tools.
  • Better data and joined-up policy, through annual Student Income and Expenditure Surveys (SIES), cross-departmental coordination, and strong protections for students during cost-of-living crises.
  • Transparent and empowering approaches, including mandatory programme-level disclosure of participation costs, universal access to financial literacy and debt advice, and a duty on all providers and government departments to demonstrate the steps they are taking to reduce the costs of participation in study.

Governments should pass legislation establishing a Minimum Income Standard for Students, based on methodologies similar to those used for the Living Wage. This should include legal requirements for universities to publish all study costs transparently and emergency hardship funding based on demonstrated need. Additionally, all students deserve legal protections against financial vulnerability, particularly during times of institutional change or restructuring.

06

The right to earn while you learn (and learn while you earn)

Full-time students should have the right to educational structures that acknowledge and accommodate the reality of part-time work alongside full-time study.

Right across Europe, economic growth has been slowing – down to zero in real terms. And that means that just as in the UK, massified higher education systems have been enjoying strong demand for participation, but little support from taxpayers to pay for that participation. As birth rates decline, and populations age, the need to increase spending on health and the need to generate economic output from the young is increasing.

Controversies over significant cuts to higher education in France and the Netherlands are the latest in a line of countries tightening their spend on tertiary education, as governments demand more efficiency from the systems they have. But those efficiency demands are not restricted to universities. Increasingly, efficiency is being demanded of students themselves. Eurostudent shows the volume of “full-time” students working during term-time is on the increase almost everywhere.

This year’s HEPI/Advance HE Student Academic Experience Survey (SAES) told us that two thirds of full-time (undergraduate) students are now working, spending on average nearly two days a week doing so, and when combined with time spent on study, students with jobs are averaging 50 hours working and studying – far more than the 36.6 hours that the ONS says adults are working for in the population in general.

That two thirds of students report they work to pay for essential bills reminds us that we are some distance from the cliche of students working to earn extra for leisure – the vast majority are working to live.

The widely recommended volume of hours over which every major study suggests that health and outcomes suffer is 15 hours – in previous waves of survey work we have found that for home domiciled students, 27 per cent of those from the more advantaged social class groups ABC1 with a job were working over that limit, while 71 per cent of those from less advantaged/working class C2DE backgrounds were doing so.

But hours spent at work and on independent study don’t account for the time spent travelling to work. In our sample, almost one in five home students have a 60+ minutes travel to work time from campus, rising to 27 per cent of international students. Home to work travel time is shorter – but it is no wonder universities and SUs are reporting that they are struggling to get students to come to campus. Their homes and their workplaces are increasingly distant.

Increasingly, it is clear that students – both home and international – are supplying large volumes of labour in industries which do not only serve other students, but rather care for and feed the population as a whole. And more broadly, while we used to think of full-time students joining the labour market upon graduation, it is increasingly clear that students are already in it, and make up a significant proportion of it in some industries.

A minority of students have found the job they are doing via a university or SU service, with the majority relying on web searches or friends and family, a resource which is not evenly distributed between the diversity of students on campus. In our sample, almost half of students are on a zero-hours contract, a figure which should worry both universities and ministers, given the centrality of the role that student work plays in helping to fund students’ participation.

Perhaps unsurprisingly, while some students do seek to reduce their expenditure when they hit a financial problem, the most popular response on the income side was to seek to work longer hours, with a large proportion of students seeking to find a second job. Both will have impacts on health and study.

As well as the established impacts on outcomes, this volume of work takes its toll on students personally. In our sample three in ten students said their work was “very” physically tiring, while more than three in ten say the same in terms of emotional/mental impact. Those impacts differ by industry. Across health and social care, retail, hospitality, manufacturing and food processing, work is “very” physically tiring for over a third of students – falling to below 10 per cent for other roles. And the more mentally tiring students said their work was, the worse their mental health scores.

In health provision, the principle of “supernumerary status” is pretty clear – the student should not be counted as part of the workforce when they are on a learning placement in a clinical setting. But every review finds students not being treated as supernumerary and being viewed as shifts workers instead. Reports find that supernumerary status is “commonly not upheld” partly because of an inability to accommodate rising numbers of students and offer sufficient high-quality placements for practice learning.

Drawing the line between actual work that an employer benefits from, and carrying out supervised work “on the job” as part of a learning experience is fiendishly difficult. It’s one thing to not pay people properly for their labour. It’s another thing for some professions to require students to undertake placements to learn the job while DfE maintains student finance arrangements that increasingly require students to be in part-time work.

But it’s a whole other thing for students to pay fees to undertake free labour – especially if it amounts to labour an organisation requires to function rather than something that represents well-mentored learning. If the government’s tightening of unpaid internships rules is designed to halt exploitation is going to work, it would do well to remember that that sort of exploitation is happening in the public services too. If the work a student does on placement is valuable to an employer, they should be paid for it. Whatever the qualification

More broadly, it is the interrelationship between work and studies that is most stark. We asked students about the extent to which it all “hangs together” by asking them to reflect on the extent to which their timetable, the academic demands of the course and their wider expectations with student life are compatible with being at work. The levels of disagreement should worry policymakers at all levels.

Universities should acknowledge what the evidence clearly shows – the full-time student model is collapsing as financial necessity forces students to work substantial hours alongside study. Rather than clinging to outdated assumptions about unlimited student availability, higher education must adapt to this reality through better timetabling, more flexible assessment, and integration of paid work into the credit system.

Then when looking for graduate work, plenty of universities have attempted to “embed” employability, attributes and skills into the curriculum – with varied results and enthusiasm from students and staff. The mistake is to assume that a student will be able to demonstrate the full range of skills and competencies via the academic curriculum – few employers are impressed by a student who has “led a team” when writing a project report, or by undertaking an employability module. It is making space in the credit system to recognise what we used to think of as “extra curricular” that allows students to shine.

For this entitlement to become reality, students need:

  • Work integrated into education, with credit for work-based learning, volunteering, and internships; every undergraduate and postgraduate taught programme required to offer a guaranteed, credit-bearing placement within the ECTS framework.
  • Fair, meaningful, and student-centred jobs, with all universities required to offer substantial structured, on-campus employment that includes proper induction, career progression, guaranteed hours, and prioritises student wellbeing – reducing reliance on exploitative external agencies.
  • Statutory frameworks and protections, including legal rights tailored for student workers, fair tax treatment, flexible attendance and assessment adjustments, and required institutional strategies co-developed with SUs to expand access to fair, affordable work.
  • Supportive conditions for working students, through transport subsidies, extended study space hours, digital access to course content, and course timetabling that recognises the reality of students’ work patterns.
  • Accessible career development, including a shift away from employability in the curriculum towards employability in the credit system, paid, non-exploitative placements (especially in public services), guaranteed access to job fairs, employer networks, and career-focused workshops that build skills and open doors.

Governments should legislate for a student employment framework that protects, promotes, and properly values student work – mandating fair hours, guaranteed shift notice, and equal access to employment rights for those on zero-hours and flexible contracts. It should require all universities to deliver student employment strategies, co-designed with SUs, that include access to credit-bearing work-based learning, paid placements, and on-campus jobs that support wellbeing.

Governments should also introduce a UK-wide Student Worker Status with accompanying rights to modified assessments, flexible attendance, and fair tax treatment. It should fund universities to embed employment into curricula, and mandate that all undergraduate and postgraduate taught programmes offer structured, credit-bearing internships. And it should establish a statutory duty on universities and SUs to ensure every student can access safe, meaningful, and fairly paid work while they study – recognising work not as a distraction from learning, but as a crucial complement to it.

07

The right to safety – not to shrink, but to stretch

Full-time students should have the right to comprehensive safeguarding that protects their physical, mental, financial, and academic wellbeing throughout their university experience. The current approach to student safeguarding lacks integration, coordination, and clear accountabilities.

Generation Z sees no contradiction in expecting structures of support without infantilisation. Universities’ failure to define their safeguarding role leads to unmet expectations and erodes trust.

We have seen a pattern emerged around safeguarding, from academics working with schoolchildren, to students reporting campus safety concerns (spiking, racism, poor accommodation), to pedagogical responses affecting student anxiety, to sexual harassment and exploitative relationships.

All these diverse issues represent facets of student safeguarding, raising fundamental questions about universities’ roles, duties and powers. The pattern reveals how these seemingly separate concerns actually form part of an interconnected web of responsibilities that requires systematic, rather than piecemeal, approaches to prioritising, preventing, managing and mitigating risks to student wellbeing across university life.

There is an unhelpful narrative surrounding “safety” on campus. Generational differences around “emotional safety” create conflict. Too often, university is characterised as an “adult” environment that should somehow be dangerous, while students clamour for safety – as if it’s that simple. Until something bad happens, when those calling for university to be “dangerous” suddenly revert to panicked parent mode and demand infantilisation of students.

Beyond these characterisations, we need to evolve a more sophisticated understanding of “safety” as a reasonable expectation of an environment, based on proper risk assessment, that’s probably a precursor for learning.

In 2023, the Charity Commission updated its guidance on safeguarding people who come into contact with charities. It requires charities to take reasonable steps to protect from harm people who come into contact with them, holds trustees accountable when things go wrong, and expects them to assess and manage risks to people – not just to buildings, finances, reputation or recruitment.

At least in England, the Office for Students acts as the “principal regulator” of universities as charities – the assumption in England being that OfS’ powers overlap sufficiently to safely downgrade the Charity Commission’s direct role. But that assumption is problematic. OfS rarely talks about safety or safeguarding in this strategic way, and within universities there’s nothing like the level of coordination and sophistication seen in big national charities.

Put simply, students don’t know what they can expect their university to do to keep them safe. And not only does that mean they can’t hold them accountable if they don’t, remember – the enemy of satisfaction is unmet expectations.

Universities should be required to demonstrate that in developing and implementing policies, procedures and practice, they have given due regard to relevant guidance about protecting people from harm. It would involve developing a strategic assessment based on the students and staff at that provider, gathering feedback and statistics, making the issue everyone’s problem, focusing on those most vulnerable, and debating carefully where safety stops and reasonable risk starts.

In Universities UK’s guidance on information sharing when there are serious concerns about student safety or mental health, the sector has finally cracked an appropriate approach to deciding whether to contact families or trusted contacts. If anything, the gap in the guidance is defining what constitutes a “serious concern” or how to notice one.

While a university might engage in policy definitions and training, a department with a 1:35 student staff ratio (SSR) needs more focus on this than one with 1:5. There will be different levels of competence and willingness to engage, and different student characteristics on different programmes to consider. Certain settings or activities will need more effort to notice and respond appropriately. We should think about risk.

Similarly with harassment or sexual misconduct, cases like that of the UCL Bartlett School of Architecture case show that not all parts of a student body will feel equally able to raise concerns. Where abuse is harder to challenge and easier to cover up, there should be more focus on building victims’ confidence to take action than in areas where a simple poster campaign might suffice. And if research shows particular communities are less likely to report, there should be bespoke approaches with specific theories of change.

For many, a “duty of care” conjures up a problematic image of a university “looking after” adults. There are often cries from the sector that in complex cases in which a student comes to harm there is insufficient focus on NHS failings. But blame and accountability aren’t a simple binary.

Under common law, employers’ duty of care means they must take all reasonably practical steps to ensure the health, safety, and wellbeing of employees so as not to expose them to unnecessary risk. This duty extends to physical and mental health. The law isn’t prescriptive – the specific steps required will be defined by what is reasonable in those circumstances.

While we regulate the corporate conduct of providers of teaching and student support, and have various mechanisms that regulate what they provide, we don’t actually regulate teachers from a professional standards perspective. Increasingly, that represents a major problem.

The debates on regulation of the university teaching profession have naturally tended towards the teaching itself rather than the relationship between teachers (and other student support professionals) and students. The 2001 “Students at the Heart of the System” White Paper called for national professional standards through what became Advance HE and for those standards to describe competences required for all teaching staff.

One critique is that while Advance HE hosts the UK Professional Standards Framework (PSF) and Fellowship scheme, its update in 2023 fails to even mention mental health or disability, let alone the importance of deepening an understanding of who is being taught in a particular cohort. Teaching is a partnership – and it takes two to tango.

We’ve reached a stage where OfS’ condition of registration E6 on harassment and sexual misconduct exists, but where we are not sure it would make much difference because the regulatory focus remains on the provider rather than the profession(al). The good news is that a move in this direction can improve the professional standing of university teaching, prevent perpetrators from moving around the sector with impunity, save universities time and money, and build trust in victims of harassment and abuse to raise issues.

Finally, the UK should consolidate oversight of the student learning environment. While Australia’s TEQSA comprehensively regulates “the nature, access to and fitness for purpose of the learning environment” without prescribing delivery models, the UK fragments these responsibilities across multiple agencies.

Our current approach scatters environmental standards across different bodies – physical spaces (estates), digital platforms (IT), academic resources (libraries), and wellbeing provisions (student services) – with no coherent framework for how these elements should integrate to support learning. This fragmentation means excellent guidance rarely reaches implementation. A single regulatory framework should establish clear standards for integrated learning environments that combine physical, digital, and support elements, while creating straightforward accountability for ensuring these standards translate into practice across all institutions.

For this entitlement to become reality, students need:

  • A statutory duty of care and safeguarding framework, requiring universities to take reasonable steps to support student wellbeing, follow sector-wide safeguarding standards with clear responsibilities, and demonstrate “due regard” to protection guidance for all students.
  • Robust, transparent handling of misconduct and harm, including a professional standards body to stop perpetrators moving between institutions, independent reviews of safeguarding failures, and guaranteed rights to anonymous reporting and transparent complaint resolution data.
  • Legal duties that strengthen institutional accountability, with a duty of candour in internal and external processes, regular publication of prevalence and misconduct reports, and mandatory safeguarding training for all student-facing staff.
  • Risk-based protections for vulnerable groups, underpinned by statutory risk assessments, clear information-sharing policies with trusted contacts, and targeted measures for students at increased risk of harm, exploitation, or abuse.
  • Guaranteed access to essential services and safety partnerships, including mental health support, subsidised prescriptions, basic needs centres, and collaboration with police and local authorities through community safety partnerships.

Government must establish a national framework for student safeguarding, including independent oversight of university teaching, risk assessments in high-risk academic contexts, and legal protection for vulnerable students. All students should have the right to be taught by staff qualified to teach and with a basic understanding of mental health issues.

08

The right to connect – and to contribute

Full-time students should have the right to secure, affordable accommodation that is near to their campus of study and meets consistent quality standards and contributes positively to their educational experience.

What is striking in many student accommodations is the absence of spaces for students to meet, socialise, or study together. Unless you’re near campus – which itself may lack social learning spaces – the surrounding city centers offer few alternatives beyond chain coffee shops. A glance at the Plymouth Plan underlines this problem. The city’s universities are mentioned in economic contexts, but there’s virtually nothing about supporting the student community. This pattern repeats across numerous university towns and cities, where acres of empty retail space lie unused while student facilities remain inadequate.

This shouldn’t surprise us – students are often “othered” by local authorities. The explosion of student city-center living pre-dates many urban development schemes, with little evidence that even the International Education Strategy considered where students would live, socialise, or study.

In 2019, the Towns Fund for England provided £3.6 billion for struggling towns to support local economic growth and reimagine community centres and social infrastructure. Yet across towns with university campuses, students are typically mentioned as economic assets rather than citizens with spatial needs for third spaces.

For students living away from home, the situation is increasingly dire. Unipol/HEPI’s student accommodation costs report reveals that in ten key markets, student rents have increased by an average of 14.6 percent over two academic years, now consuming almost the entire average maintenance loan available to English students.

When universities recruit students who’ll live away from home, they should consider where these students will live. If we deem it essential that students can rent affordable, reasonably located, quality accommodation, then overall housing supply analysis matters critically. Looking at just international postgraduates in the two largest providers across eight cities, numbers doubled from 21,035 to 42,215 between 2020 and 2022. Either there were 20,000 spare beds in those cities 2019, or universities recruited more students than local housing markets could accommodate. Since every student needs somewhere to live, more modest increases in international recruitment would almost certainly have resulted in more modest rent increases.

Universities UK suggests institutions conduct such analysis, yet we rarely see this happening systematically across the UK. Universities previously didn’t need to consider housing beyond first-year guarantees, but it’s increasingly important given higher education’s scale and the wider housing crisis.

Universities don’t control local housing markets, but for any market to function properly, moderate oversupply is necessary. This creates downward pressure on prices and enables choice. The tighter the market, the more morally dubious it becomes to recruit “away from home” students, given the impact on their experience and outcomes.

All this requires urgent attention. Universities and students’ unions should collaborate on city-wide initiatives to create student-friendly urban environments. When political figures campaign in university cities, they should address the needs of students living in inadequate, overpriced accommodation. The census might not show it, and nor will council tax receipts – but there are plenty of them.

For this entitlement to become reality, students need:

  • A national housing strategy centred on student need, requiring universities to conduct recruitment impact assessments, mandating inter-institutional collaboration in shared cities, and obliging local authorities to include student housing in planning frameworks.
  • Affordable, transparent, and high-quality accommodation, with rent controls linked to maintenance support, mandatory quality standards under a single code, regular inspections, and full transparency on costs, profits, and ownership structures. And a duty on universities to hold a reasonable assumption that students they recruit living away from home will have somewhere to live that is reasonably priced, safe and of a reasonable distance from campus.
  • Rights-based tenancy models, including flexible tenancy agreements tailored to students, protected rights to organise tenants’ unions, and emergency housing funds to prevent homelessness.
  • Student voice in local decision-making, with guaranteed student representation on planning committees and PBSA provider boards, recognition of students as stakeholders in town regeneration efforts, and legal protections ensuring access to local services and anti-discrimination for international students.
  • Community connection and civic inclusion, supported through integration programmes with permanent residents, funding for student-led community initiatives, and protected rights to access local amenities, participate in community life, and travel affordably to and from campus.

Government must establish legal protections specific to student housing, including rent controls linked to maintenance loans, flexible contract terms, and mandatory quality standards. Local authorities should be required to include student housing needs in planning strategies, while universities must conduct housing impact assessments before increasing recruitment. Student representation should be mandatory in housing governance, with guaranteed rights for students in purpose-built accommodation.

09

The right to community – not just curriculum

Students should have the right to structured opportunities for building meaningful social connections, developing networks, and engaging with wider communities beyond their academic programmes.

Remember the RAG parade? The idea that students should make a contribution to the place where their university is located predates students’ unions and civic university agreements. But the contemporary framing of students’ contribution to their community tends to be more negative – noise and litter complaints morphing in 2020 into an unfounded assumption that they “caused” the winter Covid-19 lockdown, when data showed their real civic contribution was sticking to rules to protect the vulnerable at the expense of their own education, experience and mental health.

The relationship between students and places has changed, with major impacts on housing and local economies. Far more students are “of” the local community to begin with. Campuses and student bodies are less homogeneous. And participation in traditional activities is in freefall, as the student time crisis in a mass system bites.

Throughout the waves of higher education expansion, we’ve paid little attention to the student community, students’ communities and their relationship to the wider community. A model focused on a professional elite of undergraduates has been complemented or supplanted by one of individual skills acquisition – positioning students and their activities outside the curriculum as agents for wealth creation.

Despite political narratives, students’ unions weren’t originally about politics and campaigning. They emerged, particularly in England, as ways to bring together student clubs and societies to share administration and organisation costs. Involvement in SUs always had educational and social capital benefits. But as the Conservative government developed its vision for an expanded higher education system in the late eighties, university involvement began to take on a new purpose, with initiatives like Enterprise in Higher Education stressing the need for the university experience to generate skills useful to employers.

Today, graduates routinely highlight skills learned through such activities on CVs and in job applications. Graduate attribute frameworks stress the acquisition of skills through leading a team or organising an event. The Sutton Trust has researched the impact on social mobility as students missed these activities during the pandemic.

But perhaps there’s more to all of this than a choice between creating an exclusive “professional elite” with some benevolent community work, and producing atomised individualists with CVs full of skills to sell in a mass system.

In October 2007, then shadow minister for higher education David Willetts delivered a lecture with a different view of students and their unions focused on community:

The student is not just a free-floating consumer. He is a member of a community. To this end, we should strive to foster the idea of the university community. Each and every university is its own community – its own society… But the hub of these university communities is not the university itself. It is not the Vice Chancellor, the central administration or the quadrangle. It is the students’ union.

Social capital and social division should matter for policy reasons too. In Fractured, Jon Yates notes that half of us think the country has never been more divided, with friendship circles segregated by age, class, politics, and race – half of degree-holders have no friends without degrees. Connecting with people outside our bubbles through rituals, clubs, and shared experiences has historically bridged these divides.

When we speak with student representatives and volunteers, the most common motivations are service and connection. They talk about helping, giving, wanting to get to know others, and helping others connect. They express a desire to foster community, make others feel welcome, and improve experiences through others. With strikingly few exceptions, their motivation is to serve and connect.

In recent years, universities and SUs have tended toward giving up on diversity in roles requiring time or responsibility – assuming busy commuters or student parents won’t have time for roles with badges, events to organise, and reports to write.

One concerning trend involves abolishing positions of responsibility altogether. Because these roles might only be filled by “usual suspects”, there’s a tendency toward alternatives like student engagement posts, residential life teams, focus groups, and surveys – all keeping power with convenors while robbing the student body of agency.

Another problematic approach is paying students to do what they used to do for each other voluntarily. Yet beneath the surface, there’s a whole army of students eager to serve others – running coffee mornings, facilitating project groups, gathering feedback, or giving campus tours, if only they had the time. What if, instead of asking “who wants to be the rep?” we asked who would like to get involved in running the course – and said yes to everyone, structuring timetables and credit acquisition to facilitate it?

With time pressures on students in a mass system, the traditional approach has been adding “…in the curriculum” to keywords. But what is a stressed module leader supposed to do when asked to incorporate multiple agendas into a ten-credit module? And will employers be impressed when a student’s only example of leading a team comes from an academic course?

Student association leaders deserve statutory protections recognising their essential democratic contribution. Following European models, these should include legal rights to justified academic absences for official activities, rescheduled assessments when duties conflict, flexibility in deadlines, exemptions from strict attendance requirements, and explicit protection against academic discrimination.

These rights should be formally recognised in university regulations with clear appeals processes, ensuring students aren’t penalised for civic engagement. This statutory framework should extend beyond association leadership to recognise other legitimate statuses – including student-workers, student-parents, and student-athletes – each with tailored protections that acknowledge their specific circumstances while enabling full educational participation.

At an aggregate level, an entitlement to community participation as part of a degree represents a compelling offer not just for students but for communities too. Two million students at 5 credits a year is 200m hours a year that a reformed student experience can offer its communities  – both internally and externally.

The available evidence ought to bury the cliches of lazy students sponging from the state. When a realisation dawns that maybe it’s the norms of higher education that need to change rather than wishing that students were as carefree, and frankly rich (both in money and time) as they were in a forgotten past, we can reimagine how social capital development becomes central to the student experience rather than peripheral to it.

For this entitlement to become reality, students need:

  • A universal entitlement to credit-bearing, community-rooted participation, where students earn academic credit for civic service, peer leadership, and roles that serve other students, communities, or employers – enabled through inter-institution collaboration and protected by academic flexibility policies.
  • Social capital and integration as intentional outcomes, with institutions actively measuring and building bonding, bridging, and linking ties – supported by commuter inclusion initiatives, digital platforms for hybrid and on-campus connection, and strategic goals for peer connection backed by evidence-based interventions.
  • Institutional investment in student-led activity, including guaranteed funding for cultural, artistic, and recreational initiatives, support for underrepresented societies and student groups, and a minimum of £150 of the fees paid by students allocated to SUs from institutional budgets to support it.
  • Sustained community engagement infrastructure, delivered through professional community organisers (not just admin staff), dedicated collaboration spaces, and reinvestment of AI-driven efficiencies into more meaningful student involvement.
  • Civic belonging embedded in planning and narrative, through structured community partnerships, student roles in local development, public storytelling that challenges negative student stereotypes, and collaboration frameworks connecting student communities across neighbouring universities.

Government should require universities to develop social capital strategies that establish clear expectations for community-building and measure outcomes. This includes mandated funding for students’ unions to support cultural, artistic, and recreational activities, alongside requirements that universities create dedicated spaces and resources for community development. Service learning and community engagement should be recognised through elective credit-bearing opportunities within degree programmes.

10

The right to be well – health makes learning possible

Students should have the right to accessible, integrated healthcare that addresses their physical, mental, and social wellbeing needs throughout their educational journey.

The debate about student health across the UK is stuck in an accountability void. Poor access to preventative healthcare and health services is justified either by NHS pressure from an aging population or by expectations that universities should do more with less. Both arguments have merit, but they leave the crucial link between health and academic success unaddressed.

Our polling reveals a stark contrast between student health and the general population. Only 20 per cent of students report “very good” health compared to 48 per cent of the general public. Even more concerning, 32 per cent of students rated their health as merely “fair” – nearly two and a half times the general population rate. And 27 per cent of students report their health has worsened since starting university.

Access to healthcare services remains a significant barrier. While 65 per cent of students are registered with a GP in their university town, dental care is severely lacking with only 17 per cent registered locally. A third of students aren’t registered with a dentist at all. Student dissatisfaction with the NHS is telling – 49 per cent report being “quite” or “very” dissatisfied, compared to just 31 per cent reporting satisfaction.

Mental health, sleep, and nutrition form an interconnected web of challenges. The results reveal troubling sleep patterns – 21 per cent of students getting less than six hours and 24 per cent experiencing poor sleep quality. Meanwhile, 25 per cent demonstrate possible food or body image issues and 24 per cent showed possible eating disorder patterns.

Recent news that many areas of the UK have eight-year backlogs for adult ADHD assessments should give higher education serious pause. This is particularly problematic for universities that require formal, external diagnosis before students can access support or teaching adjustments, despite the Equality and Human Rights Commission noting that universities can be found to have discriminated against students when evidence of disability is apparent from the students themselves.

Despite the Westminster government’s 10-year health plan ignoring students as recipients of healthcare, its three major shifts – moving care from hospitals to communities, better using technology, and focusing on prevention – should place students as part of equation. Any plan for the NHS that involves pushing services from hospitals into communities will fail without proper consideration of students. The time for a dedicated student health strategy is now.

For this entitlement to become reality, students need:

  • Universal, affordable healthcare access, including dual GP registration at home and university, free prescriptions, universal health screening, subsidised medications, and guaranteed access to telehealth and online support services.
  • Proactive and inclusive health support, with faster disability assessment pathways, clear communication that formal diagnosis isn’t required for adjustments, and academic flexibility and timetabling designed to support disabled students.
  • Integrated regional partnerships and basic needs provision, through NHS – university collaboration on mental health, crisis, and preventative care strategies, alongside food security measures such as low-cost meal programmes and hardship funds that cover food insecurity.
  • Health embedded in education and regulation, making wellbeing a core part of educational quality assurance, backed by a national student health and wellbeing survey and strong legal protections for students’ personal health data.
  • Evidence-based, student-focused health policy, supported by dedicated student health funding, digital access to services, and public efforts to challenge misinformation and promote informed, data-driven health interventions.

Government must establish a national student health strategy that includes legal rights to continuous healthcare access, subsidised prescriptions, and mental health support. This should include mandatory requirements for universities to provide credit-bearing health education, adequate sleeping facilities on campus, and financial support for students facing health-related costs. Health outcomes should be integrated into quality assurance frameworks, with universities held accountable for student wellbeing metrics.

11

The right to power, not just provision

Full-time students should have the right to genuine influence in university decision-making, with representation structures that ensure their voices shape both strategic directions and day-to-day operations and a clear understanding of their rights.

In the UK, the core “voice” for students is an unspoken assumption is that there’s one or two course or class reps on every course, for every year group. It’s been this way for decades, once mandated by the Quality Assurance Agency. But in my encounters with these reps, they consistently report that whichever room they’re in, it’s almost never the one where decisions are made.

The rep attending a staff-student liaison committee typically reports things outside the control of those in the room – allowing a temporary wallowing session over timetabling or facilities, where issues are rarely escalated. Those who persevere face a painful paradox – they’re told to gather feedback, but when they present it they’re told it differs from survey data or that they need more responses. Most got involved for community building rather than quality assurance.

Course representation in the UK comes from a different age – when surveys were on paper, data was scarce, programmes were smaller, and more decision-making was devolved. The internet, mass HE efficiencies, and student life realities now mean the scaffolding makes no sense. There are too many course reps but not enough representation where it matters.

Meanwhile, few UK universities have proper boards with student input that oversee counselling, campuses, projects or IT initiatives. Student input is typically forced through quarterly “student experience committees” or occasional focus groups. It’s notable that on the continent, both in democratic and managerialist systems, a broader range of students are recruited to contribute – and their input is more impactful. Given that quality culture now focuses less on auditing systems, and more on targeting interventions based on data, student reps aren’t expected to gather feedback – their role is to spot trends in existing data and feed into interpretation and decision-making.

This matters in relation to OfS’ quality conditions. The B conditions of registration form the basis of OfS’ inspections and investigations. These conditions cover everything from staffing levels to hidden costs and from academic support to adequate study space. Yet many universities act as if these conditions don’t exist. Few SUs have been alerted to them, and student leaders tell us that universities consistently conduct programme reviews without mentioning them.

When it comes to student complaints, we also have a major problem. The OIA closed 2,654 complaints in 2021 but failed to meet its KPI of closing 75 per cent within six months, managing just 69 per cent. And that’s after students wait for their completion of procedures letter.

Resolution typically applies only to those brave enough to complete the process – incentivising providers to apply “deal or no deal” strategies plus non-disclosure agreement principles rather than admitting fault and resolving issues collectively. This prevents institutional learning and discriminates against disabled students.

When a student fails or receives a disappointing grade, appeals based on university failings are doomed. “Academic judgment is sacrosanct” is the response, with “you should have made a complaint” the standard advice. But why don’t universities routinely treat failed appeals as complaints? Students often don’t raise issues when they occur because they raised concerns informally without resolution, don’t know complaints processes, or fear retribution. And the barriers are greater for international students.

Research identifies five barriers to complaint-making: opportunity costs, fear of conflict, fear of retribution, lack of confidence, and lack of information about rights. Universities, through their SUs, should be actively required to research and reduce all five of the barriers. And university annual complaints reviews rarely analyse what’s in failed appeals – just categories like “65 per cent failed because they concerned issues a student should have raised as a complaint.”

European higher education models demonstrate the power of ringfenced funding for student services with real student governance. In several systems, a dedicated portion of fees or government funding is allocated specifically for food, housing, healthcare, and activities – with elected student-majority councils controlling these substantial budgets.

This approach recognises that many services are place-based rather than provider-specific, enabling coordination across institutions in the same region. The UK should implement statutory structures guaranteeing a defined percentage of fees is allocated to student services with mandatory student-led governance, ensuring services truly reflect student needs rather than institutional assumptions.

More generally, democracy must be the foundation of this reimagined student experience – not as an abstract concept but as daily practice. When students have real voting power in governance, from curriculum design to resource allocation, they develop as both learners and citizens.

European universities that integrate students into “the power system” demonstrate how democratic participation creates better institutions and graduates. These practices aren’t symbolic concessions but essential educational components that build civic capacity. The erosion of democratic culture in UK universities threatens not just student experience but our broader civic future. Any meaningful framework of entitlements must position democracy as both a right itself and the foundation that makes other rights sustainable.

For this entitlement to become reality, students need:

  • Legally protected student representation at all levels, ensuring students have rights to participate in all decisions that affect them – across senates/academic boards and sub committees, governing bodies, curriculum committees, programme boards, and PBSA housing governance – with mandatory consultation before decisions are made. Nothing about them without them.
  • Democratic, meaningful participation in governance, backed by a legal duty to elect student representatives fairly, ensure involvement in national policymaking, and embed subject-level communities in curriculum design – extending student voice beyond teaching into support services, estates, IT, and campus planning.
  • Recognition and support for representation work, including financial compensation or academic credit for reps, mandatory training in quality standards and data use, and transparent processes with clear accountability when student input is ignored.
  • Fair, independent complaints and appeals systems, with a ban on all non-disclosure agreements, the Office of the Independent Adjudicator’s Good Practice Framework made mandatory, and reforms allowing failed appeals to be converted into complaints – supported by on-campus independent ombuds in all providers with 500 students or more (shared where providers are smaller) instead of adversarial and defensive internal processes.
  • Protections for student activism and decision transparency, including legal safeguards for protest and mediation rights, transparency requirements for institutional decision-making, and robust accountability mechanisms when student feedback isn’t acted upon.

Students’ unions should also have the right to operate within guaranteed campus space, supported by a percentage of institutional budgets (at least £150 per student) for operations and activities. Legal rights should include access to university information and funding for cultural, artistic, and recreational activities.

The idea that students are citizens, the university is a community of communities, and they have responsibilities to each other, is vital educationally and will make resource reductions more bearable.

Governments should establish a statutory framework for student rights and representation that gives student representatives real decision-making authority rather than just consultative roles. Legal rights should include a duty on students’ unions to give information to new students about their rights, access to university information, funding for cultural, artistic, and recreational activities, and protection from academic discrimination for representative activities.

12

The right to shared investment – with shared responsibility

Students should have the right to a well-funded, transparently operated higher education system that balances academic excellence, financial sustainability, and student wellbeing.

Just as unplanned expansion is so dangerous, so is unplanned contraction. And as usual it’s students – paying for 40 years not 30 these days – that will suffer. It is possible to have a less expensive HE system – albeit with difficult choices. But getting there in the way that this government is allowing to happen just means absolute misery. And all because it can’t stand being seen to plan a thing.

Throughout this paper, we have set out a whole range of things that both universities and government should do to help students to help themselves to a better education and a better world. In its totality it almost certainly feels like a lot. So it’s also important to set out how a mass system might be able to afford to deliver change on the scale we are suggesting.

One of the major problems for universities in lobbying for funding is a lack of clarity on where the money goes, and a set of global figures that make the UK system very expensive. The UK’s Transparent Approach to Costing (TRAC) data apparently doesn’t achieve the T in its name for the public funders of higher education – and so the default way to understand it becomes the OECD’s data on expenditure per head on tertiary institutions per student.

And on the face of it you can see why officials might be briefing ministers that universities should be able to take a dose of spending restraint without destroying the UK’s competitiveness in higher education.

If we ask the question “why is UK HE so comparatively expensive?” there are two kneejerk responses – one that retreads the “shiny buildings” trope, and the other positing that we spend more on “administrators” and/or non-academic staff. The panoply of professional services in the UK, especially those that seek to support students, do seem to be more extensive than we’ve seen on our SU study tours across Europe.

But there is one other argument that bears better interrogation – and it’s about choice. Almost without fail across systems we’ve visited, there’s evidence of less rigid subject-specialisation – more manifestations of liberal arts curricula, degrees achieved by diverse module gatherers, and chunks of core credit obtainable via work experience, volunteering, and interdisciplinary project work.

You don’t need many ECTS credits per year to be obtainable via these categories to reduce costs considerably – and the more that a university does this, the more it is able to apply “demand smoothing” techniques to achieve a decent student experience on what look like lower staff-student ratios than the UK seems to achieve.

Back when we all thought Covid was going to cause temporary fee income collapse, DfE rapidly developed a Higher Education Restructuring Regime that was largely rebuffed and never actually deployed because students paid up and enrolled anyway. It had four main policy objectives:

  1. Protect the welfare of current students because of the potential impact on the quality of teaching provision, and the impact on disadvantaged and local students
  2. Support the role HE providers play in regional and local economies through the provision of high-quality courses aligned with economic and societal need
  3. Protect teaching provision because of the risk of the loss of strategically important or unique provision, the loss of provision supporting key workforce pipelines, the loss of teaching capacity in cold spots and potential impact on regional businesses, jobs and local growth
  4. Preserve the sector’s internationally outstanding science base.

All four of these risks are still present, and all four will matter to a Labour government. Hoping that tuition fees will go up to fill in for the lost years of high inflation feels like a big risk – especially now that £9,250 is worth £5,616 in real terms. The sector should instead call for a version of that restructuring regime to be dusted off and relaunched with urgency.

If universities reimagine their role as civic engines – embedding students in local, regional, and national initiatives in exchange for support, funding, and academic credit – there is a clear value proposition for different government departments. A massively expanded pool of student volunteers and civic participants could be leveraged to advance key policy priorities, reduce reliance on stretched public services, and create stronger, more engaged communities.

Different departments could benefit in various ways:

  • Housing, Communities and Local Government: Students could be mobilised into community-led projects, local democracy initiatives, and high-street revitalisation efforts
  • Education: Students could mentor school pupils, support literacy and numeracy in underperforming areas, and work in local FE colleges
  • Culture, Media and Sport: Students could provide digital skills training for older residents, volunteer in creative industries, and work in sports and wellbeing projects
  • Health and Social Care: Students could volunteer in mental health peer support, community health programmes, and local social care initiatives
  • Work and Pensions: Students could take on structured civic apprenticeships, skills-based volunteering, and employment support schemes

Sustainable higher education funding requires a clear 50/50 shared contribution principle between students and state, acknowledging both personal benefits and societal value. This balance must be transparent, ending current opacity and establishing a framework to measure when government support falls below reasonable levels. This model reinforces higher education as both personal advancement and public good, deserving substantial state support for its role in national prosperity.

Certain aspects function as pure public goods requiring complete state funding – widening participation initiatives, disability support, regional provision in educational cold spots, and strategically important subjects. These generate societal benefits that cannot fairly burden individual graduates and require dedicated, ringfenced government investment with transparent accountability.

Reestablishing a dual-sector system – but one that is operated at faculty level – would preserve technical and vocational education’s value while creating clearer pathways. Unlike post-1992 homogenisation, this approach allows targeted funding, better public understanding, and stronger regional development. Modern dual-sector systems should maintain permeable boundaries, allowing students to combine elements from both sectors to create personalised educational journeys better suited for complex careers.

For this entitlement to become reality, students need:

  • A fair and transparent funding model, with a clear separation of funding streams for teaching, research, student support, and capital investment; a reduction in reliance on high-cost private borrowing; and a commitment to 50/50 state/student contribution as an explicit principle.
  • Planned, sustainable higher education infrastructure, delivered through a national planning framework to prevent sudden institutional collapse, protection for strategically vital disciplines regardless of market trends, and a national subject strategy that stops short-term cuts to essential fields.
  • Flexible, inclusive, and applied learning, including modular and extended degree structures that reduce cost pressures and mental health strain, interdisciplinary and project-based learning, and reimagined full-time education adaptable in length and pace.
  • A dual-sector system with strong civic and vocational connections, restoring universities of applied sciences and strengthening pathways between further and higher education, backed by coordinated government funding for student civic participation and a cross-government civic engagement strategy with academic credit for national contributions.
  • Efficient, student-driven support systems, including streamlined and capped costs for branding, estates, and support services; structured student communities embedded in every programme; a shift toward peer mentoring and programme-level networks; and shared welfare responsibilities between universities and government departments.

Government should relaunch the Higher Education Restructuring Regime to fund transformation, not just stave off collapse – linking public investment to transparency, civic value, and sustainability. It should require disaggregated funding streams for teaching, research, support, and estates, ending opaque cross-subsidies and risky borrowing.

It should protect strategically vital subjects through a national subject strategy and a move towards a more dual-system approach. Embed students in public service and civic initiatives for credit, with departments across government benefiting from their skills. Cap spending on marketing, branding and vanity estates, and prioritise student-led, programme-level support over excessive professionalisation. And develop a national HE planning framework to prevent unplanned contraction – ending chaotic drift through coordinated, civic-minded reform.

13

Conclusion: Students can do better and get better

The ten entitlements outlined in this paper represent more than aspirational ideals – they form the foundation of a necessary new settlement between students, universities, and the state. This settlement recognises that higher education’s purpose has fundamentally evolved, reflecting both the extended “middle stage” of modern adulthood and the complex social, economic, and technological challenges facing the UK.

For too long, policy approaches to higher education have oscillated between treating students as passive consumers in a market or dismissing their concerns as evidence of entitlement. Both approaches fail to capture the essential nature of higher education as a transformative period that develops not just knowledge but character, connections, and civic capacity.

The rights proposed here offer a more balanced framework. Students would gain structured support, meaningful representation, financial sustainability, and comprehensive wellbeing provisions. In return, society would benefit from graduates who are not only academically accomplished but socially connected, civically engaged, and practically prepared for an uncertain future.

Government action required

For this settlement to succeed, government must take decisive action through:

  • Legislative framework: The government should introduce a Student Rights Bill that establishes these ten entitlements in law, ensuring they have binding force rather than remaining aspirational.
  • Regulatory reform: The Office for Students must be broken up  – with its corporate governance and funding function folded into DfE, and the OIA reinforced to monitor and enforce these entitlements, moving beyond narrow metrics of academic quality and financial sustainability to encompass the whole student experience.
  • Cross-departmental coordination: A ministerial taskforce should coordinate policies across education, health, housing, work and pensions, and communities departments to ensure coherent approaches to student support.
  • Financial reform: A comprehensive review of student finance must establish a Minimum Income Standard for Students and reform maintenance support to reflect actual living costs.
  • Planning powers: Regional bodies should gain powers to coordinate (and where necessary, cap) student recruitment, housing development, and community integration to prevent market failures in accommodation and public services.
  • Professional standards: A national register of higher education professionals should be established, similar to the General Medical Council, to maintain standards and address misconduct.
  • Data collection: Regular nationwide surveys of student income, expenditure, health, and time use should inform policy development and measure progress.
  • Digital access: Ensuring all students have access to digital tools and resources necessary for modern education, including affordable technology and high-speed internet.
  • Global mobility protection: Guaranteeing students the right to study abroad or transfer credits internationally, ensuring academic continuity and recognition of qualifications.
  • Data protection framework: Providing strong legal protections for students’ personal data and ensuring transparency in how it is used for assessment and analytics.

University accountability mechanisms

These entitlements would be enforced through:

  • Participation plans incorporating specific targets for student wellbeing, financial support, and community integration
  • Conditions of registration that explicitly require evidence of meeting these entitlements
  • Metrics that evaluate university performance across these entitlements rather than narrow measures of “student satisfaction”, including a new National Student Survey covering all of these aspects
  • Annual reporting requirements that track progress on implementing the entitlements
  • Consumer protection enforcement with universities held accountable by the student interests and complaints body under laws like the Digital Markets, Competition and Consumers Act

Expected outcomes

This new settlement would deliver:

  • Improved retention and outcomes: Students with adequate financial support, proper housing, and comprehensive health services are more likely to complete their studies and achieve their potential
  • Enhanced social cohesion: Graduates with experience bridging social divides and engaging with diverse communities will strengthen social fabric
  • Economic growth: Developing students’ full capabilities—not just academic but social, practical, and civic – will increase productivity and innovation
  • International competitiveness: A distinctive approach that develops the whole student will enhance the UK’s global standing in higher education
  • More responsive institutions: Universities better attuned to students’ actual needs and experiences will adapt more effectively to changing circumstances

The cost of implementing these entitlements is not insignificant. But the cost of maintaining the status quo – where thousands of students struggle financially, disengage from learning, and fail to develop their full potential – is far greater. Every year we delay comprehensive reform represents another cohort whose talents are not fully realised and whose contribution to society is diminished.

As other nations develop higher education systems that explicitly nurture social capital alongside academic achievement, the UK faces a choice: continue with a model increasingly misaligned with student needs and societal challenges, or embrace a new settlement that recognises higher education’s true purpose in contemporary society.

These ten entitlements offer a path forward – one that honours higher education’s transformative potential while acknowledging the realities of today’s extended “middle stage” of adulthood. If ministers can get a grip on the student experience and enshrine these rights in law and practice, we can ensure that the UK’s higher education system not only maintains its global reputation but truly serves the students and society it exists to benefit – because students will both do better, and get better.

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About The author

Jim Dickinson
Jim Dickinson is one of the foremost experts in the UK student experience having spent three decades running students’ unions, the National Union of Students and supporting student officers and writing and researching extensively on the topic. He is now an associate editor at Wonkhe where he runs its students’ unions training, briefing and intelligence services and is co-host of The Wonkhe Show. Jim has served as a governor and trustee in both further and higher education and the voluntary sector, and is a regular speaker at sector events and conferences in the UK and around the world. He is the author of The problem with student engagement during COVID-19 (Routledge, 2023), Students’ unions: building confidence and reducing risk in How to Develop Free Speech on Campus: International Controversies and Communities of Inquiry (forthcoming) and a co-author of Hidden Marks: The contribution of student leaders to tackling gender-based violence on campus (Routledge, 2022).

The cashpoint campus comeback franchising, fraud, and the failure to learn from the FE experience

A policy paper on the chronic lack of institutional memory from regulators and government and the urgent need for cross-sector learning

Date:
26 June 2025
Authors:
Mark Leach MBE
Image: Ikon
01

Executive summary

The higher education sector is mired in a franchising crisis that mirrors – almost precisely – scandals that rocked further education a decade ago. Over £1 billion in tuition fee loans has flowed to unregistered providers over the past three years, while fraudulent activity, exploitative recruitment practices, and catastrophic student outcomes proliferate. The National Audit Office has uncovered organised crime, ghost students, and continuation rates as low as 66 per cent at some franchised providers.

This paper argues that the government’s response represents a troubling case of institutional amnesia. In 2020, the Education and Skills Funding Agency (ESFA) implemented comprehensive reforms to FE subcontracting that addressed identical issues – geographical distance, volume controls, whole programme restrictions, and enhanced oversight. These reforms worked. Yet, the Department for Education (DfE) is now proposing to reinvent the wheel for higher education, with implementation not set to begin until 2026 and full effect not until 2028. This is even harder to understand when you consider that ESFA was recently absorbed back in to DfE – it appears that all learning has been lost in the process.

The central challenge is not whether reform is needed – it manifestly is – but why proven solutions from one part of the tertiary sector cannot be immediately adapted for another. This paper demonstrates how reforms made in FE could be translated to HE within months, not years, potentially saving hundreds of millions in misallocated public funds and protecting tens of thousands of vulnerable students from educational malpractice.

02

The franchise explosion: Déjà vu all over again

When, earlier in 2025, Education Secretary Bridget Phillipson declared the current situation “one of the biggest financial scandals in the history of our universities sector,” she was both right and wrong. Right about the scale – wrong about the novelty.

As early as 2014, investigations uncovered Romanian builders trafficking people to the UK to fraudulently claim student loans, and colleges dubbed “the ATM” where students collected their £11,000 and vanished.

The numbers tell the story. Student enrolments at franchised providers more than doubled from 50,440 in 2018–19 to 108,600 in 2021–22, reaching over 138,000 by 2022–23. In 2023–24 alone, nearly £450 million in tuition fee loans went to students at providers not registered with the Office for Students (OfS). Private providers report profit margins exceeding 50 per cent – companies house records show that one turned over £73 million with education costs of just £17 million, pocketing a 53 per cent pre-tax profit.

These are not the specialist providers or innovative upstarts that former universities minister Jo Johnson envisioned when comparing validation requirements to “Byron Burger having to ask permission of McDonald’s to open up a new restaurant.” Instead, we see cookie-cutter business degrees delivered from converted office blocks, sold door-to-door with promises of “£15,000 funding today” and attendance requirements of “just two days a week.”

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The targeting is cynical and precise. In 2022–23 and 2023–24, over 65 per cent of students eligible for student finance on subcontracted courses were from nationalities where English is not the first language – particularly Romanian nationals and those with pre-settled status. The Student Loans Company reports thousands of students who receive maintenance loans but never draw down fee loans – a clear indicator of enrollment purely for cash access. In 2023–24 alone, a Freedom of Information request to the Student Loans Company revealed that 10,582 students in England received first instalments of maintenance loans without any tuition fees being paid.

The human cost is significant. Of nineteen franchise partnerships examined by OfS, only two met the minimum 80 per cent continuation threshold. At one large partnership, just 66.7 per cent of students continued to their second year. These are predominantly students from disadvantaged backgrounds – 62 per cent from high deprivation neighbourhoods, compared with 40 per cent across all providers. Nevertheless, while franchise provision shows high rates of economic disadvantage, the proportion reporting disabilities is suspiciously low – suggesting either poor support or active discrimination in recruitment.

03

The anatomy of exploitation

Understanding how this crisis developed requires examining the ecosystem that enables it. At every level, perverse incentives align to exploit students whilst extracting maximum profit from public funds.

The ghost student phenomenon: NAO investigations revealed students who exist only on paper – enrolled to trigger loan payments but never attending classes. In one case, a university discovered the “majority” of students at a franchise partner weren’t producing their own assignments. When challenged, just six per cent responded, with evidence suggesting even these were coached. The Student Loans Company identified 3,563 suspicious applications worth £59.8 million linked to organised crime. These aren’t isolated incidents but systematic fraud.

The profit pipeline: The financial flows reveal the scandal’s architecture. Universities receive 12.5 to 30 per cent in franchise fees. Private providers then extract profits of 30 to 53 per cent. Domestic agents – a largely invisible industry until recently – take commissions for each student recruited. By the time money reaches actual education, perhaps 30 pence of each pound remains. One provider showed a £73 million turnover with just £17 million spent on education – the rest vanishing into administration and profits.

The absence of student voice: Also telling is the absence of independent student representation at franchise providers. There are rarely students’ unions, few course representatives with real power, and little independent advocacy. When students at one college investigated by OfS raised concerns in meetings, inspectors appeared to tick the “student engagement” box based on process not outcomes. Students don’t know their rights, can’t access support, and have no collective voice. This isn’t accidental – it’s designed to prevent challenge to the business model.

The lag that enables: Perhaps most pernicious is how outcomes-based regulation fails when growth is exponential. Continuation rates are measured over years – providers can recruit thousands before poor outcomes become visible. By then, owners have extracted millions, students have accumulated debt, and new providers have emerged to repeat the cycle. The system’s rear-view mirror approach enables exploitation by design.

04

Why memory matters: The FE precedent

What makes this crisis particularly galling is that further education faced – and largely solved – identical problems. Between 2014 and 2020, the ESFA witnessed widespread abuse of subcontracting arrangements – provision delivered hundreds of miles from lead providers, excessive management fees, students enrolled solely to access funding, and quality disasters hidden behind commercial confidentiality.

The parallels are uncanny. Where universities retain 12.5 to 30 per cent of fees, FE providers were skimming similar percentages. Where London-based companies now recruit students with pre-settled status for business degrees, FE saw similar targeting of vulnerable communities for basic skills provision. Even the ghost student phenomenon – learners who existed only to trigger funding – plagued both sectors.

The ESFA’s response was comprehensive and effective. In 2020, following CEO Eileen Milner’s stark warning in 2019 that “abuse of subcontracting will only ultimately serve to limit access for learners,” the agency launched a consultation that resulted in sweeping reforms.

These included:

  • A requirement for governing bodies to approve and publish a clear educational rationale for any subcontracting
  • Prior approval for geographically distant provision
  • Volume controls limiting subcontracting to 25 per cent of income
  • Restrictions on whole programme subcontracting
  • Direct contractual relationships with third parties
  • A single set of funding rules across all provision
  • Development of an externally assessed management standard

Crucially, these reforms were implemented within eighteen months, with most taking effect from the 2020–21 academic year. They worked. Subcontracting volumes fell, quality improved, and the most egregious providers exited the market. The Association of Colleges now reports that where subcontracting remains, “models are generally strong and reflective of local demand.”

05

Learning from FE’s experience: strengths and gaps

Four years after implementation, FE’s reforms show both successes and shortcomings that HE must learn from.

What worked well

Board-level accountability transformed franchising from a finance office decision to a governance priority. As college board minutes now demonstrate, subcontracting is a standing compliance item requiring active oversight. The requirement for published rationales forced transparency – no longer could providers hide dubious arrangements behind commercial confidentiality.

The prospect of a direct Ofsted inspection for large subcontractors changed behaviour. AELP’s Simon Ashworth notes that clearer lines of responsibility improved both quality and financial flows. The 20 per cent fee retention expectation, while not statutory, created a benchmark that shifted sector norms.

Where gaps remain

Nevertheless, implementation revealed weaknesses HE must address. The DfE customer forum shows ongoing confusion about audit requirements – practitioners report 12-week ESFA response times and ambiguity about filing requirements. And ESFA’s own 2023–24 assurance guide reveals that routine audits check funding-rule compliance but “do not check for compliance with the subcontracting standard” – the headline reform sits outside regular oversight.

Administrative burden fell heavily on small specialists. FE Week’s warnings about distance caps putting rural and SEND providers “out of business” proved prescient. The lack of a statutory fee cap means some providers still retain excessive percentages if they can “evidence value.” Regional variation adds complexity – devolved authorities interpret standards differently, creating what one multi-campus principal called “a compliance postcode lottery.”

06

Why DfE’s current proposals fall short

The Department for Education’s consultation proposals, while acknowledging the crisis, represent a fundamentally flawed approach that misunderstands both the scale and nature of the problem.

The centrepiece – requiring providers with over 300 students to register with OfS by 2028 – fails on multiple grounds.

The timeline is inexcusable: Waiting until 2028 for full implementation borders on regulatory negligence. The current growth trajectory suggests over 200,000 students will pass through franchised provision before controls take effect. At current dropout rates, that represents 60,000 students failing to continue – each saddled with thousands in debt. The NAO has already identified organised crime in the sector – waiting four more years while criminal enterprises operate with impunity defies comprehension.

This timeline also contradicts the government’s own rhetoric about urgency. As Phillipson herself noted: “This problem has been growing and has been highly concentrated in a small number of providers in the sector.” If the problem is both growing and concentrated, delay makes no operational sense.

The threshold is too high: Setting the bar at 300 students ignores how damage accumulates. A provider teaching 250 students at a 66 per cent continuation rate still represents 85 failed students annually. Across multiple such providers, the aggregate harm is substantial. FE learned this lesson – even smaller providers can cause significant damage when operating at scale across multiple partnerships.

Registration alone won’t solve systemic or incentives issues: OfS registration is necessary but insufficient. As cases have demonstrated, registered providers can still engage in academic fraud, aggressive recruitment, and poor practice. The register was never designed to handle profit-driven providers operating at the margins. Without addressing the fundamental incentives – the extraordinary profits available from minimal delivery – registration merely legitimises current practice.

OfS itself has acknowledged capacity constraints, temporarily closing new registrations in 2024. Adding hundreds of franchise providers to an already strained system invites regulatory failure.

The innovation fallacy: DfE’s approach fundamentally misunderstands innovation. Small providers can indeed innovate – Channel 4 demonstrates this principle in broadcasting, commissioning ground-breaking content without owning production facilities. But Channel 4 doesn’t claim every independent production company needs a broadcast licence.

The parallel in HE should be clear – innovative small providers can create excellent educational experiences through partnership without needing full institutional infrastructure. Forcing them all to become mini-universities misses the point entirely.

The proposals ignore the agent problem: DfE’s consultation barely touches the domestic agent industry despite its central role in driving inappropriate recruitment (notwithstanding repeated promises of action dating back to January 2024). Waiting for April 2025 just to make the Agent Quality Framework mandatory – and even then only for international recruitment – shows a failure to grasp how these operations work.

Domestic agents operating on commission, targeting vulnerable communities, using misleading advertising on TikTok and in shopping centres, are the sharp end of exploitation.

No real powers over financial arrangements: The proposals say nothing about the financial splits between universities and franchise partners. When universities cream off 30 per cent and franchise providers still make 50 per cent profits, simple mathematics reveals how little reaches actual education. Without transparency requirements or caps on profit-taking, registration merely provides official blessing for extraction.

The geographic loophole remains: Requiring registration doesn’t address the fundamental absurdity of students registered in Canterbury studying in London, or students from a university in Leeds taught in Birmingham. The fiction that meaningful oversight can occur across such distances will persist. FE’s “one hour by car” rule recognises practical reality – universities cannot easily monitor provision hundreds of miles away, and should be required to demonstrate more clearly that they can if proposing to do so.

Validation as escape route: Perhaps most critically, DfE’s proposals may accelerate a shift from franchising to validation arrangements. If franchise partners must register with OfS, they might instead seek validation – where students register directly with them while receiving awards from universities. This creates even less university oversight whilst maintaining the prestigious brand. The proposals risk pushing problems into an even murkier corner.

07

The political economy of forgetting

The failure of previous governments to apply FE’s lessons to HE reveals deeper pathologies in educational policy-making. Three key factors explain why so much has been forgotten:

Sectoral silos: Despite rhetoric about a unified tertiary sector, FE and HE occupy different policy universes. They have different regulators, different funding mechanisms, and crucially, different teams within DfE. Hard-won lessons in one sector rarely cross the divide. This artificial separation enables identical problems to be treated as novel challenges requiring years of consultation and delayed implementation.

The cultural divide between sectors compounds structural separation. HE policy-makers often view FE as fundamentally different, ignoring that students, providers, and fraudsters move seamlessly between sectors.

Regulatory capture: The HE franchise boom benefits powerful interests. Universities facing demographic cliffs and frozen fees find franchising an attractive revenue stream. Private providers and their investors – including some with remarkable political connections – profit handsomely.

The domestic agent industry, invisible until recently, depends entirely on current arrangements. These interests have successfully framed rapid reform as threatening widening participation, despite evidence that franchise provision often fails the very students it claims to serve.

The innovation illusion: Since the 2011 and 2015 white papers, policy-makers have confused market entry with innovation. The narrative that regulatory barriers stifle new providers offering radical alternatives has survived despite minimal evidence.

Dyson, and NMITE (the New Model Institute for Technology and Engineering) represent genuine innovation; thousandth iteration business degrees in converted offices do not. Yet fear of hampering “innovation” paralyses necessary regulation.

08

The cost of delay

DfE’s current consultation proposes requiring franchise partners with over 300 students to register with OfS. Implementation would begin in April 2026, with first decisions in September 2027 for the 2028–29 academic year.

This leisurely timeline ignores urgent realities:

Financial haemorrhage: At current growth rates, over £2 billion in public funding will flow to unregistered providers before controls take effect. Much will fund provision with continuation rates below 70 per cent, meaning hundreds of millions in loans for students who never complete their courses. The maintenance loan fraud alone – with over 10,000 students annually receiving cash but no tuition – represents tens of millions in direct losses.

Student harm: Tens of thousands more students – predominantly from disadvantaged backgrounds – will be recruited through misleading advertising into programmes with minimal oversight and poor outcomes. Each cohort that enters before reform represents thousands of individual tragedies: debt without degrees, promises without prospects.

Sector reputation: Every scandal further erodes public confidence in higher education. The Sunday Times’s “walk-in degrees” headline joins a litany of negative coverage that tars all universities with the franchise brush. Delay amplifies reputational damage that affects even excellent providers.

Regulatory credibility: OfS was established partly to prevent repetition of “cashpoint college” scandals. Its failure to act decisively undermines confidence in risk-based regulation. When the regulator’s “boots on the ground” take years to march anywhere meaningful, the entire regulatory philosophy comes into question.

09

The translation challenge: From FE to HE

This paper argues that ESFA’s reforms, enhanced by lessons from implementation, could transform HE franchising within months. The core principles remain sound but require strengthening in key areas:

Educational rationale and governance

The FE requirement for boards to approve and publish a rationale for subcontracting addresses precisely the governance failures OfS has identified. According to Advance HE, universities’ audit committees have been rather too sanguine – effective oversight of contractual arrangements “had proved a challenge” for many governors, a common concern from whom was receiving the right kind of information in sufficient detail to give them “confidence in any subcontractual arrangements.”

Requiring a published rationale would force institutions to justify why a provider in the North West needs partners in London, or why some franchise to providers whose continuation rates languish twenty percentage points below campus provision.

However, HE must go further. Boards must not only approve rationales but also review them annually against outcomes data. Where franchise provision consistently underperforms campus delivery by more than 10 percentage points on any key metric, partnerships must be terminated within 12 months.

Each provider should have to have a published policy on subcontracting, and it should include the rationale for subcontracting provision. It must enhance the quality of the offer, and providers should be explicitly informed that they must not subcontract delivery to meet short-term funding objectives.

That enhanced quality would have to hit one or more of the following aims:

  • enhance the opportunities available to learners
  • fill gaps in niche or expert provision or provide better access to training facilities
  • support better geographical access for learners
  • support an entry point for disadvantaged groups
  • support individuals who share protected characteristics, where there might otherwise be gaps
Financial probity

Here we must go beyond FE’s approach. Universities must neither profit from nor subsidise franchise arrangements – fees should reflect actual costs only, with full transparency required. This cost-recovery principle removes perverse incentives for expansion whilst ensuring proper oversight isn’t undermined by financial dependence.

Providers should have to set out their full range of fees retained and charges that apply including:

  • funding retained for quality assurance and oversight
  • funding retained for administrative functions such as data returns
  • funding retained for mandatory training delivered to subcontractor staff by the directly funded provided
  • clawback for under delivery or other reasons
  • how the provider will determine that each cost claimed by a subcontractor is reasonable and proportionate to the delivery of their teaching or learning and how each cost contributes to delivering high quality learning
Provider profit

Further Education is not the only part of the Department for Education where learning could be found. The Children’s Wellbeing and Schools Bill represents a significant shift in how government approaches profiteering – its Clause 15 creates a regulatory framework that establishes the legal mechanism to introduce profit caps should market interventions fail.

The parallels between social care and HE franchising are striking. Local authorities struggle with private providers extracting excessive profits from children’s homes, and care home sector research reveals how providers extract value through complex corporate structures, with concern that the largest for-profit providers taking £15 of every £100 received through profit, rent payments, directors’ remuneration, and interest payments – double the rate of smaller providers.

Similar patterns are present in HE franchising, where opaque financial arrangements obscure the true cost of provision and the destination of student fees. The practice of charging high interest rates on intercompany loans, identified as hidden profit extraction in care homes, also appears in various forms across franchised HE provision.

Adapting the approach in the Bill would involve requiring all for-profit providers delivering franchised higher education to register directly with the Office for Students. The framework would grant the Secretary of State powers, through OfS, particular types of mandatory financial reporting to surface true leakage – and would also give the SOS the power to impose profit caps specifically on for-profit franchised providers, international pathway operators, and private training providers delivering under university franchise agreements.

Geographical controls with flexibility

ESFA’s “one hour by car” principle for FE subcontracting directly addresses the distance problem. The proliferation of London-based providers serving students registered at universities hundreds of miles away makes a mockery of place-based education. Prior approval for distant provision – already operational in FE – would end the fiction that educational oversight can be effectively maintained from Canterbury to Canary Wharf.

Nevertheless, geographical controls should accommodate legitimate exceptions. The specialist provision linked to an area of expertise held by the main provider, specialist provision for students with particular disabilities, and genuinely innovative partnerships deserve consideration. The key is shifting the default from permissive to restrictive – proximity unless justified, not distance unless challenged.

Volume restrictions while recognising innovation

The FE sector’s 25 per cent cap on subcontracted provision (with a trajectory towards 10 per cent) offers a ready-made solution to universities becoming mere “badge providers.” When institutions teach more students through partners than on their own campuses – as several now do – questions about institutional identity become urgent. A phased reduction would allow adjustment whilst preventing further expansion.

However, we must create space for genuine innovation. A separate “innovation track” for truly novel provision (verified by external review) could exceed limits. This protects quality whilst enabling genuine advancement – not the thousandth business degree but actual educational innovation.

Programme integrity with nuance

FE’s restrictions on whole programme subcontracting recognise a fundamental truth – students who never set foot on campus, never meet university staff, and never access university facilities are not meaningfully students of that university. The requirement for prior approval of such arrangements would end the most egregious examples of distance franchising.

Yet implementation must avoid FE’s administrative tangles. Clear criteria, fast-track processes for established quality providers, and recognition of blended models where students access both sites can maintain standards without strangulation.

Providers should be told that they must only use subcontractors for delivery of the provision if they have staff with the knowledge, skills, and experience to successfully select subcontractors in line with the requirements of the funding rules, contract with and actively manage those subcontractors, and that those charged with governance determine the subcontractors as being of high quality and low risk to public funds.

There should be standard terms that have to be included in contracts. They would have to list the services provided and the associated costs for doing so, with specific costs for quality monitoring activities and specific costs for any other support activities offered broken out (with their contribution to the delivery of high-quality learning noted).

Subcontractors should have to agree to give OfS access to their premises and to all documents related to their subcontracted delivery, have to provide student data, and must provide sufficient evidence to allow the subcontracting provider to assess performance against OfS’ regulatory framework.

Student voice and protection

FE’s reforms didn’t adequately address student representation – a gap HE must fill. Every franchise arrangement must include funded student advocates, clear complaints procedures aligned with OfS B conditions, and annual student surveys with response rates above 50 per cent.

Results must be published separately from campus provision – no more hiding poor satisfaction in aggregated data. There should be an expectation that the subcontracting provider’s students’ union will play a role in working with students at the provider to assess quality and support students with complaints.

OfS must also publish provider-level data for all franchised-to organisations, regardless of registration status. If a provider teaches 200 students across multiple partnerships, aggregate performance should be visible. Transparency drives improvement.

Perhaps most critically, HE must address the lag problem that bedevils outcomes-based regulation. Monthly data submissions on recruitment, attendance, and early warnings can trigger intervention before thousands accumulate debt at failing providers. FE’s experience shows annual reporting enables problems to metastasise – HE must do better.

10

Recommendations: A comprehensive reform package

Learning from both FE’s successes and shortcomings, this paper proposes a phased implementation of proven reforms, enhanced by four years of operational experience. These recommendations prioritise immediate student protection while building robust long-term oversight.

1. Emergency Measures (Immediate – by January 2026)

Freeze and investigate existing arrangements:

  • Impose moratorium on new franchise partnerships exceeding 50 students pending reform implementation
  • Trigger immediate OfS investigations at partnerships with continuation rates below 70 per cent
  • Establish emergency intervention powers where organised fraud is suspected
  • Require all current partnerships to submit monthly data on recruitment, attendance, and early progression indicators

End commission-driven recruitment:

  • Ban domestic agents from receiving per-student recruitment commissions
  • Make Agent Quality Framework mandatory for all recruitment (not just international)
  • Require full disclosure of agent relationships and payments in partnership agreements
  • Implement “cooling off” periods preventing students from re-enrolling solely to access maintenance loans
2. Governance and Educational Rationale (April 2026)

Board-level accountability:

  • Mandate governing body approval of all franchise arrangements with published educational rationale
  • Require annual review of rationales against outcome data, with automatic termination where franchise provision underperforms campus delivery by >10 percentage points on key metrics
  • Make subcontracting oversight a standing compliance item for audit committees
  • Publish separate performance data for franchise provision on all OfS metrics

Educational justification requirements:

Each partnership must demonstrate it enhances quality through one or more of:

  • Improved geographical access for underserved communities
  • Specialist facilities or expertise unavailable on campus
  • Targeted support for students with protected characteristics
  • Genuine educational innovation (verified through external review)
  • Entry pathways for disadvantaged groups with evidence-based wraparound support
3. Financial Transparency and Profit Controls (April 2026)

Cost-recovery principle for universities:

  • Limit university fee retention to actual oversight costs only (no profit, no cross-subsidy)
  • Require detailed breakdown of: quality assurance costs, administrative functions, mandatory training, clawback provisions
  • Mandate quarterly financial reporting with automatic audit triggers for unexplained variances

Work towards profit caps for franchise providers:

  • Require full disclosure of all financial flows including: agent commissions, related-party transactions, director remuneration, facilities costs
  • Legislate to allow imposition of pre-tax profit margin limit with immediate loss of student loan access for violations
  • Create automatic clawback mechanisms where profits exceed any imposed caps retrospectively

Enhanced financial oversight:

  • Cross-agency data sharing between OfS, HMRC, Companies House, and Student Loans Company
  • Biometric attendance monitoring at providers with suspicious financial patterns
  • Real-time monitoring of maintenance loan drawdowns without corresponding fee payments
4. Geographic and Structural Controls (September 2026)

Distance restrictions with specialist exemptions:

  • Apply “one hour by car” rule as default requirement between university and franchise provider
  • Create fast-track exemption process for innovative partnerships
  • Require prior OfS approval for all distant provision with published justification

Volume and programme integrity:

  • Cap franchised provision at 25 per cent of university’s total student numbers (reducing to 15 per cent by 2029)
  • Prohibit whole-programme subcontracting without prior approval and evidence students access meaningful university facilities/staff
  • Extend all controls to validation arrangements to prevent regulatory arbitrage
  • Create separate “innovation pathway” for genuinely novel provision verified by external academic review
5. Student Protection and Voice (September 2026)

Independent representation:

  • Fund student advocates at all franchise providers through a levy on partnership fees
  • Require universities to support students’ unions to extend support and scrutiny to franchised students with separate reporting
  • Mandate student satisfaction surveys with >50% response rates, published separately from campus provision
  • Establish clear complaints procedures aligned with OfS B conditions with university-level escalation

Enhanced consumer protection:

  • Require plain English disclosure of: true continuation rates, employment outcomes, distance from awarding university, profit margins
  • Implement mandatory “reflection periods” before enrollment with independent advice access
  • Establish hardship funds and compensation funds for students at failed providers funded by sector levy
6. Data, Monitoring and Enforcement (January 2026 onwards)

Real-time oversight:

  • Monthly submissions on recruitment patterns, attendance data, assignment submissions, early warning indicators
  • Automated alerts for – suspicious recruitment spikes, ghost student patterns, below-threshold attendance
  • Cross-reference with HMRC employment data to verify student status

Unified regulatory approach:

  • Joint FE/HE audit framework covering both funding compliance and quality standards
  • Shared intelligence protocols between education regulators, law enforcement, and border agencies
  • Annual review process with rapid policy adjustment capability

Transparency requirements:

  • Public dashboard showing all partnership performance data updated quarterly
  • Mandatory disclosure of – financial arrangements, geographic locations, agent relationships, related companies
  • Annual sector reporting on franchise provision impact and outcomes
7. System Learning and Innovation Support (Ongoing)

Cross-sector knowledge transfer:

  • Establish joint FE-HE implementation group with practitioner representation
  • Create policy learning protocols preventing regulatory amnesia across government departments

Innovation pathway:

  • Channel 4 model enabling small providers to deliver excellence without full institutional infrastructure
  • Fast-track approval for verified educational innovation with enhanced monitoring
  • Support genuine widening participation through evidence-based partnerships

Implementation flexibility:

  • Avoid FE’s “postcode lottery” through consistent national interpretation
  • Regular consultation with quality providers to reduce administrative burden
  • Built-in review mechanisms with annual policy adjustment capability
8. Anti-Fraud and Enforcement Powers (Immediate)

Criminal justice coordination:

  • Dedicated fraud investigation unit with powers to freeze student loan payments
  • Systematic prosecution of organised fraud with asset recovery
  • Intelligence sharing with the National Crime Agency and border agencies

Enhanced detection capabilities:

  • Biometric attendance systems at high-risk providers
  • Cross-matching of student loan, tax, and immigration data
  • Mandatory reporting of suspicious recruitment patterns

Graduated sanctions:

  • Immediate suspension of student loan access for serious breaches
  • Financial penalties for universities failing in oversight duties
  • Director disqualification for systematic fraud
  • Civil recovery of misappropriated funds
Implementation Timeline

Phase 1 (January-March 2026): Emergency measures and fraud investigation

Phase 2 (April-September 2026): Governance, financial, and geographic controls

Phase 3 (September 2026-April 2027): Student protection and full registration requirement

Phase 4 (April 2027 onwards): System learning and continuous improvement

This phased approach enables immediate protection while building robust long-term oversight. Each phase builds upon the previous one, ensuring practical implementation informed by operational experience. The timeline reflects urgency while avoiding FE’s implementation tangles that confused practitioners and delayed effective oversight.

11

The choice

The evidence is overwhelming – franchise abuses in higher education mirror those previously seen in further education. The solutions are proven – ESFA’s reforms successfully addressed identical problems. The only question is whether we will apply these lessons – enhanced by implementation experience – or repeat history.

Critics will argue rapid implementation risks unintended consequences. They will invoke innovation, access, and autonomy. These concerns echo FE’s experience – where quality providers adapted while exploitative ones exited.

But we must learn from FE’s gaps too – avoiding excessive burden on genuine specialists, ensuring consistent oversight, and maintaining flexibility for real innovation.

The government must choose. Continue leisurely consultation while billions flow to dubious providers and thousands accumulate worthless debt. Or demonstrate that policy learning crosses sectors, that student protection trumps vested interests, and that public money demands proper stewardship.

The choice extends beyond education policy. At a time when public services face unprecedented pressure and every pound matters, can we afford to finance 53 per cent profit margins? When trust in institutions continues to erode, can we tolerate preventable scandals? When rebalancing the national economy remains a priority, can we accept provision that exploits rather than empowers disadvantaged communities?

The central question posed by this paper – why is government’s memory so short? – reveals uncomfortable truths about policy-making silos, regulatory capture, and vested interests. Nevertheless, recognising these barriers enables overcoming them.

The franchise crisis represents not novel challenges but familiar problems with proven solutions. FE’s reforms, enhanced by implementation lessons, offer a blueprint requiring only adaptation, not invention. What we lack is not knowledge but will – the will to learn across boundaries, to act on evidence, and to protect the vulnerable over the powerful.

It is arguable whether a sector that prides itself on knowledge creation can claim credibility while proving incapable of institutional learning. A government promising change contemplates timelines extending beyond likely electoral cycles. A regulator established specifically to prevent past scandals watches identical scandals unfold.

Under the new economic paradigm of constrained resources and maximum accountability, repeating expensive mistakes becomes doubly unacceptable. When solutions exist – tested, refined, ready – delay represents not prudence but negligence.

This paper’s recommendations balance proven approaches with implementation wisdom. They protect students whilst enabling genuine innovation – commissioning excellence without requiring full infrastructure. They ensure financial probity through cost recovery and profit caps, while avoiding strangulation. They represent not perfection but pragmatism – the art of the possible informed by the lessons of the actual.

The tools exist, the evidence compels, and the solutions await.

References

Advance HE (n.d.). Governor view: franchise arrangements. [online] York: Advance HE.

Ashworth, S. (2024). It’s time to take on the subcontracting profiteers. FE Week, [online].

Association of Colleges (n.d.). Written evidence submitted. [online] London: UK Parliament.

Centre for Health and the Public Interest (CHPI) (2019). Plugging the leaks in the UK care home industry. [online] London: CHPI.

Centre for Health and the Public Interest (CHPI) (n.d.). How to regulate the profits of public service providers. [online] London: CHPI.

Department for Education (2024). Franchising in higher education. [online] London: Gov.uk.

Dickinson, J. (2023). OfS insight on the risks of franchising fall short at addressing the incentives. Wonkhe, [online].

Dickinson, J. (2024). Some students take maintenance loans but not fee loans and nobody knows what is going on. Wonkhe, [online].

Dickinson, J. (2024). The question on regulating franchising isn’t how, it’s why. Wonkhe, [online].

Education and Skills Funding Agency (ESFA) (2024). Common findings from assurance work on post-16 education providers: 2023 to 2024 assurance year. [online] London: Gov.uk.

National Audit Office (2024). Investigation into student finance for study at franchised higher education providers. [online] London: NAO.

National Audit Office (2024). Investigation into student finance for study at franchised higher education providers – Full Report. [online] London: NAO.

National Audit Office (2024). Investigation into student finance for study at franchised higher education providers – Summary. [online] London: NAO.

Office for Students (2024). Insight Brief 22: Subcontractual arrangements. [online] Bristol: OfS.

Office for Students (2024). Subcontractual arrangements in higher education. [online] Bristol: OfS.

Office for Students (n.d.). Subcontractual partnership student outcomes dashboard. [online] Bristol: OfS.

The Telegraph (2014). Illiterate builder in £400,000 fake student loan trafficking scam, court hears. The Telegraph, [online] 27 November.

The Times (2023). Walk-in degrees sold in UK. The Times, [online].

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The Author

Mark Leach MBE
Founder & Chair
Mark Leach is the founder and Chair of The Post-18 Project. Mark is also Editor in Chief of Wonkhe – home of the higher education debate – a platform he founded in 2014 after the first part of his career in higher education policy and as a Labour adviser. Mark was appointed MBE for services to higher education in the King’s Birthday Honours in 2023.

Tooling up: Building a new economic mission for higher education

We argue for a fundamental shift in how the UK government conceptualises, regulates, and incentivises higher education to align it more closely with a new, proactive industrial strategy aimed at driving national economic growth and addressing regional inequalities

Date:
9 June 2025
Authors:
Dr Debbie McVitty, James Coe, Jonathan Simons
Image: Ikon
01

Executive summary

The government wants economic growth. That is obvious to anyone who follows politics in even a cursory way. If the country cannot become more productive, if the economy does not grow, and if people do not feel their lives are getting better, Keir Starmer will be a one-term Prime Minister.

The government has, as an asset, a higher education system which, on many metrics, is the envy of the world. But it is also structurally disconnected from wider post-compulsory education provision, and driven almost entirely by student choice rather than the government’s economic priorities – and the current funding and regulatory arrangements do not offer many levers to government to change this. While the Secretary of State for Education has set out her priorities for higher education, there is on a daily basis in government a weak link at best between the work of the higher education system, and the work to drive economic growth.

This government has indicated its plans to make a decisive break from the broad consensus around macroeconomic strategy that has held sway in recent decades. For this administration, economic thinking requires not just a response to market failures, but a more proactive industrial strategy that takes account of a wide range of factors – geography, industry, supply chains, national security, technology – to realise the potential for growth in all parts of the country.

Previous governments’ failure to integrate skills policy, fiscal intervention, and economic reform into a framework that could deliver deeply felt and widely shared economic growth, are believed to be at the root of the malaise the country has felt since at least 2008. The last 15 years of uneven growth, low skills equilibria, regional inequality and political disengagement make the case for the new reform stronger.

Higher education policy has been guided by the older economic thinking of market-based, laissez-faire engagement, with a focus on expanding participation, student choice, competition between providers, and more recently lower barriers to entry for students and providers. For higher education to play a role in the new paradigm, government and institutions will both need to reconceptualise higher education as part of a wider system of post-compulsory education provision. Government will need to find, and higher education institutions accept, regulatory levers and incentives to align higher education provision to economic priorities as set out in the government’s industrial strategy. And all of this under considerable fiscal pressure.

This paper attempts to map the philosophical underpinnings of the shift that will be required, explain why it is necessary, and indicate some compass points for higher education reform in the forthcoming post-16 education and skills and HE reform white paper.

A quick note about scope and terms:

This paper specifically addresses higher education provision in England – which is delivered by universities, colleges, specialist providers and other higher education institutions and encompasses a range of different kinds of qualifications, including higher technical qualifications, higher and degree apprenticeships, traditional degrees and postgraduate qualifications.

02

Introduction

Growing the economy is the only hope the Labour government has of achieving any sustained electoral success. If the country cannot become more productive, if the economy does not grow, and if people do not feel their lives are getting better, Keir Starmer will be a one-term Prime Minister.

Sustained and significant economic growth is an enormous challenge. The country has been stuck in a productivity funk with people’s wages lower, their towns and cities less prosperous, and their lives less expansive, because of successive governments’ failure to recapture lost growth following the 2008 financial crash. No amount of strategies, policies, frameworks, moonshots, levelling up, fiscal bazookas, or any other number of interventions has broken the fundamental problem that the UK does not have the right people, with the right skills, in the right jobs, in the right conditions, to cumulatively make the country more productive.

While much of the public sector and further education has felt the pinch of austerity since the 2008 crash, higher education provision, particularly in universities, has been relatively well protected – grounded in a longstanding assumption among policymakers that broad investment in higher-level skills and research and innovation would pay dividends in national economic growth and productivity. Those happy times seem to be at an end. In ministerial directions, funding choices, and political rhetoric the government’s faith in the capacity of higher education and the knowledge economy to provide the economic silver bullet seems to be ebbing, with a rhetorical turn to skills and “vocational” options, particularly at sub-degree level and a parallel downplaying of the value of a traditional degree.

It is arguable whether the last 15 years of uneven growth, low skills equilibria, regional inequality and political disengagement represent a failure for the higher education sector or whether the efforts of higher education institutions have mitigated the wider problem. It is easy to point to both significant successes and failures in what is a large and diverse sector. The wider contention of this paper is that no government has yet found a way to truly harness the potential of the higher education sector in the service of economic growth, joining the policy dots in a sufficiently systematic way so as to create the right regulatory and funding incentives to orient higher education providers towards government economic priorities.

You may argue that higher education provision is not solely about economic growth and autonomous institutions are under no obligation to dance to the government’s tune. Both contentions are technically correct, but are arguably wilfully blind to the challenges the country is facing, the dependence of the sector on public money and the changing expectations of the public and policymakers of how institutions are held accountable for their use of that money when it is increasingly scarce.

The choice facing the sector, to paraphrase Universities UK president Sally Mapstone in a speech to vice chancellors at the 2024 Universities UK annual conference, is to go on like this into a period of decline, or to meet a government committed to economic growth with a vision of a reorganised sector and in doing so ensure their own sustainability, and a stronger economy.

03

A new approach to economic growth

Ever since the 1980s, successive UK administrations have embraced a single theory of economic growth. The approach, or elements within it, can be described (positively or otherwise) as “a Treasury approach”, “sound money”, “neoliberal”, “supply side”, “laissez-faire”, or “light touch”, among others.

The key aspects include:

  • A belief in lightly regulated private markets as the dominant motor for economic growth;
  • Using taxation and regulation, to a greater or lesser extent, as a way of redistributing the proceeds of that growth towards areas of political or economic focus;
  • A belief in using state intervention, again to a lesser or greater extent, as primarily a means of addressing market failure;
  • A belief in choice and contestability within both private and public markets as a way of driving innovation and lowering prices;
  • A premium on maintaining control of overall money supply by the Exchequer, and holding inflation low;
  • The creation of growth principally through supply side reforms including deregulation, privatisation of former state owned enterprises, deprioritisation of trade union power, and tax cuts;
  • A belief in the innovative power and wealth enhancing aspects of globalisation, and support for the mechanisms that underpin this, including free trade, and lightly regulated movement of labour and capital;
  • The shift of labour in higher wage economies such as the UKs into the service economy, with manufacturing being shifted to lower wage economies; and
  • A strong focus on education and skills at all levels to provide a labour force that can compete and innovate globally.

There are differences between administrations, both between Conservative Prime Ministers, and especially between Conservative and Labour governments. Neither party would willingly accept a thesis of complete consistency, and indeed, measures like different volumes of public spending as a proportion of GDP do show the impact of conscious political choices. Nevertheless, these central economic tenets have remained consistent even where their application has differed between governments.

The financial crash and its legacy

The 2008 financial crisis marked the first major break in this model – certainly among the most influential politicians and policymakers holding sway in successive Whitehalls and Westminsters.

Since the crash, successive UK governments have confronted a series of pervasive and linked economic problems: low or no economic growth, low productivity, regional inequality coupled with low growth in areas outside of London, and a sizeable cohort of “left-behind” individuals and communities. A succession of further economic shocks such as Brexit, Covid-19 and the Russian invasion of Ukraine have driven up the cost of living, and added to the general economic malaise. Skills England analysis of ONS labour output data suggests that had UK productivity continued to grow at the rate seen pre financial crisis, it would be nearly a third higher than it is today.

This very particular set of economic problems in the last 17 years has prompted a search for new ways of thinking about economic growth. Without economic growth and the investment in public services it enables, governments have been faced with the unenviable choice of increasing taxation or reducing spending – or both.

GDP per capita compared to pre-recession trend


Source: IFS, The Conservatives and the economy, June 2024.

Rachel Reeves, and making a reality of a new approach

In the months leading up to the general election of 2024, then-Shadow Chancellor Rachel Reeves set out her version of a new approach. In highly technocratic language, she mirrored the US take on “modern supply-side economics,” as then US Treasury Secretary Janet Yellen described the Biden administration’s economic approach – known as “Bidenomics” in popular parlance in the US and “securonomics” in less popular parlance in the UK.

In a 2023 pamphlet for Labour Together, and her Mais lecture of March 2024, Reeves argued that the role of governments is to shape markets, not just “correct” them: “Governments always shape markets. Good governments consider how they do so.”

For Reeves, the new economic thinking requires not just a response to market failures, but a more proactive industrial strategy that takes account of a wide range of factors – geography, industry, supply chains, national security, technology – to realise the potential for growth in all parts of the country. Reeves’ broad themes were economic stability, removing barriers to investment and large-scale reforms to planning and regulation, as well as a focus on skills, framed as amplifying individuals’ potential to contribute to the economy.

Reeves also criticised the failure of all governments to integrate skills policy, fiscal intervention, and economic reform, into a framework that could deliver deeply felt and widely shared economic growth:

For a decade, the last Labour government offered stable politics alongside a stable economic environment. In New Labour’s analysis, growth required on the one hand macroeconomic stability, and on the other supply side policies to enhance human capital and spur innovation. What followed was a decade of sustained economic growth, stability, and rising household incomes. Average household disposable income rose by 40 per cent. Two million children and three million pensioners were lifted from poverty. Public services were revitalised.

But the analysis on which it was built was too narrow. Stability was a necessary, but not a sufficient condition to generate private sector investment. An underregulated financial sector could generate immense wealth but posed profound structural risks too. And globalisation and new technologies could widen as well as diminish inequality, disempower people as much as liberate them, displace as well as create good work.
Economic security was extended through a new minimum wage and tax credits, but our labour market remained characterised by too much insecurity. Despite sustained efforts to address our key weaknesses on productivity and regional inequality, they persisted, and so too did the festering gap between large parts of the country and Westminster politics. Most of all, the ‘great moderation’ could not last. And as the global financial crisis unfolded, these weaknesses were exposed.

Although “securonomics” was a distinctively Labour proposition, it tracked with broader trends in economic thinking. A public policy analysis from government that sought to understand the effects of geographical disparities in growth and productivity on individuals and communities, and take a strategic view of the various factors that could begin to correct these imbalances, was the basis of both Boris Johnson’s levelling up agenda and some of the domestic policy championed by Theresa May and her key advisors.

The difference between Reeves and Johnson and to a lesser extent Reeves and May is that the Chancellor has a single organising theory of growth which is anchored in sectors, places, and market reform. Reeves has alighted on an economic programme of state reorganisation, market reorientation, and addressing regional imbalances, but she is undoubtedly like her predecessors pro-market, pro-growth, and pro-business.

Industrial strategy

The industrial strategy is the Labour government’s key economic document. The draft strategy, Invest 2035, published in October 2024, seeks to realise in practice the economic principles of an activist state, identifying eight key sectors and promising to connect these more closely with places to identify “clusters” in city regions where there is untapped and/or high growth potential.

The criticism of industrial strategies is that they inevitably lead the government to attempt to pick winners and in economies of such enormous complexity they are doomed to fail and in failing they will do more harm than good. The hope of this industrial strategy is that it will create the conditions for economic success, including in regions where it promises to devolve more powers to mayoral combined authorities.

Universities may feel rather slighted about how little they are mentioned in the industrial strategy green paper – former universities minister David Willetts called this “very odd” in a paper for the Resolution Foundation. But the working strategy rightly recognises national skills and innovation capability as foundational – the challenge is to marry up university and, more widely, the breadth of higher education provision, to the priorities established through the industrial strategy. If anything, the draft strategy offers a salutary reminder that for this government higher education and research forms part of the overall economic growth and productivity puzzle; it is not viewed as a target for development in and of itself.

04

Higher education in a market-based economy

The story of university regulation and oversight in recent decades more or less reflects the approach to the macroeconomy. Under a broad knowledge economy banner governments have sought to increase the supply of human and knowledge capital through increasing participation in higher education.

Tuition fees were introduced in England in 1998 under a belief that a more massified system had to be paid for, and that ought to fall at least in part on the graduates who benefit from the economic value of a degree. As the Chancellor Gordon Brown said ahead of further tuition fees rises through the Higher Education Act 2004, “It is right that, once students become graduates, they make a greater contribution” – a key tenet of supply side or neoliberal thinking (which was not copied in other home nations). Successive rounds of tuition fee rises increased the resource to institutions and shifted the balance away from the state and taxpayer. Under the stewardship of David Willetts and subsequently Jo Johnson as universities ministers, capacity in the system also expanded with the facilitated entry to the sector of so-called “alternative providers”. Increasingly, students were positioned as “paying customers” whose choices should drive competition between higher education institutions and in doing so drive up quality.

Until 2014 the mechanism for increasing participation in higher education was still linked to the state control of the overall supply of funded places. Once the government had implemented its policy of tying to the unit of resource for teaching to the student in the form of a tuition fee loan it became possible to remove the cap on places entirely, as happened in 2015, allowing higher education institutions to recruit as many students as they wanted. In 2015 the Conservative government also introduced the Apprenticeships Levy on business to expand apprenticeship provision at every level, with provision for providers to charge higher and degree apprenticeship fees at the same level as for bachelors degrees. As a result of these measures, higher education institutions were initially relatively well protected from the public spending cuts that followed the 2008 financial crisis. Further education colleges did not enjoy the same protections, and were subject to budget and numbers cuts across their programmes, particularly in adult education provision, though some could benefit from the fee reforms for their higher education provision.

There has been a significant period of uninterrupted growth in higher education, particularly in universities – and this growth has allowed universities to fund more research, invest in more buildings, and further their societal mission. The central contradiction is that this period of expansion has coincided with a period of economic stagnation in the rest of the country. It could be that the economy would have been worse without university expansion, or it could be there is no link between university growth and economic growth, or – perhaps more likely – that universities do support economic growth but not as well as they could because of a misalignment between government policy, funding, and incentives in the system.

Winter is coming

The system we have was designed to create the conditions for everyone with the will and capacity to benefit to be able to access their choice of higher education with no upfront costs – a noble aspiration. But just as the wider model of economic growth has come face to face with its downsides, so too has this model of funding and allocating places produced some significant system-level downsides: specifically in public satisfaction with higher education, the diversity and responsiveness of the offer, and the general instability of the system that creates barriers to fixing these issues.

The unsustainability of an home undergraduate funding model, in which students resent the expense of the core tuition fee “sticker price” while higher education providers struggle to cover their costs as the real value of the fee erodes with inflation, are well rehearsed. There is little public appetite for a transfer of public funds into higher education, though many believe it should be cheaper. There are problems with the student maintenance package in England, which falls well short of what students require to cover their living costs. There has also been a systematic inequity between the higher education student finance system which makes provision for student maintenance, and advanced learner loans, which do not – something the LLE should correct.

But the challenges the post-18 sector faces extend well beyond the core funding conundrum.

As the Augar review of post-18 education pointed out in 2019, the incentives in higher education are for institutions to offer courses that are well-understood and popular in the largest part of the market i.e. full-time three year undergraduate bachelors degrees and to a much smaller extent, degree apprenticeships. The current system has fuelled the headline of expansion of young entrants to degree-level qualifications while participation among those over 21, those studying part-time, and those studying sub-degree level qualifications has declined. The funding system is only one part of this picture – there are other underlying issues driving both supply of and demand for particular qualifications – but the broad point is that the system as it is currently configured does not create the conditions for being innovative in post-18 provision either to respond to changing student circumstances, or to employers’ needs.

Moreover, while notionally the current system operates a level playing field, in practice providers have a highly variable capability to operate and flourish in a competitive market. This competitive system is profoundly destabilising for those institutions less able to secure sufficient student numbers year on year to sustain their operating costs. Institutions not geared up to rapidly change their operating models to adapt to changed patterns of student demand – especially against a volatile backdrop of fluctuating international student numbers, eroding unit of resource for UK students, and the Covid-19 pandemic and period of inflation that followed it – have struggled to stay afloat.

This scenario in which popular institutions and courses have been able to expand student numbers, while others have contracted is a feature not a bug of a marketised system, benefiting the students who are able to secure their first choice of institution, including a greater number of students from less advantaged backgrounds who can more readily secure a place at a selective institution, if that is what they want to do. But behind the the headlines of increased choice, as the unit of resource via the undergraduate fee and the additional funding for high cost subjects distributed via the Strategic Priorities Grant have declined in real terms, the sector has seen a relative decline in provision of the subjects that cost more to deliver – subjects that, as Universities UK has pointed out, match closely with the sectors identified as priorities in the industrial strategy, while those that cost less to teach and have broad market appeal, such as business, have expanded.

Of particular concern to any government, but particularly to a Labour government, must be the support for regional institutions with significant public sector education provision. But beyond that risk of teaching, or nursing provision, for example, there is also a wider risk to subject and institutional diversity and continuation of delivery of subject areas with strong regional industrial links that a fully market-led approach cannot correct.

This might be deemed the price to pay for facilitating open student choice. Indeed, acting on the consumer interest over the provider interest is a key tenet of how successive administrations have managed public services more broadly – for example, expanding popular schools, allowing patients to choose their hospital for treatment and growing the most popular ones, and so on. But the higher education sector is not largely like other public sector institutions in that the government does not have the tools to manage market volatility such as forcing mergers or managing orderly institutional closure. As such, the destabilising effect on institutions has a direct knock on effect on the public interest. But nor has this greater matching by student preferences in higher education course and institution choice appear to have resolved chronic skills shortages in the country or addressed some of the ingrained productivity challenges.

Graduates, geography and the labour market

Given that much higher education provision does not relate to specific job roles, it can be hard to make precise claims about the relationship between higher education provision and the labour market. Claims that graduates are not “work ready” are not always very helpful; the definition of “work ready” is too subjective and fails to account for the very different environments and expectations that most graduates experience in education and workplace settings. However, higher education is dogged by claims about the “oversupply” of graduates leading to an estimated one-third nationally of those with graduate-level qualifications occupying jobs that are not currently classified as requiring a degree. The economic returns to a degree can be highly variable depending on the individual’s personal characteristics, subject of study and the sector and geography of an individual’s labour market participation, with patterns of growth in highly-skilled work uneven across the country. And as employer demand for graduates to arrive equipped with specific technical skills increases, higher education provision can sometimes struggle to stay up to date.

It is possible that these challenges arise because students are graduating with the “wrong” skillset from having graduated from the “wrong” subject; in other words, that students in aggregate are making choices only weakly linked to labour markets and/or the qualifications do not adequately prepare them for employment. It is also possible that some industries in some parts of the country struggle to deploy the skills of the workforce that is available to them because of having low access to the graduate labour market, a lack of investment in innovation, or lack of management capacity.

Either way, a wholly student-led approach to picking degree courses and then matching to graduate labour demonstrably isn’t leading to the necessary level of symbiosis between the economy and labour market (regionally or nationally) and its post-18 provision. And if, as the government’s projections indicate, the future economy will depend not only on a ready supply of people who are prepared to deploy general graduate level skills in the workforce, but also to some degree for specific knowledge and skills to be available in specific parts of the country, then the market will need to be shaped accordingly. Skills England’s assessment is that there are “especially strong benefits to be realised by ensuring higher education institutions are even more engaged with local skills needs, as well as those that are strategically important for our country, such as medicine and science.”

Place and provision

An over-focus on competition also has a knock-on impact on the institutional resource and strategic bandwidth of institutional leadership to develop and sustain new partnerships and innovative provision, and undertake “unfunded” activity such as civic and regional development. For many higher education institutions, including FE colleges and specialist providers, such activity is understood as being part of the core mission rather than a bolt-on – but it remains the case that the system we have does not incentivise or even, particularly, support this kind of civic and regional engagement, still less, against a highly competitive backdrop, coordinated co-development of post-18 provision.

To illustrate, a recent study exploring the challenges of a lack of coordination in the post-16 landscape for specific industries from the perspectives of employers, young people, and education and training providers found a wealth of systemic issues in addition to the industry-specific challenges.

The report cites:

  • a lack of defined structures for employers and education providers to engage with,
    competition between colleges and universities driving prioritisation of student enrolment rather than employer needs,
  • and for young people, fragmentation in the information, advice and guidance landscape along with baked-in prejudice towards technical and vocational provision.

Finally, the influx of new providers, many without their own degree awarding powers, has led to significant innovation and specialised higher education provision, from Cordon Bleu cookery to interdisciplinary degrees. But it has also led to a rapid increase in franchised and validated provision in which providers without degree awarding powers recruit and teach students and award the degree of another provider, often one that is located many miles away from the validated provision.

Such arrangements are, to an extent, a necessary and legitimate feature of allowing new entrants to the system, but increasingly it’s becoming clear that they can also attract actors whose primary interest appears to be in teaching as many students as possible at the highest possible profit margin, often specifically targeting students with low educational capital from economically underserved areas. Concerns about weak regulation of partnerships and potential fraud in the system have prompted the government to consult on proposals to strengthen oversight of partnership arrangements. Recent data suggests that in the last three years more than £1 billion in tuition fee loans has been paid to providers that not only do not have degree awarding powers but that do not appear on the Office for Students’ register of providers.

The system as it stands therefore has a worst of all worlds approach when it comes to skill provision. There is no effective means of matching labour market needs to student instruction. Providers are not incentivised to do the things that the government believes to be important, like regional growth. And where innovation does exist, the regulatory environment has failed to keep up.

Under the old economic paradigm, the government funded the expansion of traditional higher education as a good in and of itself, and then introduced various alternatives alongside it when the traditional model started to look a bit too abstract or a bit too expensive. Diversity of provision is a strength of the system, as it allows individuals to identify the version of post-18 education that will best suit their needs, but efforts to pursue diversity have led to fragmentation on both the supply and demand side.

Under the new economic paradigm, the government will continue to expand human potential through education and upskilling – that is why it has created Skills England. But rather than relying on the human capital produced to create economic growth, post-18 provision will need to be more closely aligned with wider industrial strategy and growth agendas. This requires something closer to a whole-system approach rather than piecemeal policy reforms.

05

An agenda for the post-16 education and skills strategy and HE reform white paper

The Labour government has made economic growth its number one priority. And it has also indicated through its general election manifesto some of its core ambitions for post-compulsory education provision, including the development of a comprehensive post-16 skills strategy, the creation of the new Skills England arms-length body, transforming selected FE colleges into Technical Excellence Colleges, converting the Apprenticeships Levy into a Growth and Skills Levy, and generally to improve access, raise standards and create a secure future for higher education “to deliver for students and the economy.”

The post-16 education and skills white paper is likely to set out an ambition to shift from a fragmented and competitive sector to a more coherent and coordinated one – as indicated by skills minister Jacqui Smith in a speech to the Association of Colleges conference in November 2024. Plans for reform of higher education will be published as part of that strategy, with policy detail expected on the themes of access, quality, higher education’s contribution to economic growth and regional development, and financial sustainability. The government has also committed to continue the rollout of the planned Lifelong Learning Entitlement (LLE) which, in its current form, will harmonise the student loan offer for higher education and adult learning above level 4 and make it possible in principle for an individual to register and receive loan finance for modules (initially only in designated technical courses) as well as full courses that lead to a formal qualification

A mountain to scale

The government has set itself a highly challenging task in any fiscal environment, never mind the current one. Even defining a post-16 education “system” – including level 3 A level/T level and their equivalents in schools and colleges, higher education, further education, apprenticeships, work based learning and adult education – is not an easy job. Designing and implementing policy interventions to build towards a more a coherent, efficient post-16 education and training system in England which maximises local and national economic growth, and is fair to all students and learners of all ages and circumstances, regardless of where they live and how they were brought up, feels like the sort of policy challenge designed for the proverbial long grass.

On higher education finance the indicators are that the government will index undergraduate tuition fees to inflation on a rolling basis – but it expects to see significant movement on efficiency, safeguarding of public finances, and delivery of its priorities as the quo for the public quid. There is clearly very little appetite for reform of the core funding model, however unpopular. And any hopes that there might be injections of new public funding to support activity in priority areas are clearly forlorn – as the government has shown in its decisions about cutting and reprofiling the Strategic Priorities Grant and the removal of funding from the vast majority of level 7 apprenticeships. Universities, under the auspices of a Universities UK taskforce have sought to show willing on efficiency and transformation, including pursuing new collaborative models for service delivery and operations, but the recent report of the taskforce’s work indicates that there is only so much the sector can do on its own initiative and to an extent it is looking to government to set out a “vision” around which the sector can convene.

The central policy question is how government can pivot the bits of the post-compulsory education sector that it has little direct influence over towards its core economic mission.

The government could propose relatively modest reforms: encouraging low-key local coordination between providers around access and skills through Local Skills Improvement Plans; wagging fingers on quality and leaning on the Office for Students to “crack down”; and endorsing efficiency efforts (while keeping its fingers crossed that any institutional insolvency can be managed under existing policy frameworks).

But this would be a mistake. As has been argued already, despite the knowledge and skills the post-18 sector demonstrably produces for the public benefit, the system is not in its current state fit for purpose if that purpose is driving economic growth and productivity, and by association raising the quality of life and opportunity for individuals across the country. Simply funding more of it has not led to the productivity gains that might be expected if the solution was simply about increasing higher-level skills in the general population.

While the reality may be that the government’s scope for reform at pace is limited, it should not be shy about setting out a bold agenda for a reformed higher education sector and defining some steps towards it. Adverse economic circumstances nevertheless offer an opportunity to create a new kind of higher education policy agenda – one that is neither entirely top-down from the state, nor left to the vagaries of “market choice” but one that builds in mechanisms for co-design and co-delivery from the outset and in doing so establishes a new civil compact between the state, higher education providers, and the public.

Under the auspices of a new industrial strategy, post-18 institutions will need to more closely link their activity to the new approach to economic growth. This could potentially have three different facets:

  • Housing and developing expertise on their regional economies and labour markets to inform growth agendas
  • Demonstrating responsiveness in education provision to specific labour market shifts and growth plans
  • Strategically intensifying research, innovation and knowledge exchange activity in core areas of alignment to industrial strategy and growth plans

While arguably any single higher education institution could point to activity in at least one of these areas, the prize for national policymakers will be to harness the collective knowledge and practice of the sector to enable all of this activity to be more coordinated and strategic, and more accountable to regional stakeholders and the public.

The upcoming strategy for post-16 education and skills and higher education reform is the opportunity for the government to set out its aspirations for a new system, even if every element of that system can’t be achieved right away – creating space for institutions to step up individually and collaboratively to use the knowledge and expertise they hold to develop answers to some of the policy challenges.

Compass points for reform

To achieve this, we propose that the government must, in its post-16 education and skills and higher education reform white paper, set out the government’s aspirations around five core policy themes: 

  1. Understanding the landscape: so that there is a framework underpinned by data and evidence for regional growth planning incorporating skills and innovation that regional authorities, especially those with lower maturity, are not obliged to reinvent the wheel in developing regional economic growth plans. 
  2. Developing regional education and skills brokerage systems: so that employers can have greater visibility of the knowledge and skills pipeline, and prospective students can benefit from greater coordination – with the potential for the emergence of innovative models of delivery including credit transfer arrangements
  3. Cooling the student recruitment market and supporting collaboration: leaving space for student choice while reframing incentives towards economic growth, with the longer term aim of reducing the risks of innovation 
  4. Killing the academic/vocational divide: reducing the complexity of the qualification landscape and opening up opportunity for institutions to design education that meets labour market and student needs
  5. Financing and facilitating transformation 

 

Understanding the landscape

The policy landscape is littered with failed regional economic growth initiatives from regional development agencies in the New Labour years, to local enterprise partnerships under the coalition government, to the “levelling up” agenda. Former Prime Minister Tony Blair has said that one of the lessons should be about the critical relationship between universities and economic growth:

If you look at those things that really drive economic development, I think the position of cities and universities are really important. We did a lot, in fact, to revive a lot of the cities. Cities like Newcastle and Liverpool, Glasgow, Cardiff…all of these places became much more interesting, much more vibrant places. But we didn’t really, until the end, start to understand the absolutely crucial relationship that was starting to develop between universities and economic development, which I think today is absolutely central.

Higher education institutions are obvious hubs for knowledge about economic growth in their region generally, and the role of skills and innovation in particular. Investing in knowledge about “what works” for differing regional economic ecosystems should reap significant dividends both in catalysing activity and ensuring it is monitored and evaluated to draw lessons for the future. 

Following publication of the industrial strategy, the government should conduct or commission a review of the knowledge landscape for regional economic growth, mapping both existing expertise and the data environment informing regional economic growth plans against national sectoral and spatial priorities, and setting out a plan to address gaps. 

In order to make this more regional approach work there should be a modest regional growth knowledge fund to which groups of regional providers and their partners can apply to establish regional growth insight centres with direct links to devolved authorities, on the assumption that the more efficient allocation of provision will be a net cost saving. 

Developing regional education and skills brokerage systems

In Scotland, the regional tertiary pathfinders pilot projects demonstrated what can be achieved with a very little money and a lot of good will – simply bringing education institutions together with employers and regional stakeholders to begin to map the education and labour market landscape and explore the potential for closer alignment in the spirit of action research led to all kinds of learning and new activity. 

England’s regional governance is arguably not yet mature enough to consider a funding devolution and commissioning framework for education and skills at every level, but it should be possible under the devolution framework for every region to have a “table” around which diverse education providers, employer representatives and other regional stakeholders “sit” that is explicitly tasked with:

  • better understanding the alignment between post-18 education and the labour market to inform dialogue with Skills England and government around regional skills and labour market priorities
  • creating a joined-up knowledge base about available curriculum pathways that can underpin provision of information, advice and guidance to prospective students and signposting for employers 
  • brokering proposals with education institutions for enhanced coordination and streamlining of provision 

The Devolution Bill should make provision for mayoral combined authorities to convene a post-18 education and skills provision group with a diversity of provider and industry representation that can draw on the insight from regional growth insight centres to develop post-18 pathways, provision and partnerships. These groups could initially propose business cases for reprofiling of funding but over time could be given direct commissioning powers and/or direct injections of public funding to catalyse new provision aligned to national or regional economic growth priorities. 

The forthcoming HE reform white paper and skills strategy should also set out an ambition for a regional access approach that sets collective targets for post-18/L4 or above participation, that is qualification agnostic and identifies key under-served groups across the education system that can guide shared priorities and collective action. The exception should be where an historically selective university has a published entry tariff above a defined level, it needs to be held to access targets for the recruitment of under-represented students. 

Cooling the market and supporting collaboration

Competition can be healthy, but there are downsides to a system driven entirely by student choice. While institutions may offer lots of positive noises about collaboration and coordination, the calculus of survival may yet encourage – or force – them into a competitive posture. Yet the prospect of reimposing universal student number controls or central labour market planning is also unpalatable, given the complexity of the system and the arbitrariness of freezing it in its current state. 

On the punitive side the government could explore a more robust regulatory approach to managing full-time home student number growth, placing temporary but binding limits on institutional growth rates, with a requirement to produce a business case for plans to breach that cap based on the industrial strategy’s priorities or in exceptional circumstances such as the acquisition of another provider. While a measure like this would probably not be welcomed by the sector, it could bring a measure of stability and potentially allow for more robust financial planning. Closer oversight of franchised arrangements could form part of this measure, with unregistered providers equally bound by growth restrictions unless there is a clear rationale for new provision – for example, to address a higher education “cold spot” or meet the need for emerging specialist provision in a particular industry.

On the incentive side, the government should designate national priorities where it believes post-18 institutions can collaborate, convene, and drive change. This should be a rolling set of priorities which are funded, through application and business cases, that cover both enormous internal challenges like training large cohorts of students in advanced digital skills, and efficiency measures like supporting collaboration in teaching design and delivery. The programme should simultaneously allow structured funds that ease the flightpaths for providers to make sensible choices on collaboration to ease cost burdens while incentivising targeted work on regional and national economic needs.

Within a calmer market environment there should still be a role for a regulator that is concerned with the material delivery of higher education via a concern for quality, value for money, and students’ interests. However, the Office for Students is not currently configured to be empowered to shape the market as well as regulating provision. Either the regulator will need to be reconfigured so as to be a more powerful convenor of activity or its regulatory role more tightly defined and the convening power directed elsewhere. Skills England could potentially be empowered to create policy space for developing the coherence that is sought across higher and further education, apprenticeships and adult learning. 

Killing the academic/vocational divide

Fragmentation of the qualification landscape does not serve students, institutions, or employers. For the last decade or so, government ministers have sought to promote participation in higher technical qualifications and degree apprenticeships, with limited success. Degree apprenticeships in particular are arguably a good example of policy failing to meet the expectations that were set for it. UCAS research with the Sutton Trust found that 40 per cent of prospective undergraduate students are interested in apprenticeships – far more than the volume of actual apprenticeship opportunities – indeed the main reason given for not taking up an apprenticeship was that there was not a suitable one available. That research also uncovered significantly worse experiences of finding information about and applying for apprenticeships, and a continued belief that degree apprenticeships are much less prestigious than traditional degrees.

From a student perspective, it doesn’t seem especially radical to suggest that for any post-18 applicant considering study at level 4 or above it should be possible to tap into diverse choices not only of different kinds of providers and subject areas but varied and flexible modes of study. Imagine if instead of the choice of a “degree” or a “degree apprenticeship” it was possible, within defined limits, to dial up or down the ratio of classroom to workplace delivery or the ratio of in-person to online delivery; to compress or extend the number of credits acquired in a given timeframe; or to be offered the opportunity to study with different kinds of provider at different points in a course – all within a single funding and regulatory framework. 

The ongoing rollout of the LLE should open up the opportunity to think about the kinds of provision that the government wants to fund as well as the funding delivery mechanism. Within a single framework there could be programmes that are designated as eligible for funding via the new growth and skills levy while others require students and/or employers to fund through direct financing or student loans. This would give the government the opportunity to incentivise strategically important provision, while enabling institutions to design qualifications in a way they think will best meet the needs of students and employers in as frictionless a way as possible. 

The post-16 skills and education strategy should indicate a plan to move to a single qualification framework for post-18 provision that allows for a sliding scale between work and scheduled learning, encompassing what we currently think of as higher and degree apprenticeships, higher technical qualifications and full degrees. Post-18 providers, in partnership with employers as appropriate, should be able to design qualifications within that framework that best meet their needs and that of the students they aim to attract. Under the auspices of a single qualification framework regulation of quality, students’ rights and interests and monitoring of student outcomes should begin to be brought together into a single regulatory framework. 

The government should commission a tightly focused review on the delivery of qualifications other than the “core” Level 6 Bachelors provision – specifically, level 4 and 5, and level 7 provision. 

  • Level 4 and 5 qualifications, like higher technical qualifications or higher apprenticeships, provide the skills that employers need in technical roles and also form a gateway to higher qualifications. 
  • Level 7, masters level qualifications, are not only an enormous attractor of international students but support the higher level knowledge and skills ideal for economic innovation and regional growth.

The review of level 4 and 5 should focus on how funding arrangements support a diversity of provision and a diversity of pathways both into skilled work and further learning either immediately or in future. The review of level 7, particularly given apprenticeship reform and the defunding of level 7 degree apprenticeships, should look at how education institutions can be supported to offer programmes that align to labour market needs, how learners could benefit from more flexible provision, and the ways in which the sector can maintain its global competitive advantage. More diverse entry pathways and more labour market alignment and flexibility in level 7 programmes should also incentivise providers to adapt their work at core level 6.

Financing transformation

Everybody knows there is no money – and what little money there is already is subject to cuts and reprofiling. But that means that both government and post-18 education providers need to be more creative about how to fund transformation. A number of UK banks already have deep relationships with higher education and would be open to discussions about a role for government in creating the conditions that would enable banks to consider supporting higher education transformation with private finance. The government should acknowledge the costs of transformation and commit to exploring with the sector sustainable options for funding it

More controversially, the government should not shy away from signalling what it would like to fund if economic circumstances improve. Throughout this paper there are suggestions for modest injections of public funds to catalyse and incentivise strategically important activity in the post-18 sector. A signal from the government about its priorities and aspirations could help to galvanise discussions now, even if the available funding pot is constrained. As institutions make difficult decisions about what is sustainable, and continue to reform their operating models, a clear steer from government about its priorities for post-18 education will help to guide those decisions. 

06

Conclusion

Higher education providers, of all kinds, are already doing significant work to make their regions more productive and more prosperous. There is no doubt that the majority of staff in those institutions see their success as bound up with the life chances an education offers their students. The challenge is that the way higher education is configured gets in the way of providing an education which more clearly meets regional and national economic priorities.

Higher education providers hold significant knowledge and experience that could be deployed in the service of policymaking. The vast majority in our experience are committed to enhancing their impact on lives, communities and the world. But the reality is that at times of financial pressure their ability to surface and apply their knowledge and filter changes through their organisation will depend on the ability they have to do so. While many are in the process of transforming their operating models, there is still a significant degree of exposure to shifts in international recruitment. And the administration of regulatory requirements, data collection and return, portfolio management, student registration and timetabling, and statutory duties on things like equality and freedom of speech are very hard to streamline to the degree that it makes a significant difference to the bottom line.

For these reasons, effecting change requires the government to set out an agenda and priorities for higher education, and the policy to back it up. But that agenda will be much more powerful if it is framed as a process of co-development and co-learning, driven by engaged communities and public stakeholders as much as by government or by providers themselves. Higher education providers do not exist in a vacuum. There needs to be a new settlement that aspires to the inclusion of multiple types of provision, qualification, institution, and student, ambitious for economic growth and regeneration, and that builds collective shared accountability for delivering it.

References

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Department for Education, Labour market and skills projections 2020 to 2035.

Department for Education, Review of post-18 education and funding independent panel report, May 2019.

Department for Education, Skills England: driving growth and widening opportunities, September 2024.

Katherine Hill, Matthew Padley & Josh Freeman, A minimum income standard for students, HEPI, May 2024.

Tristram Hooley, “A mixed bag: employer perspectives on graduates skills” Prospects Luminate, March 2021.

Institute for Fiscal Studies, The Conservatives and the economy, June 2024.

Shitij Kapur, UK universities: from a triangle of sadness to a brighter future, King’s Policy Institute, November 2023

Mark Leach, “It’s time to take a closer look at an ‘opaque corner’ of higher education,” Wonkhe, June 2023.

Office for Students, Improving opportunity and choice for mature students, May 2021.

ONS Local, Employed graduates in non-graduate roles in parts of the UK 2021 to 2022, August 2023.

Public First Public attitudes to tuition fees, October 2023.

Rachel Reeves, A new business model for Britain, Labour Together, May 2023.

Rachel Reeves, Mais lecture, March 2024.

James Robson et al. From competition to coordination: rethinking post-16 education and training in the UK. Industry case studies, SKOPE and the Education Policy Institute, April 2025.

Universities UK, President’s address to conference, September 2024.

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Michael White, “No retreat on student fees, Blair warns,” The Guardian, December 2003.

David Willets, How to do industrial strategy: a guide for practitioners, Resolution Foundation, April 2025.

Xiaowei Xu, The changing geography of jobs, Institute for Fiscal Studies, November 2023.

Acknowledgments

The authors would like to thank the following for their contributions to this paper

Professor Andy Westwood
Jess Lister
Mark Leach

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THE AUTHORS

Dr Debbie McVitty
Fellow
Debbie McVitty is Editor of Wonkhe and an honorary fellow of the School of Education at the University of Birmingham. Debbie is a former chief of staff at Universities UK, director of policy at the University of Bedfordshire, and head of policy at the National Union of Students.
James Coe
Fellow
James is a senior partner at Counterculture LLP and Associate Editor for R&D at Wonkhe. James is the former Head of Sustainability, Policy and Civic Engagement and senior policy advisor at the University of Liverpool, the author of a book on the future of universities, and he is an advisor to organisations and people that want to make their places better
Jonathan Simons
Fellow
Jonathan Simons is a Partner at Public First and Head of the Education Practice. Jonathan has spent the last twenty years advising government and external organisations on strategy, communications and public policy. Jonathan has also worked as Director of Policy & Research at the Varkey Foundation, Director of Strategy and Market Development at Serco, Head of Education in the Prime Minister’s Strategy Unit, when Gordon Brown was Prime Minister, and also Head of Education at the Policy Exchange think tank.

Introducing The Post-18 Project: Why the time is right for new thinking in post-18 education

In our launch essay, we explain how The Post-18 Project will provide practical policy ideas and solutions to the current government in Westminster, and build capacity in education to influence policy

Date:
19 May 2025
Authors:
Mark Leach MBE, Dr Debbie McVitty
Image: Ikon

Education, and opportunity, cannot and must not be considered merely as goods for individuals. The opportunity that education offers is not simply about the citizens of tomorrow, but the society, communities, companies and country of tomorrow. The vision we must have of how we deliver education – not just higher education, but every level and every stage, from our youngest children through their early years and into schools, onto colleges and universities and crucially all our lives long, that must speak to a broader vision of the society we should build.

– Bridget Phillipson speech to Universities UK conference, September 2023

The war against universities will stop if there is a Labour government.

– Peter Kyle speaking at Keele University, June 2024

01

The big pivot

It seems hard to remember now, but when Labour came into power in July 2024, there was a distinct mood of optimism in the air – at least in many policy circles.

On taking office, the policy objectives of the new government for higher education remained high-level. There was mood music on regional coordination between further and higher education, endorsement of the principles of quality and access, and a genuine understanding that the financial challenges facing the sector would need to be addressed in some way or another.

A key pledge to the sector was that higher education would no longer be treated as a political football but instead as a partner in delivering the government’s missions on opportunity and economic growth. Though few underestimated the scale of the fiscal and economic challenge facing Labour, the general belief was that this was a government that would welcome a grown-up conversation about how the government and the higher education sector could work together for the greater good.

But something important has failed to gel between higher education and government. This is a wider problem for all those connected to the post-18 education system, which could have serious ramifications for the quality of policymaking for the rest of this parliament and beyond.

The decision to allow undergraduate tuition fees to rise by inflation, with a door left open for future increases, has shown that the policymaking hasn’t all been one-way traffic. But the list of expectations that could be termed the quo for Labour’s quid is starting to get longer – a new accountability mechanism for vice-chancellor pay tied to graduate outcomes; a levy on international student recruitment; the promise of new powers for the Office for Students to protect public money driven by evidence of fraud in the franchising system. A fuller policy agenda is expected later this summer as part of the post-16 white paper incorporating a plan for HE reform.

The tone the government seems to be planning to take has been signalled by Minister for Skills Jacqui Smith writing in The Telegraph in early May that higher education has forgotten its core purpose to serve society, adding that universities “seem to have lost sight of their responsibility to protect public money.”

While it’s reasonable for government to approach all public spending with a close degree of scrutiny, this is an unusually punchy statement from a minister. The scepticism seems, however, not to be about the inherent value of a highly educated workforce and citizenry, but about whether institutions can deliver against a tightly defined mission and set of national priorities, as the responsible stewards of public money that the government expects them to be. It’s been a long time since we could assume that the government saw higher education growth as an automatic social good – accountability for the delivery of education beyond 18 in the context of the stated national priorities is now the underlying driving force, and if not careful, institutions are going to find themselves pivoting around this axis in an uncontrolled way.

02

The charge sheet

It’s easy to criticise ministers for a failure to appreciate all the complexity of the work that goes on inside the education system, but a review of the charge sheet throws up some real and significant challenges that need to be tackled. Access and opportunity are stalling, the graduate premium is highly variable across subjects and regions, signalling a real challenge in the deployment of graduate-level skills to drive productivity, and there is a structural problem in deploying international recruitment as a panacea for financial pressure on teaching and research budgets.

Not only that, there is actual fraud in the franchise system, not to mention some very legitimate questions about quality. And we’re pretty confident that there isn’t enough diversity of provision to meet the needs of the future economy and achieve regional growth, fuelled by a deeply conservative cultural hierarchy of providers that pushes against the development of a healthy and diverse ecosystem of post-18 provision.

While the sector might have a case to answer on these charges, it is far from being solely responsible for these issues, and it certainly can’t solve any of them alone. Nor can all of these issues be solved from Whitehall. Neither of these statements should be controversial.

The way the sector has been imagined as a regulated quasi-market in the last decade-odd of higher education policy has not enabled the sort of innovation and transformation higher education institutions are now expected to pursue. There remains no consensus about what an alternative paradigm might be, but for it to work, it will need to arise from a constructive accommodation between providers and government, rather than solely from one or the other.

Education and research, the human capital and innovation that higher education produces, are among the very few drivers that the government has to achieve its growth ambitions. And the vast majority of people who work and study in the post-18 system are doing so because they care enormously about the various ways that knowledge can be deployed in the service of society. The claim that somehow they must all have collectively lost their grip on their sense of social responsibility is a misreading of their values, motivations and intentions.

The national conversation doesn’t have to look like this. A country and a government at ease with itself should depend on a thriving, diverse post-18 sector that is simultaneously woven into the fabric of regional economies and civic life, and a global powerhouse of ideas and impact. Different sorts of institutions and providers should not be pitted against each other: great education, research and societal impact can happen in the smallest FE college and the most famous university. A post-18 sector that has a functional relationship with government should be a trusted interlocutor on policy challenges and the experiences and concerns of citizens and communities.

Government and the post-18 sector should share the pursuit of the common good, and each should be prepared to show the leadership, creativity and political acumen to make that abstract concept real in people’s everyday life.

03

Enter The Post-18 Project

We have more than ten years’ experience of building Wonkhe from a blogging site for HE policy nerds into the higher education sector’s primary source of analysis, intelligence and debate about higher education in all its facets. And we’ve no intention of stopping bringing the daily insight and up-to-the-minute analysis you expect from it. But we also think there is room for a different kind of policy insight, more thoughtful and reflective, and designed explicitly for influencing and shaping policy in this parliament rather than just commenting on it in real time. If there is no longer a need for the project after the end of this parliament, then perhaps we’ll wind it down – but we’re here because we believe that it’s needed now.

We’ve created The Post-18 Project to offer a space to policymakers and those working in post-18 education to develop ideas for how the government can work together with the post-18 sector to achieve its mission to build a better country: giving people educational opportunities they have reason to value, tackling inequitable patterns of economic growth; restoring confidence in public services and ultimately in the institutions of government and civil society.

The post-18 sector is not short of ideas and expertise, but it can struggle to turn those insights into concrete policy recommendations that can command widespread support. We want to mobilise the right combination of evidence and innovative thinking – or find where the gaps are – to tackle the policy questions that are too intransigent and wide-ranging for any single mission group or representative body in post-18 education to answer. With that in mind, we have also decided to be institutionally agnostic, and will not seek to promote one sort of provider over another. We approach the system as it is in front of us, and what we believe the future should look like; rather than looking back to the past.

We have intentionally convened a powerhouse advisory board from across the full breadth of types of post-18 providers, industry and policy. We’ll be relying on them to help keep us accountable for how we develop a policy space that draws on the enormous range of experience and knowledge that the sector has to offer, while staying true to the principle that to work constructively with this government and align around its priorities, there will need to be some real change.

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Our programme of work

The government has been clear that its core missions are economic growth and opportunity, but has not yet configured higher education’s role in either of these.

On growth, we know that a key policy instrument to drive that growth will be industrial strategy. Post-18 providers will need to rise to the challenge of evidencing that they are guided to some degree by broader national and regional economic growth plans, whether in developing education provision that aligns with the changing labour market and skills needs, by intensifying innovation and knowledge exchange activity in core areas of alignment to industrial strategy, or by housing expertise on their regional economies and labour markets to inform growth agendas.

While any post-18 provider could point to activity in at least one of these areas, it’s clear that there is an expectation that this should be much more coordinated and strategic, and more accountable to regional stakeholders and the public.

On educational opportunity, we can see a route ahead both in terms of reimagining the “traditional” student experience to offer something a great deal more flexible and inclusive, but also to incorporate a greater diversity of pathways into and through post-18 education. Post-18 opportunities need to directly meet the needs of prospective students for options that mesh with their lives and aspirations, and that continue to equip individuals with the knowledge and skills they need to thrive not only immediately post-graduation, but throughout their careers. Successive attempts to set up “alternatives” to the traditional full-time degree higher education route in the form of higher technical qualifications at levels 4 & 5 and degree apprenticeships have not yet been sufficiently scalable to answer the policy question of how to expand higher education opportunity without simply replicating the culturally dominant model.

In the weeks and months ahead, we’re intending to publish new evidence and insight, incorporating solid recommendations for government and providers, all aimed at fostering a more constructive national policy conversation. Our three core themes are:

Higher education for the common good – exploring what a policy framework looks like that can maximise the public value of post-18 provision to the UK

The post-18 experience – what prospective and current students need from their education experiences and how to achieve scalable diversity of provision and pathways

Universities and colleges in a changing world – the global dimension of post-18 education and how it interacts with the UK’s position and influence in the world

Within these themes, we’ll be tackling questions like:

How can post-18 providers do more to drive economic growth through skills, R&D and innovation? 

What would a radical new vision for the full-time student experience include? 

What does post-18 education really cost, and why? 

How can the franchising system be brought back into line? 

What does the next generation of students want the post-18 options landscape to look like? 

What does the country and government need from post-18 institutional leaders? 

How does post-18 education enable public sector reform? 

Do we need another HERA? 

If the era of globalisation is over, how do global post-18 providers reconfigure their ambitions?

We hope through this work to contribute to building a new kind of policy agenda – one that is neither entirely top-down from the state, nor left to the vagaries of “market choice” but one grounded in a shared mission of public service, that builds in mechanisms for co-design and co-delivery from the outset, and in doing so establishes a new civic compact between the state, post-18 education providers, and the public.

We’ll build on many of these themes at The Festival of Higher Education this November (early bird tickets already on sale), and use the festival as a huge, live opportunity for engagement and input from the incredible community of experts in and around the sector who we believe can help provide many of the answers to these challenges facing us all.

We hope you’ll join us on the journey as The Post-18 Project takes flight.

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THE AUTHORS

Mark Leach MBE
Founder & Chair
Mark Leach is the founder and Chair of The Post-18 Project. Mark is also Editor in Chief of Wonkhe – home of the higher education debate – a platform he founded in 2014 after the first part of his career in higher education policy and as a Labour adviser. Mark was appointed MBE for services to higher education in the King’s Birthday Honours in 2023.
Dr Debbie McVitty
Fellow
Debbie McVitty is Editor of Wonkhe and an honorary fellow of the School of Education at the University of Birmingham. Debbie is a former chief of staff at Universities UK, director of policy at the University of Bedfordshire, and head of policy at the National Union of Students.

Returning for its third year at The University of London, The Festival of Higher Education is taking place across 11-12 November 2025. The festival is always an opportunity to look beyond the narrow confines of higher education policymaking, that will be the case more than ever this year as we bring together the wider national conversation about the future of post-18 education in the UK. Early bird tickets are now on sale.

Find out more and book your tickets now