The top line

Britain is likely soon to have a Prime Minister whose governing philosophy – Manchesterism – suggests that policy on skills, education, and economic development should have a much stronger local dimension. But no part of Whitehall is currently configured to deliver this. The post-18 education system, the principal mechanism through which skills, research, and productivity growth are developed, is fragmented across three departments in a configuration no other comparable democracy has adopted. A Prime Minister committed to Manchesterism will need to build the tools he requires, because they do not yet exist.

The context

Manchesterism is more than devolution by another name. It operates on three layers: a pragmatic programme of public investment and local control; an institutional theory that devolution is the structural precondition for functional governance; and a moral claim about where legitimate political authority comes from. Andy Burnham’s direct experience of the frustrations of the current system – particularly the resistance of the Department for Education to sharing powers over skills – makes the post-18 education system central to any Manchesterist programme.

What the paper finds

The English post-18 system is fractured across the Department for Education, the Department for Science, Innovation, and Technology, and the Department for Work and Pensions. It has two junior ministers, both peers, both answering to two different secretaries of state, but with no formal relation to each other. No other G7 country or EU member state, including the other UK nations, runs things this way.

The current arrangement has never been adequately theorised or explained by any Westminster government. It is not so much a model as a mistake.

Bringing those functions back together is an essential starting point for a department to deliver Manchesterism but both DWP and DfE have broad portfolios and centralising tendencies. Neither is a suitable base for such a department.

What the paper proposes

A new Department for Skills, Research, and Prosperity, built on the DSIT base, should reunite all post-18 education functions – higher education teaching and research, further education, adult skills and apprenticeships – and absorb the industrial strategy from the Department for Business and Trade. Unlike its predecessors in BIS and BEIS, which became bloated by the addition of company law, business regulation, and consumer affairs, DSRP would be built from its first day with a presumption in favour of local decision-making: local where possible, national where necessary.

The paper also distinguishes DSRP’s role from that of MHCLG, which should retain responsibility for the legislative framework of devolution, and from the Treasury, which DSRP should complement rather than rival.

The bottom line

Manchesterism has a genuine diagnosis of what ails Britain, seeks to build broad-based prosperity to treat that illness, and  is clear enhancing agency in local communities is a key requirement for that. 

But a philosophy is not a programme until it has institutional form. Without a department built for the purpose, the structural incoherence that has frustrated a decade of skills reform and a decade of devolution will simply continue – and the next government will inherit the same problems as every government before it.

How this paper connects to other work from The Post-18 Project

This paper draws on The Post-18 Project’s longer-term work to reform and improve the whole post-18 education system in England, including:

• Blood, Debt, Toil, and Arrears diagnosed the dysfunction of the whole post-18 system, arguing that none of the fourteen factors necessary for a coherent education system are being properly managed – the proposals in this paper would begin to address that structural failure. 
• Tooling Up examined the attempts by Keir Starmer’s government to tackle the problem of weak skills development, and its analysis of why those attempts fell short is directly relevant to the case made here for a differently configured department. 
• Marking The Course dealt specifically with the recommendations in the post-16 White Paper, many of which remain relevant to the issues discussed here, and, as yet, have not been operationalised by any government department, either through legislation or direct executive action. 
• A forthcoming paper will address the student loan accounting framework, which presents a further structural obstacle to the reform likely to be pursued by the department proposed here.

Every government in the past decade has explicitly set out to expand non-degree aspects of post-18 education. The aim has been consistent: better match students’ qualifications to the needs of the labour market, and through a more highly skilled workforce, drive increased economic growth.

Across that same decade, every government has also experimented with devolution, creating new local and regional administrative units expected to build more efficient and effective policy, precisely because it is designed and implemented closer to the people it serves.

Neither of these approaches has been fully successful, and Britain is likely soon to have a Prime Minister with direct experience of the frustrations of both.

Andy Burnham has served as Mayor of Greater Manchester, perhaps the most mature of all the English devolution projects, throughout this period. He is now set to take control of the country, guided by “Manchesterism”, a term which describes not so much an ideology as a disposition towards governing, in which both the post-18 educational challenge and the hyper-centralising yet intervention-averse tendencies of the British state play central roles.

Right now, Burnham will find no government department properly set up to deliver Manchesterism. The tools for supporting and enhancing the skills-driven growth he seeks, through direct government action in which local and regional power are prioritised, are dispersed across Whitehall, and there is little reason to believe that any of the major ministries are ready and able to make genuine place-based policy their driving principle.

Burnham will need to build the tools he requires to make Manchesterism a mover of government priorities, and this paper suggests how he might do that.

Two brute facts provide both the context for Manchesterism and its greatest challenges:

1. Britain has experienced a lost decade in living standards growth 
2. Britain is the most centralised large democracy in the world.

Labour won in 2024 on a prospectus of driving improved living standards and declared economic growth its “defining mission”. Instead, it has delivered anaemic growth, indistinguishable from the trend it inherited, and significantly adrift of comparator nations.

There are many plausible explanations for why Britain is such an outlier amongst G7 countries in its per capita growth, but one obvious distinction is that the British state is tightly run from the centre. Formal devolution to Scotland, Wales, and Northern Ireland is inconsistent – none of those three countries has the same set of powers in relation to Westminster. Within England, while some areas of the country have received greater local authority, this has been very diffuse by geography and level of power. The current Labour government has moved money and authority to regional mayors, but as Burnham himself has complained, this has been at the discretion of Whitehall, not by right.

Burnham says that Manchesterism is “not a slogan, but a system”: a practical not theoretical framing, which considers relative economic weakness a consequence of an over-mighty central state. But Burnham’s approach is more than pragmatic municipalism, or “just” devolution by another name – it carries a specific account of what devolved power should be used for. 

Although he resists significant theorisation, Burnham’s public statements suggest that manifesting political power in localities is not only better at achieving social progress, but also essential for ensuring people feel empowered. He has explicitly argued that when national policies dismantled industries, the knock-on destruction of communities without adequate support or reinvestment was not merely problematic, because its effects were undesirable, but unjust, because as well as inflicting bad outcomes on people, this mode of doing policy denied agency to localities to determine their own futures. 

Local politicians, Manchesterism suggests, are closer to both the specifics of the challenges in their regions and better placed to convene the relevant stakeholders and drive the change required. When Burnham says “place first,” he means something more than an organising principle for departmental responsibilities – it is a claim about where legitimate political authority comes from.

In essence, then, Manchesterism has three layers. The surface is a pragmatic programme – buses, skills, clusters. The middle layer is institutional theory – devolution as the structural precondition for functional governance. The deepest layer is a moral claim about the proper relationship between economic power, political authority, and place. In some ways, Manchesterism might be better defined by the term “prosperity” than by the concept of “economic growth” – the second may be a pre-condition for the first, but the improvement of human dignity and welfare is the objective, economic growth the tool, and that tool far more managed than prevailing policy instruments have attempted.

That moral commitment matters for what follows: no department in Whitehall currently can serve Manchesterism properly. Devolution is not alien to England’s central government, else Burnham would never have had the chance to be Manchester Mayor at all. Yet because the centralising logic of the Whitehall machine is so strong, no current government department has the presumption to release power to the regions built into its DNA, not even the Ministry of Housing, Community and Local Government – in its various guises under both Labour and Tory, it has overseen more powers passing to regional mayors, yes, but has also driven through significant consolidation of local government units across the country.

And precisely because the British government is so centralised, a Prime Minister committed to Manchesterism will need to build Whitehall tools capable of making a reality of his aspirations.

The post-18 education system is central to these challenges. Higher and further education have always been seen as crucial to any growth mission, and under Labour, Coalition, and Conservative governments, these policy areas were bound to local and regional economic planning from 2009 to 2016. Burnham himself has explicitly named the Department for Education as the source of his greatest frustrations as Greater Manchester Mayor, resisting sharing powers over the skills system when Burnham felt it was both essential and proper that those decisions be made locally.

Burnham’s direct experience of these frustrations is weighted toward skills and further education – the policy areas where he had, or sought, devolved levers. He has been notably quieter on higher education, although this is clearly not from a lack of interest – that Greater Manchester should be the most mature tertiary system is no accident, and Burnham’s direct and personal engagement with, and convening of, leaders of both universities and FE colleges in Manchester has been a significant driver of, for example, the Atom Valley project or the establishment of Greater Manchester’s Institute for Technology. Bringing universities and research fully into the Manchesterist framework – recognising them as place-based institutions with a role in regional prosperity, not just national prestige – is the work this paper seeks to advance.

Creating both a more level and more local playing-field for institutions engaged in post-18 education does not pre-suppose that all such institutions are necessarily only, or even mainly, focussed on the locality. The University of Manchester, for example, has not lost its international outlook by virtue of the creation of the GMCA, nor its place as a nationally-significant host of cutting-edge research. What could change is that decisions about what provision is required in a locality, and the processes of working with local post-18 institutions to deliver that provision, move closer to the people served, the better to understand their needs and work together to resolve challenges. 

Improving the interplay between the provision of higher learning, whether academic, technical, or vocational, and the skills needs of the economy will not automatically generate prosperity, but it is impossible to imagine it occurring without that shift. Manchesterism sees that interplay being mediated at the local level, with a strong bent toward co-operation between different local and regional actors. For such eco-systems to properly endure and flourish, the ultimate arbiter for determining the success or otherwise of relevant initiatives, and therefore determining who will receive funding for these, must be fundamentally local. 

This last is not simply about allowing local politicians to spend money currently reserved to the centre, it is as much about reducing the pressure on the centre of resolving the arguments which will inevitably arise. We should not expect Manchesterism to end what are inevitable conflicts between different institutions seeking to serve some of the same students with similar education tools, especially in the context of the likely shrinking population of students the English system is facing. But instead of, at present, committees convened somewhere in and between the DfE, DSIT, and the DWP being expected to determine whether one or more FE and HE institutions within a given area are more-or-less likely to successfully respond to the needs of the locality, those decisions are made locally, owned locally, defended locally.  

It therefore seems both likely and sensible that a Manchesterist PM will want to review the oversight of the post-18 education system by the government. What they will discover is that those responsible for government oversight and leadership of post-18 education are actively hampered in doing so by the way the English state has wired those responsibilities.

How the English post-18 system is currently organised

The post-18 system can be thought of as making three crucial contributions to the prosperity agenda: developing students’ agency over their own lives, most especially through teaching powerful knowledge; allowing students to improve their career prospects through increased social, cultural, and personal capacity and well-devised technical skills training, both before and during their working lives; and generating improvement and innovation within the economy by fostering high quality research.

These three functions are not divided neatly between institutions: both further education colleges and higher education providers deliver teaching focussed on academic disciplinary knowledge and specific technical skills, although the proportions vary between sectors and between institutions within each sector. In general, research is undertaken only in universities, and not even in all of those.

Nor are the distinctions between these functions as clean as administrative arrangements suppose. The concept of “skills” often pre-supposes that these can be trained for in a vocational setting, separate from the disciplinary knowledge more commonly associated with university lecturing. In reality, skills are manifestations of knowledge, and knowledge is enhanced by practising skills. Research and teaching, especially at higher levels of study, are tightly bound together: those studying for degrees or other higher qualifications often, rightly, expect that what is being recently discovered in their fields of study should feature in their learning.

This is the context for the decisions taken over the past decade to divide the post-18 brief in ways not previously undertaken.

The current government divided further education in half, with FE colleges remaining in DfE, but adult skills moving to the Department for Work and Pensions (DWP). In theory, that represents a fusion of strategic skills planning with job readiness for the unemployed, but this has yet to yield either practical policy change or new legislation, and although Skills England moved, responsibility for the implementation of the Lifelong Learning Entitlement, through which much future training might be funded, has remained with DfE. A single minister, Baroness Smith, holds both these portfolios, answering to a different Secretary of State for each, but Smith is also the only DfE minister in the Lords, and therefore responsible for all DfE business in that chamber, which has included several lengthy stints guiding non-FE or HE-related legislation. She is also the Minister for Women and Equalities, with additional responsibilities from that role.

DfE has retained responsibility for all teaching in higher education, but research has been the province of another department since 2016, and while a bridging minister held both portfolios for a time, this ceased in 2020. The minister with responsibility for research now still bridges two departments, but it is Lord Vallance, who serves both in DSIT and the Department for Energy Security and Net Zero, and has no formal relationship with the other aspects of post-18 at all.

This lack of coherence is rare when compared to previous English arrangements, and unique internationally. Fuller comparisons are drawn in the appendices, but the key point is this: if post-18 education is a lynchpin of any strategy directed towards prosperity, then some reorganisation of government machinery is essential for delivering on the PM’s ambitions.

International comparisons

Not only is the current post-18 ministerial set-up in England anomalous by the standards of our own system, it is unique when compared with those used in other constitutional democracies of the G7 and the EU. Looking around the world, it is possible to classify three different models for government oversight of post-18 education:

• Model 1: A dedicated post-18 department, with FE, HE, research, adult skills and apprenticeships in a single department, separated from schools, led by a Cabinet-equivalent minister.
• Model 2: A dedicated post-18 minister within a broader education ministry; in some cases, with Cabinet status for that minister.
• Model 3: A higher education, science and research ministry, distinct from FE, adult skills, and vocational training, which generally, although not always, sit with schools.

In addition, several comparator systems have either formal federal arrangements or long-standing conventions which divide responsibilities between national and regional or local government.

Two features are universal across all three models. First, higher education research is always administered alongside higher education teaching – no comparator nation separates the two into different departments. Second, further education and skills are always kept together – no comparator nation splits FE colleges from adult skills and apprenticeships.

England currently has neither feature. HE teaching is in DfE, HE research is in DSIT, and the further education system is divided between DfE (colleges) and DWP (adult skills and apprenticeships). Of comparator nations, only Australia shares the education department versus employment department split for post-18 functions, but even Australia does not also divide the HE portfolio: schools and HE sit in one department, and FE and skills in another. A fuller comparison of international arrangements is at Appendix B.

What international comparisons suggest is that, while it is possible and often useful to distinguish between adult skills, higher technical education, academic qualifications, and research and development when discussing specific policy initiatives, the lived experience of students, staff, and administrators of these functions is that all post-18 institutions, everywhere in the world, engage in several of those activities simultaneously. Given the current English position has never been adequately theorised or explained by any government, there is no reason to suppose we are consciously proposing a fourth model others could follow. 

Ultimately, that no other comparable democracy has chosen to organise their post-18 oversight in this way suggests that it is not so much a model as a mistake. Certainly, it seems likely that it will hamper any attempt to build a more effective prosperity engine powered by high quality skill provision and research excellence. 

A PM looking for an appropriate vehicle for driving Manchesterism through Whitehall might consider a new department an additional encumbrance when what is needed is simply more devolution.

But the irony is that delivering devolution requires a central tool. The forty-year process of denuding local government of both money and functions means that the local state cannot absorb new responsibilities without a coherent national framework and appropriate support.

So a new central department will be necessary, and this department ought to be governed by three clear principles:

1. “Local where possible, national where necessary.” Instead of the present situation in Whitehall where every decision to devolve something must be justified against a status quo of central control, the calculus should be reversed: where decisions about matters covered by the department can be made locally, they should be, and justification is required to pull a decision back towards the centre.
2. “Collaborative by design.” This must not be a department for the wholesale outsourcing of central government problems to local government, telling them to get on with it without support – such methods are too reminiscent of the Coalition’s handling of austerity. While local decision-making should be preferred, the department should foster imaginative forms of collaboration, in form ranging from full transfer of functions to the regions, through properly accountable local and national partnerships, to simply improved communications between regions and the centre on implementation.
3. “Accountability comes with authority.” In determining how issues should be collaborated on with localities, the department should be mindful of not simply handing over the responsibility for the outcomes of a policy, but also the funding and decision-making necessary for a locality to take meaningful decisions.

A radically different approach to engagement with local government is likely to require a department built quite differently from many in Whitehall. Neither of the two largest current post-18 departments, DfE and DWP, is a suitable starting point. Both are very large departments — DWP is one of the two largest in Whitehall by staff, and DfE is one of the largest by budget. Both are also highly centralised. Both are also highly centralised, with other fundamental functions – benefits payments, schools and children’s welfare – which are only made more complicated by the addition of responsibility for a regionally-driven prosperity agenda.

DSIT has fewer of these problems. It is a newer department, only created in 2023, and without other enormous priority areas to manage, it is a prime candidate as the core of a prosperity-focused ministry. That ministry should carry a name that manifests directly its purpose, Prosperity, and the tools by which it is to be achieved, the enhancement and application of Skills and Research.

The Department for Skills, Research, and Prosperity

The DSRP would reunite the post-18 contributions – knowledge, skills, and research – that have been progressively separated since the dismantling of BIS, but unlike its predecessors, it would be built from the outset with a presumption in favour of local decision-making.

It should take nearly all of DSIT’s current responsibilities, recombine higher education research funding with responsibility for higher education teaching, also bringing over from DfE responsibility for further education colleges, and recombining that with adult skills and apprenticeships, which should leave DWP. 

This would create, for the first time since 2016, a single coherent post-18 department, with significant scope to influence both adult and young people’s education and training. It would also allow the new department to address a particular challenge flagged by Andy Burnham, of the creation of arms-length agencies which cut across rather than working with devolved bodies. Under this scheme, a single department would sponsor UKRI and the research councils, the Office for Students, and Skills England, providing a platform for significant change in how these bodies interact with each other, post-18 education institutions and stakeholders, and of course local and regional government.

The department should also take responsibility for the Industrial Strategy, currently with the Department for Business and Trade, giving it specific levers for initiating and co-ordinating activity in the regions and localities.

Previous governments built something similar to this, in BIS and BEIS, but those created overly-large departments by including company law, business regulation and support, consumer affairs and employment relations. Instead, those functions should be transferred to DWP to create a Department for Employment and Enterprise, charged to work on both sides of the employer-employee relationship. The idea that DWP ought to have a more coherent role in shaping policy to encourage prosperity, which underlay the movement of skills into DWP, was not entirely wrong-headed – the wrong aspects were combined.

The two departments whose functions are most complementary to DSRP’s are the Ministry of Housing, Communities and Local Government, and the Treasury, and their respective roles need to be clearly differentiated.

Designing the legal nature of devolution and determining the specific policy objectives which ought to be achieved through it are not the same. Someone will need to keep thinking about how, both legislatively and practically, authority is shared out better between the centre and localities, and hold the ring in the inevitable tensions which will arise at the margins, and MHCLG should retain responsibility for directly managing the legislative framework for central government relations with local authorities. 

This ensures government is not creating a department that is marking its own homework when it comes to how successful any given devolved project is. DSRP should be the department that designs devolved skills and research policy; MHCLG should remain the department that brokers the devolution framework. This is especially important as the process of devolution in England is so uneven: no two “devo-deals” are entirely alike, and much of the country does not have the sort of strategic authority Manchester has, nor are their geographies necessarily favourable for the creation of these. Separating MHCLG and DRSP keeps both the mechanisms and objectives of devolution as the primary functions of two different departments, which is exactly the dynamic a Manchesterist PM would want.

As for the Treasury: as Appendix C discusses, there is a case for a more radical restructuring that would see growth-focused spending functions detached from HMT and placed in a new ministry. The lesson from Harold Wilson’s Department of Economic Affairs, however, is that the way to change the Treasury’s behaviour is to complement it, not rival it. DSRP complements the Treasury by building productive capacity – through skills, research, and regional economic development – that fiscal management alone cannot generate. It does not need the Treasury’s powers; it needs to be the department that gives the Treasury something worth funding.

Manchesterism is a serious governing philosophy with a genuine diagnosis of what ails Britain: that the most centralised large democracy in the world is also one of the worst-performing, and that reconnecting economic power to the places where people actually live and work is a precondition for reversing that decline.

But a philosophy is not a programme until it has institutional form, and at present no part of Whitehall is configured to deliver what Burnham is proposing. The post-18 education system – the principal mechanism through which skills, research, and productivity growth are developed – is fragmented across three departments in a configuration no other comparable democracy has adopted.

A Department for Skills, Research, and Prosperity, built on the DSIT base, absorbing all post-18 education functions and the industrial strategy, and governed from its first day by a presumption in favour of local decision-making, would give Manchesterism the Whitehall tool it currently lacks.

It would not, by itself, deliver prosperity.

But without it, or something very like it, the structural incoherence that has frustrated a decade of skills reform and a decade of devolution will simply continue – and the next government will inherit the same problems as every government before it.

England’s post-18 education system is currently distributed across three departments:

Department for Education (DfE) is responsible for a series of portfolios broadly related to teaching and qualifications provided by FE, HE, and other training providers. DfE is directly responsible for the roughly 230 FE colleges, following their reclassification into the public sector in 2022. DfE is also the sponsoring department for the Office for Students, the regulator for higher education; Ofsted, which inspects FE and teacher training and apprenticeships in HE; the Further Education Commissioner’s office; the Student Loans Company, which administers the student fee and living costs loans system; and Ofqual, which regulates qualifications offered by both FE and other training providers. DfE also administers the Strategic Priorities Grant, the last remaining significant injection of direct cash from government into the teaching side of HE, and is the lead department on the introduction of the Lifelong Learning Entitlement. DfE is also responsible for the state school system, early years, and child safeguarding.

Department for Science, Innovation and Technology (DSIT) is responsible for research infrastructure and spending, overseeing approximately £14bn per year, of which around £8.8bn is moved through UKRI, for which DSIT is the sponsoring department.

Department for Work and Pensions (DWP) has, since 2025, been responsible for a broad “skills” agenda, operationalised through the Growth and Skills Levy (the replacement for the Apprenticeship Levy), the Adult Skills Fund, careers policy and aspects of FE covering adults, defined here as those over 20. At the same time as acquiring these responsibilities, DWP also became the sponsoring department for Skills England, the arms-length strategic body for identifying and addressing skills gaps, in addition to its previous responsibilities, including Jobcentre Plus, Universal Credit and reducing economic inactivity.

Aside from this triumvirate, the Department for Business and Trade is responsible for the industrial strategy, which shapes decisions about the adult skills system and other education systems; the Home Office administers the visa schemes, and through UKVI has direct regulatory impact on any institutions with international students; the Department for Health and Social Care is responsible for student medical services, as well as the NHS being the employer of a very significant number of graduates; and Treasury holds the loan book. Accommodation and transport sit elsewhere again, but are of central importance, given that student movement to HE is the largest internal migration Britain experiences, and it happens every year.

Comparator nations organise government oversight of post-18 education in three broad models. The following survey covers G7 and EU member states and the devolved UK nations.

Model 1: A dedicated post-18 department

Under this model, FE, HE, research, adult skills, and apprenticeships sit in a single department, separated from schools, led by a Cabinet-equivalent minister.

Ireland created the Department of Further and Higher Education, Research, Innovation and Science (DFHERIS) in August 2020, led by a full Cabinet minister – Simon Harris, who subsequently became Taoiseach. The department covers FE, HE, research, innovation, science, apprenticeships, and adult skills, with schools separate. A junior Minister of State handles the FE and skills sub-brief. DFHERIS has survived six years, multiple changes of government, and two changes of minister – it is now led by James Lawless TD, with Marian Harkin TD as Minister of State for further education, apprenticeships, construction and climate skills.

Northern Ireland takes a variant approach: HE, FE, skills, and research all sit in the Department for the Economy, bundled with the wider economy brief including energy, economic development, and consumer affairs. The Economy Minister sits in the Executive and is an elected MLA. The design principle is the same as Ireland’s – schools separate, everything post-school together – but housed in an economy department rather than a dedicated tertiary one.

This model offers maximum ministerial focus, no competition with the schools agenda, and preserves both the HE–research and FE–HE links while integrating skills with the institutions that deliver them. Its vulnerability is political: small departments can be absorbed, and England’s own version – DIUS – lasted only 23 months. The school-to-university pipeline also crosses a departmental boundary.

Model 2: A dedicated post-18 minister within a broader education ministry

Under this model, one ministry covers all education, but a dedicated minister – usually with Cabinet status – holds the post-18 brief.

The Nordic systems are the paradigm. Norway, Sweden, and Finland each have two ministers inside one Ministry of Education and Research, both attending Cabinet. The HE and research minister has a dedicated brief and an independent Cabinet voice. In Sweden, the minister’s title – Upper Secondary School, Higher Education and Research – explicitly bridges the 16–18 transition into HE, owning the last years of school alongside universities.

The Netherlands inverts England’s seniority allocation. The senior minister (currently Rianne Letschert, a former university president) handles HE, research, and culture. The junior State Secretary handles schools. England does the opposite – Phillipson (senior) does schools, Smith (junior) does HE.

Austria, Japan, and Portugal are single-minister variants where one Cabinet minister covers the whole education and research landscape, but Austria and Portugal are significantly smaller systems, while Japan compensates through strong bureaucratic infrastructure including a dedicated Higher Education Bureau.

Wales and Scotland both have junior ministers for HE and FE who lack Cabinet status, but both have created compensating statutory agencies: Wales through Medr, the Commission for Tertiary Education and Research created by the 2022 Act, which funds sixth forms, FE, HE, apprenticeships, and research in a single statutory body; Scotland through the Scottish Funding Council, recently given a wider, more integrated remit through legislation.

This model provides dedicated ministerial focus plus Cabinet access without the overhead of a separate department, keeps the school-to-university pipeline visible, and is less vulnerable to reshuffles. Its weakness is that Cabinet attendance for the dedicated minister is not guaranteed – in the UK system, PM-granted attendance can be withdrawn at the next reshuffle (Willetts had it, Clark didn’t, Donelan had it, Jenkyns didn’t). The political salience of schools also creates a permanent gravitational pull on the Secretary of State’s attention.

Model 3: A distinct higher education and research ministry, with FE and skills elsewhere

Under this model, HE and research sit together in a dedicated ministry, while FE, vocational training, and skills are administered separately, usually through labour, education, or regional government.

France has had a dedicated Ministry of Higher Education and Research in some form since 1974, surviving every political configuration from Giscard to Macron. The current minister is a full Cabinet member, with schools in a separate ministry. The HE and research side is administratively coherent, but vocational training is fragmented across labour, education, and regional government.

Italy has oscillated between combining and separating universities from schools. The dedicated Ministry of University and Research (MUR) dates in its current form from 2020 and has been maintained through the Draghi and Meloni governments. Spain briefly had a standalone Ministry of Universities from 2020 to 2023, but without research, it was widely criticised and remerged.

Most German Länder follow this model, with education and research ministries at Land level distinct from vocational training oversight. Ontario and Quebec also broadly fit the pattern.

This model provides maximum HE–research coherence and guaranteed Cabinet weight. Its weakness is that FE and vocational training become fragmented, the FE–HE boundary becomes a departmental boundary, and lifelong learning falls between stools.

The US exception

The United States operates within a different governance tradition entirely – board governance rather than ministerial governance – but even within that tradition, the trend is toward coordination and integration through coordinating boards and unified systems rather than fragmentation. The states that have fragmented postsecondary governance across multiple uncoordinated boards, such as California until recently, are the ones that have experienced the most severe coordination problems.

England’s position

Of these three models, England most closely resembles Model 2, with a single DfE and a dedicated junior minister. But the division of adult skills from other further education across two departments, combined with the separation of HE research oversight into DSIT, marks it out from every comparator. Of comparable nations, only Australia shares the split between an education department and an employment department for post-18 functions, but Australia does not also divide the HE portfolio: schools and HE sit in one department, FE and skills in another.

Two features are universal across all three models. Higher education research is always administered alongside higher education teaching. Further education and skills are always kept together. England currently violates both principles simultaneously.

This paper proposes a bold reformation of central government departments with responsibility for the different aspects of the post-18 education system, in order to properly design and deliver the policies needed to achieve the stated goals of the Labour government. The creation of a new Department for Skills, Research, and Prosperity balances the need for significant reform in ministerial oversight of the post-18 system and new approaches towards the role of local and regional government with the complexities of significant Whitehall re-organisation.

However, there are other possible combinations that could be considered, ranging from the minimal to the very dramatic. Below, we explore two possible ends of that spectrum, both to elucidate what other options exist, but also to suggest why the DSRP represents a good balance of boldness and pragmatism.

As an additional note, all these options recognise that DSIT’s current responsibilities for digital regulation and telecommunications policy are not natural fits for a prosperity-focused ministry and should transfer elsewhere, most logically to the Department for Culture, Media and Sport.

The minimal change option: a slightly smaller DfE and a slightly bigger DSIT

What about the other end of the scale – the smallest plausible change a PM minded to build a department for Manchesterism could consider? Minimal machinery-of-government changes would be required to move adult skills from DWP back to DfE, and to reduce DfE’s burden by reuniting higher education teaching responsibility with research oversight by giving DSIT all HE-related policy areas.

This would have significant benefits. The split between HE research funding and HE teaching funding is one not found in any other G7 or EU nation, and for good reason: although not every higher education institution is research-active, those that are profess a deep connection between their research and teaching work, and one of the foundational ideas of a university is that it is an academic community which communicates knowledge to others, but also creates and curates it.

Transferring adult further education and skills to DWP has yielded no significant benefits, and has rendered FE colleges answerable to two masters without any formal co-ordination arrangements. Reversing the split would be a commonsense acknowledgment that FE deserves a single directing mind.

This proposal would keep post-18 education split between two departments rather than three, on lines which are significantly more logical than at present and far more in keeping with G7 and EU comparators. It also involves only the three departments already directly concerned with post-18 education, and does not generate a wider ripple across government.

But the risk with small-scale changes is that they signal limited ambition. Even if rhetorical force can be deployed to change that impression, the government would still be relying on the same departmental tools which have failed to achieve the desired change under both Conservatives and Labour in the past decade.

The maximal option: a Ministry of Economic Growth

One of the specific explicit concerns raised by Andy Burnham about the Westminster governing model is the power of the Treasury, and in particular its role as a barrier to more radical action to invest for growth. There is historical precedent for a Labour PM seeking to circumscribe the Treasury through departmental creation: Harold Wilson and the Department of Economic Affairs in 1964. Moreover, since Manchesterism is a core principle of the new PM, and the delivery of economic growth and wider prosperity is both the avowed aim of the government as set out in the 2024 manifesto and an essential pre-requisite of its being re-elected at the end of this Parliament, a single mega-department committed to that aim might seem appropriate.

Such a department would absorb all the post-18 system functions discussed here from DfE, DWP, and DSIT, and would likely also encompass the whole of the Department for Business and Trade, bringing together industrial and commercial strategy with long-term skills planning. But, crucially, Burnham could go further and split the Treasury, adding its growth-focused spending teams, the tax policy functions relating to R&D credits, investment allowances and enterprise zones, the Green Book appraisal framework teams, and OBR liaison on growth forecasting. A new Ministry for Economic Growth, alongside a Treasury set firmly to the task of fiscal accounting, would be a powerful statement of the centrality of Manchesterism to the government’s identity.

However attractive such a bold move might be, it is not without serious problems. When Wilson tried this, the Treasury ultimately consumed the alternative economic ministry. Cynics might argue this is merely departmental empire-building, but the reality is that running investment spending separately from fiscal management is genuinely difficult. Investment decisions both enable and constrain fiscal ones, and while Burnham is a more assured politician than Liz Truss, the risk of triggering a rapid escalation in the costs of financing Britain’s debt through seemingly unrestrained spending is genuine.

The top line

English higher education is in crisis – but the crisis is not primarily financial, nor is it about AI, Brexit, or any single policy failure. The fundamental problem is that the relationship between the English state and higher education – what this paper terms the “HE/state nexus” – is broken. For thirty years, successive governments have attempted to manage the system through a single mechanism: student choice driving competition between providers. This mechanism has failed, by every metric its architects set for it, and its failure is structural, not incidental.

The diagnostic framework

This paper applies to higher education a diagnostic framework developed by Tim Oates for analysing school systems. The framework identifies fourteen control factors – including funding, accountability, curriculum, pedagogy, assessment, institutional forms, governance, and information and guidance – that must be managed in coherent alignment for any education system to succeed. Applied to higher education, the framework reveals that student choice was not one control factor among fourteen – it was a single mechanism substituted for the distinct management of at least five of them, while others were largely ignored. The result is a system that lacks not only coherence, but even a conceptualisation of the factors that would need to be aligned for it to work.

What the paper finds

The paper examines each control factor in turn. Its principal findings include:

• Funding has gone nowhere. Per-student funding has returned to its pre-Dearing level in real terms – approximately £10,000 – despite the entire purpose of the fee system being to increase it. The system that was supposed to insure higher education against Treasury penny-pinching actually put the sector at the mercy of government accountants.
• Student choice has not driven up teaching quality. By shifting the vast majority of university funding into the hands of the aggregate decisions of 17-year-olds, the English system of choice has become, more or less, an enormous machine for finding out who has the best (or best resourced) marketing department, with some world-leading research sprinkled in certain places.
• The price mechanism is broken. Every institution charges the maximum fee, every time, because the architecture of the system divorced the sticker price from the experienced cost. David Willetts insisted the £9,000 fee would apply only “in exceptional circumstances”; by 2014, all but two of 123 universities charged it for at least some courses.
• The system’s greatest claimed achievement – widened access – was not produced by the system. The demand for massification was already there; what the system was supposed to do was channel that demand into better outcomes. On that measure, the record is far weaker.
• Guidance has been systematically built up and torn down. AimHigher established 42 area partnerships and seven years of accumulated relationships, expertise, and trust with schools. It was abolished, with a three-year gap before anything replaced it. Its successors have been progressively defunded. Where public guidance has been defunded, the market has sent salespeople, not advisers.
• The franchise crisis was the system working as designed. When the only tool for managing institutional diversity is the market, the market produces the forms that maximise revenue, not the forms that maximise learning.
• The Office for Students (OfS) has been set an impossible task. It was told to be a market regulator in a system where the market does not function as a market: the price is fixed, the customer cannot easily switch provider, and the information asymmetries between institution and applicant are vast. Each new function added to its remit represents another turn of Achtenhagen’s “cycle of planned failure.”
• Pedagogy, curriculum, and professional development have been largely ignored. A world-leading researcher with no training in pedagogy can be put in front of 300 first-year students, and the system has no mechanism even to know this is happening, let alone to address it.
• Where the system does approach coherence, the results are genuinely world-leading… Research funding, governed by the Haldane principle and managed through expert-mediated accountability, has produced a system where UK research output is cited 54 per cent more than the global average. This provides the strongest evidence that another way of managing higher education is possible.
• … but the lessons of that system are ignored for most of the work HE does. The architects of the post-Dearing settlement left untouched – and, through HERA 2017, statutorily reinforced – the non-market architecture of research funding. They applied the logic of choice and competition to teaching with total commitment, but stopped at the door of research, because they knew the research system worked and would not survive being broken. The question this paper asks is why teaching was not afforded the same respect.

The heterogeneity question

Any comprehensive review must explicitly address whether a broadly homogeneous system – in which all universities are treated as essentially the same kind of institution, subject to the same regulatory framework and funded through the same mechanism – can be sustained, or whether policy should accommodate the differentiated institutional landscape that is already emerging. The system currently pretends that a research-intensive university with a £1 billion turnover, a specialist arts conservatoire with 500 students, and a large teaching-only private provider operating across multiple geographies are the same kind of entity. They are not, and governing them as though they are produces dysfunction in both.

What the paper proposes

The paper proposes a governance concordat – a transparent, negotiated settlement between the state, the sector, and students about who is responsible for what, by what mechanisms, with what limits, and with what processes for resolving disputes. This concordat should be the first product of a new comprehensive review of the purposes, shape, structure, size and funding of post-18 education, encompassing higher education, further education, and in-work technical training.

The review must not be a funding review. Funding is one of fourteen factors. A commission that treats it as the only one will produce another sticking plaster.

Seventeen interim recommendations are made, at least one per control factor, none requiring primary legislation, all achievable within the current parliament. These measures are not solutions; they are the diagnostic groundwork and pre-emptive action to enhance the quality of the review and to ensure there is enough of a system left to review.

The bottom line

The post-Dearing project failed – not because it was implemented badly, although it was; not because it was underfunded, although it was.

It failed because its mechanics were broken from the start.

Like a badly-wired plug, it operated, but the longer it did so, the more likely it would spark. The current financial state of the sector suggests that, somewhere, the fire has already begun.

English higher education has demonstrated that it has the power to change lives, enhance communities, spread prosperity, and stimulate transformation. But everywhere those benefits are achieved, it is in spite of the state/HE nexus, not because of it; driven by the altruism of public service, not the advancement of private interest.

With the hard-won learning of the past three decades, we should start again: a new review, a new policy framework, and a better chance for establishing a post-18 system that truly works for the common good.

Thirty years ago, the Dearing commission was set up to make recommendations on how the purposes, shape, structure, size and funding of post-18 education, including support for students, should develop to meet the needs of the United Kingdom in the following decades. Its report established the foundations of a broad-based political consensus, that greater competition for students was the proper instrument for transforming English higher education, which has been accepted, in one form or another, by every governing party since the millennium.

The English state elevated student choice and competition between providers into organising principles for the system, such that no other tools or further justifications were considered necessary.

Thirty years of blood, debt, toil, and arrears later, it is clear these gods have failed, and we must replace them. The tools enabling competition have left the system disordered, overburdened, and effectively bankrupt. Worse, this happened precisely because of those tools, not in spite of them. The political class enlisted the youth of England as their agents of change in universities, and they got more than they had dreamed, and almost nothing they wanted.

A new system must be created, one which is politically palatable, financially sustainable, and educationally sound. But even these features, while necessary, are not sufficient. The full scope of the relationship between the English state and, not just universities, not just all providers of higher education, but all those involved in the post-18 education system, including further education and in-work training, needs to be properly codified, made transparent, and provide meaningful ways to hold all those who are part of it, including agents of the state, to account.

This is not a temporary aberration brought on by a change in government, or the advent of generative AI, or post-Brexit hangover, or policy-political Long Covid. It will not fade away with time, it will not self-correct, and while there are short-term policy fixes to diminish the fury of the graduates and the crisis of institutions (and government should enact them), there can be no long-term answer for the entirety of post-18 education which does not grapple with the deformity of the relationship between higher education and the state.

There are actions that can and should be taken now (and this paper will propose them) but to build the system the country needs and deserves will be the work of many, over an extended period. Changes to the funding model will only be one aspect of the necessary transformation and any measures will only be sticking plasters on an open wound, if a new, thorough and holistic assessment of the state of higher education, and further education, and in-work technical training is not undertaken.

This paper sets out to explain why we must change, provide a framework for what must be considered by a commission, and propose viable interim measures to ensure that our post-18 system, and the students it serves, are prepared for the challenges of the next 30 years.

Today, English higher education is in a bad way – institutions are setting deficit budgets, free speech disputes have become regular headlines, and the benefits of it to those who’ve received it are being questioned. In the past weeks, the system by which higher education in England is primarily funded – the system of student loans to pay fees – has come under sustained attack from across the political spectrum, in a wide range of media, and has been a hot topic amongst graduates themselves.

Current travails are no doubt real and knotty, but they are symptoms of the dysfunction, not its cause. At its heart, all these problems, and a considerable number more, are a function of the incoherence of the inter-related, and over-lapping interactions, duties, and dependencies between the English state and the higher education system, what I term in this paper “the English HE/state nexus.”

For reasons of history, function, efficiency and democracy, higher education is both bound to the state and necessarily at a distance from it. The free creation, curation, and communication of knowledge is a good in itself in all human society, but in a constitutional democracy, such work also has a higher function, as one of the essential checks on the power of the state. It is no accident that wherever authoritarians arise, higher education is always one of their first targets.

Beyond its democratic function, higher learning is also a vital contributor to the training of technical professionals, and today in England encompasses much more than traditional conceptions of “university” might suggest. Over 100 universities make up the bulk of the English higher education sector, but there are also smaller, specialist institutions, including cultural conservatoires, professional training providers, and further education colleges offering degrees and other higher-level credentials. Higher education is profoundly important for individual, economic, and democratic health.

To sustain such a function in a modern society is not only extremely costly, but places the majority of our nation’s young people in the hands of institutions set at a distance from the state between the end of compulsory education and the beginning of their working lives, and gives such institutions a central role in local, regional and national economic life. Expense, influence, and investment are all areas where the state has a legitimate interest in holding any whose actions affect its citizens to account.

So higher education needs the state, and the state needs higher education, and both have legitimate cases that their core functions require, on the one hand distance from direct oversight (the sector), and on the other, powers to ensure accountability and responsiveness (the state).

There is no set formula for answering this question; it is necessarily a matter of dialogue. How successfully that dialogue leads to useful calibration of the distance between the state and higher education is the essential question for building a viable higher education system fit for the current age.

On what matters ought the sector to be autonomous – all or only some, and if some, in what combination? What forms of accountability ought to apply, to whom, judged by what metrics? What happens if either the state or the sector exceeds the bounds of the agreements between them?

As the examples we opened with demonstrate, the calibration exercise is currently not working: the nexus of state and sector is broken. And broken in a way that impacts well beyond England’s universities. Those aspects of post-school provision that are not funded, regulated, or discussed as part of HE but are linked to or provided by institutions inside the wider HE system have drawn further education and in-work technical training into the gravity well of the HE/state nexus.

The entire post-18 education system, even where other aspects are operating well by the metrics of their own eco-systems, is infected if the higher education system is dysfunctional.

This paper argues that a nexus failing as the English one is requires comprehensive replacement, not cursory repair. Such expansive reformation is not impossible in England, because the current nexus is the result of such forces. The past 30 years represent a distinct period of state/HE engagement, deliberately constructed to be different from preceding arrangements, based on a consensus which all major English parties elected to the Commons before 2024 have been part of: “[t]he ends of higher education and the needs of society will be best served if funding for institutions comes increasingly through the choices of well-informed individual students.”

Of course, it is not the case that market tools only appeared in English HE with the Dearing review and its impacts: England has had two universities to choose from for eight centuries, and at least one new institution of higher learning every decade since the 1820s, and it has been an accepted feature of English law for more than a century that university students have a contract with their institution. The tools of the market have been part of English HE for a long time. However, since the turn of the century, and through cross-party consensus, choice and competition have not been “aspects of the system” – they have become the organising principles.

But, as organising principles, they are deficient. We know this because every governing party has taken at least one turn in using these principles to build a white paper, subsequent legislation, and then a review of why things are not working as intended:

The current Labour government has reached white paper stage, although no legislation has yet been announced. That white paper criticises the present system, but unless the legislation it leads to addresses the underlying problem in how the state conceives of both its own and education providers’ functions, processes, rights and duties in regard to higher learning for citizens, it will be impossible to build capable, credible, enduring governance and accountability mechanisms. Without codified systems in which tensions between the state and the sector can be debated and resolved, the system will continue to fail.

But there is a model available for how to build a more successful nexus between HE and the state, drawn from analysis not of other HE systems, but of successful school systems across the world.

Tim Oates has put forward an analysis of the English school system which has proved to have enduring influence in this country and abroad. Oates argues that successful school systems are distinguished by, firstly, having clear, enduring, and appropriate control of fourteen different factors, and secondly, implementing such control with primary focus on the interaction between those factors. That is, no single factor determines whether a school system will work; instead it is whether all the factors have been deliberately aligned in such a way that they interact in more-or-less predictable and productive ways. Close attention to these factors and the relations between them achieves “coherence”, and it is the coherence of the system, not any of the choices about the individual factors, which marks the successful out from their peers.

The fourteen control factors are:

1. Curriculum content – national standards, subject specifications, textbooks, schemes of work, sequencing

2. Pedagogy – teaching and learning approaches, models of ability and progression, setting/streaming, homework

3. Assessment and qualifications – summative, formative, diagnostic; teacher vs external assessment; measurement models

4. Institutional development – leadership, management models, lesson observation, dissemination of good practice

5. Institutional forms and structures – school/institution size, type, phase, class size, facilities, collaboration/competition

6. Governance – national control arrangements, inter-departmental collaboration, governance tiers and powers

7. Professional development – teacher selection, training, CPD, remuneration, performance measurement, unionisation

8. Accountability – targets, data collection, publication, consequences, sanctions

9. Inspection – framework, frequency, composition of inspectorate, governance of inspection

10. Funding – levels, patterns, sources, allocation, financial control, links to accountability

11. National framework – legal attendance requirements, routes in education/training, allocation points, route flows, transfer arrangements

12. Selection and gatekeeping – methods of allocation to routes, entry requirements, equivalence rules

13. Information and guidance – focus and detail of guidance, entitlement to services, links between institutions and destinations

14. Allied social measures – fiscal policy incentives, family support, regional development, health services, labour market policy

Although any list of the factors necessarily requires they be in some form of order, the order is not a priority listing. Again, it is the relations between the factors that is significant, not any one of the factors.

Alongside the factors, Oates also lays out six explanatory factors, which are not levers the system can move itself, but instead establish the states of affairs in which a system operates: global economy, domestic economy, culture, political structures, historical contingencies, and natural environment.

As well as setting out the control factors, Oates also draws on an insight from German educational researcher Frank Achtenhagen, who outlined a model of the dysfunctional policy cycle he called “the cycle of planned failure.” Absent a proper appreciation of the value of coherence, and measures to ensure it was in place, Oates argued, school systems would be trapped in this cycle.

Codified into A Cambridge Approach to Improving Education, the framework is based on evidence from detailed case studies of England (the original primary subject), Finland (subject to particularly intensive historical analysis, correcting some profound errors of ahistorical analysis), Singapore, and Massachusetts. Subsequently, Hong Kong and Alberta, Canada have also been made subject to deep case-studies.

Beyond these deep cases, substantial comparative analysis covered Japan, South Korea, Taiwan, Germany, France, Flanders (Belgium), Australia, New Zealand, and the United States at national level. In 2021, coverage was expanded to include Chile, Estonia, Poland, Portugal, and Spain, explicitly citing curriculum coherence as a key explanatory factor across all ten country analyses. The Centre for Education Systems (CES), which directly draws on Oates’s framework, compares all four UK nations plus ten international jurisdictions. Through Cambridge Partnership for Education, the framework’s principles have been deployed in partnerships with governments in Gujarat (India), Uzbekistan, Malaysia, Ethiopia, Panama, Oman, Qatar, Egypt, Sweden, Vietnam, Rwanda, Bahrain, and others – reaching over 49 million learners in more than 40 countries.

The framework’s most thoroughly documented impact is on England’s 2014 National Curriculum, which is perhaps not a surprise because Oates chaired the four-member Expert Panel. The panel’s report directly embedded the control factors analysis, and concrete policy changes followed, but the framework has endured through a change in government that otherwise brought strong critics of the previous government’s approach into power. The 2025 Francis Curriculum and Assessment Review stated that “the previous review, whose expert panel was chaired by Tim Oates, did exceptionally high-quality work that has largely stood the test of time” and affirmed that the broad structure it set out would remain the same.

The control factors framework can therefore be seen as an academic analytical tool with direct, documented, and durable policy impact. Even critics of the implications Oates drew from it have not challenged the value of the framework for explaining differences in the level of success of school systems.

What has not yet happened has been any sustained application of the framework to higher education. This is not surprising, because the framework was explicitly developed for school-level/compulsory education, and every case study, data source, and example concerns primary and secondary schooling. The theoretical foundations – Schmidt and Prawat’s curriculum coherence concept, TIMSS and PISA data – are exclusively school-level assessments. However, attempts to apply aspects of its theoretical antecedent to HE have been made: “curriculum coherence” has been explored independently in HE contexts, notably by Bateman et al., Fung on connected curriculum, and Muller using neo-Bernsteinian theory, but none of these studies use Oates’s specific control factors framework. Pountney cites both Oates and HE sources on coherence but does not apply the fourteen factors to universities.

However, the control factor analysis can provide real insight into the problems of the current English HE/state nexus, and point the way towards enduring solutions. Although the framework’s original objects of study – national curriculum, approved textbooks, school inspection, standardised testing – are specific to compulsory education, the framework itself does not have to be. The framework is not prescriptive but diagnostic, and thus, while higher education’s institutional autonomy and academic freedom operate very differently from the compulsory school systems the original work describes, considering all of the factors and their relations can be used to review any form of education system. The framework does not require the control factors to be managed in a specific way, by a centralised state for example; it requires only that somewhere within the system the factors and the relationship between them is understood.

The factors do not need to be controlled through top-down mechanisms – indeed, Schmidt and Prawat’s key insight was that even when all these factors appeared to be nominally in the hands of the state, coherence was not guaranteed if they were not properly aligned. What the factors must be is controlled in some way – whether by a capable agency or through distributed arrangements – with the processes and impacts of that control considered in light of how they interact with the other factors. Schmidt and Prawat’s central insight is that there is no necessary relation between political form and coherence: Singapore’s directive-consensual model, Finland’s participatory-democratic model, and Massachusetts’ distributed model have all produced coherent systems through very different mechanisms. What matters is that somewhere in the system, the work of alignment is being done, and that somebody is watching whether it is being done well.

Utilising the framework, it becomes clear that the English HE/state nexus not only lacks coherence, but even a conceptualisation of the control factors as distinct aspects of the system that need to be brought into coherence.

For the past thirty years, the nearest thing to such a conceptualisation has been assumptions about the benefits of student choice and competition between providers. Given the framework has not previously been applied to HE, it is not a surprise that the system’s designers did not deploy it in their architecture, but using this lens to review the system demonstrates why it has been so unstable and unsuccessful.

Choice and competition are not a control factor – they are a single mechanism that was substituted for the distinct management of several control factors, while others were largely ignored. To avoid repetition, the below considers the control factors in groups:

A. Structural: funding, accountability, inspection, institutional forms and structures, national frameworks

B. Navigational: selection and gatekeeping, and information and guidance

C. Institutional: institutional development, professional development

D. Educational: curriculum content, pedagogy, assessment and qualifications

Lastly, I will consider the outstanding control factor, governance, and explore why this is especially important in a higher education/state nexus, and briefly consider why research, a function of HE that no school system has, provides further evidence of the value of the framework and the weakness of the present nexus.

Funding

Funding has dominated the conversation about English HE in this period. Although Dearing’s remit was wide, the immediate cause of the review was, fundamentally, financial – per-student funding in English HE had halved during the 1979–1997 Conservative government. Above and beyond all other things, that universities (of which there were now significantly more than in 1979 as a result of the abolition of the polytechnic/university divide) were underfunded was a political given, even by the government itself. Convened by the Conservatives and accepted by New Labour, Dearing said funding should come “increasingly through the choices of well-informed individual students”, and subsequent policymakers reinforced this principle at every turn: for example, under Vince Cable, then-Liberal Democrat secretary of state with responsibility for higher education, the 2011 white paper committed to “deliver a more responsive higher education sector in which funding follows the decisions of learners and successful institutions are freed to thrive”.

However, the way student choice and funding would interact was through a complex mechanism, created to resolve what was generally agreed at the time was a wicked problem. Growth in student numbers was not considered reversible – it was widely held that more higher education would, more-or-less automatically, engender more economic growth. Therefore, any new system needed to provide for enhanced funding on an enduring basis for an expanded population of students. But it was argued, politicians would never privilege higher education over other aspects of the education or wider government budget, such as early years education or children’s health.

To match and then improve the available funding for a growing system, Dearing concluded it was therefore necessary to raise additional funds not from the general taxpayer, but instead from those directly engaging with HE. But traditionally higher education was undertaken by people at the beginning of their careers, when they had no capital to spend on the education necessary to make them into people likely to generate enough capital to pay for their education.

Nicholas Barr proposed an elegant solution: a sort-of reverse pension, by which students would get HE for free, and graduates would pay for it, in proportion to the benefits they derived. Students would borrow the necessary capital from their older, graduate (and therefore generally richer) selves by taking out loans that did not have to be repaid until the individual was earning, and where the amount paid off per month was a portion of the earnings, not of the debt. Because such loans would never be offered on the open market, this system required government to underwrite the system, using the Student Loans Company (created for a much more limited loan function a decade before) to send the fee money directly to HE institutions, and maintenance loans (for living costs) directly to students. Because government was neither prepared to write an entirely blank cheque to universities, nor risk deterring young people from disadvantaged backgrounds from accessing HE, a limit was put on the amount of fee that could be charged: in 2004, £3,000; in 2012, rising to £9,000. Limits were also placed on the amount of money which could be borrowed for living costs.

Despite its technocratic neatness, thirty years after Dearing, this funding system has left us exactly where we started. In 1997, per-student funding was worth about £4,608 per year at 1995–96 prices – a little over £10,000 in today’s money. In the 2025–26 academic year, a domestic student paid £9,535 per year in fees, which when added to other government grants, means per-student funding today of… a little over £10,000. Too little attention has been given to this: the very reason for Dearing and building a new fee-based system has failed. One does not need to blame those who tried to make it work – it was not always obvious it would fail. But by the standard it set itself, it most definitely has.

In fact, it is worse than that, since the demographic composition of English higher education has changed across those thirty years, and now includes more full-time students from a wider range of backgrounds who both need and deserve additional resources to teach and properly support. Moreover, the English state has persisted in underfunding its research demands to the sector – arguably, part of the point of any fees uplift was to not only improve funding to teaching, but also to cross-subsidise research. It is a mark of the failure of this ambition that no one now suggests this is a purpose of the domestic fee, instead ascribing this role to international students’ payments (itself a dubious contention, as we shall see below).

Thus, the domestic student funding situation has oscillated, only to return to precisely where it started, while the likely costs have expanded. English HE now needs to do a lot more with a unit of resource from domestic students nearly identical to that which it had at a point where almost everyone agreed the system was in crisis. Looking at this with an eye on system coherence, we can see further evidence of meshing together multiple control factors through a single mechanism, and therefore achieving none of them. Not only did the system not result in substantial and sustained additional funds to higher education in perpetuity beyond what could ordinarily be raised by general taxation, it actually baked this outcome into the system itself, through the interrelation of two different aspects of the fee/loan process.

The first issue was that almost every institution charged the full viable fee amount, almost immediately, every time they could. Governments of all parties persistently asserted that government-set loan amounts should be a ceiling, not a standard, price: David Willetts, higher education minister at the time of the 2012 increase, insisted that the £9,000 fee would apply only “in exceptional circumstances,” despite the fact that every institution had more or less immediately moved to charge £3,000 in 2004. This ought to have been predicted, because the architecture of the fee broke the price mechanism. For students, HE was free at the point of delivery and what students borrowed (in so far as they really understood what that amount meant, and what it would look like to pay it back when they were working, on which see below) had only an incidental relationship to what the graduate would pay back.

The customer was the aspirant student, not the graduate (not even the actual student attending the institution, since mechanisms for moving provider remain exceptional). There is thus no incentive for institutions to differentiate their offer through price, because the intended customer has no compelling reason to choose a lower-fee institution. Indeed, it swiftly became clear that those offering “cheaper” degrees were losing out, because students doubted the quality of anything being offered at a discount rate in a “market” where the standard price was “everything students could borrow”. Since 2012, the Teaching Excellence Framework (TEF) has added a small additional level of fee differentiation for those institutions without a TEF judgement as against those with one, and again, amongst those entitled to charge higher, everyone has chosen to do so. Precisely because the amount borrowed is only relevant as the top limit of what is to be repaid (subject to inflation, of course, though how this is calculated is its own vexed question for the system), the sticker price and the experienced cost are divorced from each other.

Because the initial outlay of money by the student to the university was funded directly by the state, once it became clear that the level set by government would be the default, the Treasury proved extremely resistant to raising the limit, and thus the fee lingered at a level below its real-term value for most years, until we reached the position that the total domestic per-student funding is the same now as in 1995.

But this was not the only unintended consequence of the funding model. The Resource Accounting and Budget (RAB) charge – the money the Treasury believes it will not see again as a result of underwriting the student loans system – has also been dramatically squeezed. Today, the RAB charge ought to represent the overwhelming majority of government subsidy to HE for teaching, but the Treasury’s willingness to bear this burden decreased significantly over time. Sums of money that, when they had appeared on educational department balance sheets as grants, appeared defensible, were no longer so when they showed up as “bad debt” in the government’s accounts. One did not have to be an arch-Thatcherite to look at sizeable loan write-offs and consider them to be peculiar, and indeed, both Tory and Labour chancellors took steps that reduced the RAB charge through the only mechanism available – changing the terms of the student loans system. The repayment threshold (the point at which graduates were earning enough money to have to pay into the system) was held below inflation, drawing more and more lower-paid, early-career graduates into making repayments.

Under Rishi Sunak, a new “Plan 5” system was created which meant new students would repay for 40 years, not 30 as their older siblings were expected to. The Treasury now expects to make money out of the student loan system, and because of the nature of government accounting, is incentivised to do so. The very system that was supposed to insure higher education against Treasury penny-pinching actually put the sector at the mercy of government accountants.

Where a genuine infusion of additional cash does seem to have been found is from international students. Numbers have grown and generally brought with them corresponding, much higher fees. It is true that far more international students attend English higher education today than in the 1990s, and the total monetary value of their fees is about the same as the total provided by their domestic counterparts. This was never envisaged as part of the post-Dearing system (in so far as international students were considered within the various reviews at all, it was imagined their numbers would grow relatively slowly) but it might be argued it is evidence the system can self-stabilise in innovative ways.

However, the actual sums do not really stack up to support that claim. The additional income is significant, but fundamentally, it comes from an increased number of students, so is diffused across the system – so whilst there now is cross-subsidy from international students to domestic students, it amounts to around £2,500 per year, suggesting an overall per-student spend in HE of £12,000 to £13,000; an increase against the 1990s, yes, but not extraordinarily so. More problematically, that average obscures that the distribution of international students has, until relatively recently, been clustered in highly selective institutions, who were already the most financially advantaged under the former system. Where international student numbers have grown in other parts of the sector, they have tended to be at price points largely the same as domestic students, in a manner which has attracted negative attention from the Home Office and the regulator.

Accountability and inspection

If the funding mechanism failed by its own metrics, it also led to deficiencies in other control factors. For example, student choice in the post-Dearing system was also supposed to provide an accountability feedback loop which would drive enhanced quality. In their reform of the system in 2004, New Labour introduced the National Student Survey (NSS), and Browne, convened by Labour but reporting to the Conservatives, doubled down on the link between student satisfaction and accountability, with an entire section titled bluntly, “Student choice will drive up quality”.

Education quality is notoriously difficult to determine, especially by users of any education system. In fact, Dearing mostly directly equated quality with per-student funding, but we have seen how that panned out. Instead, let us first consider the metric the system established for itself, the NSS. Conducted annually since 2005, its data does indeed suggest there has been a steady positive increase in students’ satisfaction with higher education.

However, the NSS is not a reliable or even especially useful instrument. In the first place, determining the quality of teaching is a demanding and complex task, which is why the school inspectorate Ofsted stopped making judgements about the quality of individual lesson observations nearly a decade ago – students’ expressed satisfaction one way or another does not demonstrate that good teaching has happened. There is considerable evidence for systemic biases in teaching satisfaction surveys elsewhere, and repeated reports across the system of attempts by HE providers to play on the high-stakes nature of NSS outcomes to induce students to provide positive feedback.

Even so, students could give us some idea whether what they got out of higher education was what they had expected, but this is not something the NSS can tell us, because there is no cohort-by-cohort comparison of what students are satisfied with, because they are not asked about their expectations upon entry. The steady improvements in satisfaction suggested by the NSS might simply reflect very different views by each cohort of what ought to be considered satisfactory. As either an objective or a subjective measure of satisfaction, the NSS is deeply flawed.

Moreover, there is evidence elsewhere that students are not satisfied. Recent work by Nicola Dandridge (who was chief executive of OfS when it took on responsibility for the NSS) suggests that significant numbers of undergraduates, and a still larger proportion of recent graduates, would have changed some aspect of their HE experience if they were to undertake it again. Elsewhere, students taking their universities to court over their treatment during Covid or at times of industrial action, or the growing number and nature of complaints making it to the Office of the Independent Adjudicator, suggest there is real unhappiness amongst students. This is not evidence that these students wish they had not undertaken higher education. Instead, it suggests that they wanted, and believed they were being offered, something better than what they got. For a system badged with “students at the heart,” this cannot be considered a success, but it also should not be a surprise.

Although the nexus has tended to assert that choice must drive quality, the actual mechanism by which this might work is unclear. It was suggested, especially after the number caps were lifted after 2012, that students would flock to the “best” institutions. But even if one were to assume students were entirely rational utility maximisers, there are significant disparities across the country both in the quality of learning students receive before 18 (and, thus, the breadth of institutions they could apply for with a reasonable chance of success) and the material resources students could access that would allow them to travel freely and select from the full range of institutions. So students’ concept of the best might be “the nearest”, for example.

Moreover, students were hardly making their choices in a vacuum – the dominance of a small number of highly selective institutions in the national imagination about what university is and should be, especially Oxford and Cambridge, gave them inherent advantages in the battle for students over less well-known competitors. The very gimmick which made income-contingent loans so attractive – the students borrowed them, the graduate repaid them – stored up enormous problems, because students, approaching university generally at the age of 17 or 18, had no real idea what the sums of money they were signing up to borrow actually meant – it is hard to imagine what nine per cent of a salary over £21,000 is if you have never earned anything like that. Nor did they fully understand the terms on which they had agreed to borrow. Even the language of the system is now consistently misleading: a “loan” which could not be got on the open market, offered by a broker who can and has changed the terms in ways which would be illegal were it a private contract; a “fee” where the thing being purchased is, by definition, difficult to be precise about, but the price of which is set by neither party to the contract.

Ultimately, it was always unlikely that student choice would inherently improve quality, because the evidence that students are choosing institutions on the basis of teaching quality is highly questionable. In so far as the TEF does measure teaching quality (itself a contestable point), it seems unlikely that TEF outcomes drive choice more than, for example, high name-recognition and status, which may be entirely divorced from teaching quality. Students interviewed about how and why they make the choices they do about education cite distance, the choices of friends, and the positive impressions created through pre-university engagement as at least, if not more, likely to drive their decision-making. By shifting the vast majority of university funding into the hands of the aggregate decisions of 17-year-olds, the English system of choice has become, more or less, an enormous machine for finding out who has the best (or best resourced) marketing department, with some world-leading research sprinkled in certain places.

It is this break in the implementation chain of student choice which has made it so ineffective at changing the standards of education available in HE. A system in which every HE institution is teaching-active, and only a portion of them are research-active, ought to privilege teaching over research. But the English system does not do so. In part, this is because of status issues related to the concept of what a university is – many academics think of themselves as researchers first, who are sharing their research and its discipline with their students, rather than tutors first, who are systematically inducting their tutees into a discipline. But given the funding disparities between research and teaching, this cannot be the whole explanation. The annual outlay into HE is around £4–6 billion for research per year, but is £11 billion in tuition fees, with a further £10 billion in cost-of-living support, much of which makes its way back to universities. However, if students do not choose universities because of their teaching quality, there is very little an institution can do to increase student enrolment through improving teaching quality. But there are material actions individual academics and whole universities can take to improve their standing in the Research Assessment Exercise, and thus have a direct impact on their research funding.

Student choice has made student recruitment essential – and government decisions about reducing the funding to universities available through other routes have only made that more so – but because such recruitment does not rest on improving teaching quality, or better aligning curriculum with the job market, or thus far any other objective a government has thought appropriate for an HE system (other than that numbers should expand), those objectives will not be prioritised. Ironically, the system does not even improve experiences for actual students, because in general, they are not actually the objects of interest – it is aspirant students a university needs to impress; once they are in, few will seek to go elsewhere.

However, as part of the cycle of planned failure, the shortcomings of student choice as an accountability system have led to significant expansion of other forms of accountability, contrary to the implicit promises of the choice and competition model of light-touch regulation. For example, reliance on international students made it necessary for English universities to engage with states abroad and put their cash flow at risk in the event such states take actions which shut down the pipeline. But if contending with the whims of the Chinese Communist Party was not enough, international student fees have actually increased HE’s dependence on parts of the British government – decisions in the Home Office about which students will be permitted to study in England are now matters of existential concern.

But the failure of student choice as an accountability mechanism in regard to domestic students also did not lead the state to reconsider the model – it led to the creation of more regulation on top of it. The Office for Students, established by the Higher Education and Research Act 2017, was explicitly framed as a market regulator rather than a sector steward, charged with promoting competition and protecting students as consumers. Its creation was supposed to resolve the tension between light-touch regulation and public accountability by giving a single body the power to enforce both.

In practice, OfS has found itself in an impossible position, not because of its leadership (changed twice already in a body less than a decade old) but because the task it was given is structurally incoherent. It was told to be a market regulator in a system where the market does not function as a market: the price is fixed, the customer cannot easily switch provider mid-course, and the information asymmetries between the institution and the applicant are vast. It was told to protect student interests while relying on metrics – the NSS, graduate outcomes data, continuation rates – which measure proxies for quality rather than quality itself. And it was told to promote competition while simultaneously being expected to prevent the consequences of competition, namely institutional failure and the stranding of students at providers that go under.

The result has been an ever-expanding regulatory apparatus that satisfies nobody. The sector complains of excessive bureaucratic burden, government complains the regulator is not assertive enough, and students continue to report experiences that fall short of what was promised. OfS now finds itself conducting investigations into franchised provision, managing access and participation plans, running the TEF, overseeing the NSS, adjudicating freedom of speech disputes, and considering how to manage the potential financial collapse of institutions. Such a remit would have been unimaginable under the old HEFCE model, and is entirely at odds with the “light-touch” market regulation the 2016 white paper promised. Each new function was added because the previous accountability mechanism proved insufficient; each addition represents another turn of Achtenhagen’s cycle.

Institutional forms and structures, national frameworks

The troubles of English HE and the choices made in response to them have also had undesirable consequences for the other aspects of post-18 education. In 2015, Alison Wolf warned that “an ever-expanding gulf between FE and university funding will push more students into the university sector, driving technical education out of the FE colleges that might be suited to delivering it.” It seems undeniable that this has happened. For example, between 2010 and 2022, the number of foundation year courses (offered in universities) grew enormously, mostly in institutions in the sector that catered to students with lower prior attainment, who were thus in direct competition with their local FE college, where the equivalent “Access to HE” courses have seen a decline across the same period, despite the growth in the size of the cohort. The Augar review explicitly recommended withdrawing funding from foundation years for this reason – but holding an entire review to address just one of the unbalancing forces within the system is both expensive and also does not address the root cause of the problem, a system in which the appropriate roles of HE and FE have not been delineated, nor credible mechanisms for resolving tensions between them established.

The skills agenda too has been significantly disrupted by its proximity to an HE system with a thirst for resources. Apprenticeship starts in England in 2022–23 were 160,000 lower than before the advent of the Apprenticeship Levy (now the Growth and Skills Levy), and the average cost of an apprenticeship has doubled. This is partly a function of the monies raised from the levy being disproportionately spent on higher-level apprenticeships, many delivered in cooperation with universities. Given the explicit framing of the apprenticeship agenda as supporting the needs of students from less socio-economically advantaged backgrounds, it is significant that only 13 per cent of degree apprenticeships, those requiring university involvement, go to disadvantaged apprentices. Although it is worth noting that, despite the attention given to degree apprenticeships, they provide only around 25,000 places per year for students, as against more than 400,000 places each year in HE – even if they were more equitably distributed, the scale of their impact would be minimal, and the reasons for that are a direct result of the way the system is set up.

This is not an argument that HE necessarily should not be involved in the provision of work-related training or preparation for undergraduate study – there are excellent examples of HE providing both of these – but that the interplay between HE and its sibling post-18 systems is profoundly imbalanced. On average, HE has more resources, higher status in the eyes of the public, and often greater capacity to innovate than either FE or the skills sector. Universities can therefore roam at will into areas provided by these other sectors, potentially destabilising systems of implementation in those sectors. This does not require malign intent or incompetence; it is straightforwardly a function of the incentives of a choice-and-competition-based system.

What is even more peculiar is that genuine attempts to manage the tensions between the different aspects of the post-18 system go unsupported in any practical sense. London South Bank University is the lead institution in a group structure with an FE college and a multi-academy trust of schools, yet its vice chancellor reports it works “in spite of the system rather than because of it,” facing ongoing complexities of competing and sometimes contradictory regulatory and funding environments. Even recent public investments in enhanced collaboration have been strangely ignored: despite investing £300 million in the Institutes of Technology programme, no evaluation of its effectiveness has been published by government.

Perhaps the most damaging example of the system’s incoherence has been the growth and subsequent crisis of franchised higher education provision. Franchising – by which a registered university validates and funds a course delivered by a third-party provider, often a private company – was originally conceived as a mechanism for expanding access, enabling specialist providers and FE colleges to offer degrees under the quality umbrella of an established institution. In a system governed by student choice and competition, it appeared to combine the best of both worlds: widening participation without requiring every provider to meet the full burden of OfS registration.

In practice, the incentive structure produced exactly the opposite. Because registered providers received the student loan funding directly and passed a portion to the delivering partner, the arrangement created an arbitrage opportunity: the validating university took a margin for bearing the regulatory risk, the delivering provider operated at lower cost than a university, and the student – who in many cases was recruited by the delivering provider rather than choosing it through the conventional application process – was frequently unaware of the distinction between studying at a university and studying through one. At its worst, this produced the scandals of 2023–25, in which providers with minimal teaching capacity recruited thousands of students, often from vulnerable populations, to courses where attendance was sporadic, completion rates were dire, and the public money spent per graduate was grotesque.

The regulatory response has been substantial –OfS has tightened franchise registration conditions, and government has announced further restrictions – but the episode illustrates the systemic problem rather than resolving it. Franchising failed not because of a few bad actors, but because the system created a structural incentive for it to fail. The separation between the body bearing regulatory accountability (the registered provider) and the body doing the actual teaching (the franchise partner) is a direct consequence of a system in which market entry was encouraged, oversight was designed to be light-touch, and the mechanisms for ensuring that institutional forms served educational purposes rather than commercial ones were never properly designed. When the only tool for managing institutional diversity is the market, the market will produce the forms that maximise revenue, not the forms that maximise learning. The franchise crisis is not an aberration; it is the system working as designed.

Selection and gatekeeping

As well as funding and accountability, student choice was also supposed to substitute for institutional or state planning in determining the supply of higher education and allocating learners to providers. Browne baldly stated “Their [students’] choices will shape the landscape of higher education.”

Arguably, this has seen both the English HE/state nexus’s greatest achievements and its most significant failing. Perhaps the most distinguishing mark of English higher education when set against our international peers is the openness of the system to students who would once have been either unable or firmly discouraged from taking up a place on a degree or equivalent course.

At each point of the expansion of the student choice mechanism, the question has been posed whether expanding indebtedness for many will deter students from disadvantaged and historically excluded backgrounds from seeking access to higher education. Proponents of the system have pushed back that it is built precisely so this can happen: more funding for HE to take on more students, that funding arranged in a way which reduces the risk of debt aversion, and can put forward a strong case: participation rates in English higher education have soared in the post-Dearing era. In the mid-1990s, around 13 per cent of young people eligible for free school meals (FSM), the standard measure used to identify students from the least privileged families in the country, entered higher education by age 19. By 2023–24, that figure was around 29 per cent. In 1997, the entry rate to HE for black students was significantly below the white British rate, but by the mid-2010s, the overall ethnic minority entry rate to HE had overtaken the white British rate, and by 2023–24 it was substantially higher. UCAS data shows that 18-year-old entry rates for black students roughly tripled over that period – from around 12 per cent to around 35–40 per cent.

But the post-Dearing system did not cause this expansion – it merely sat on top of it. Peter Mandler has compellingly argued that every aspect of the English education system which had an in-built status divide at the end of the Second World War was destroyed as aspirant working-class communities sent their children into those systems and decided they did not want to be offered second-best. Grammar schools, the university/polytechnic divide, and the preservation of HE as a highly selective, elite experience all went by the wayside on a timetable precisely matched to the growth in political significance of those who had been earmarked to miss out, and that timetable paid little attention to which party was in government. Massified higher education is not a gift from politicians to their people; it is a policy response to a consistently expressed preference from the public. Those who condemn Tony Blair’s commitment to sending fifty per cent of young people to university should consider whether it was less an act of radical vision and more a case of him finding out where the people were going so he could lead them there.

The post-Dearing system, in other words, has claimed as its greatest achievement something it did not produce. The demand for massification was already there; what the system was supposed to do was channel that demand into better outcomes. On that measure, the record is far weaker. The most selective institutions are more diverse now than thirty years ago, but are still less so than the sector average. Gaps in outcomes between students from less privileged backgrounds and their better-off peers, and between certain groups of ethnicities, are persistent. Furthermore, as the gatekeeping for institutions (as opposed to students) has been loosened, especially since the Higher Education and Research Act, a significant portion of the “participation revolution” has been made possible by the growth of franchised provision which is now the subject of considerable regulatory, and even law enforcement, interest, because its methods have been so suspect and its outcomes so appalling.

Although the average return for graduates on their investment in HE remains positive, some have not seen the benefits they were promised. Questions about how well HE has adjusted itself to its newest recruits, or the extent to which the system has properly constructed the scaffolding necessary to take students with poor experiences of prior learning into degree-level study, remain challenging. Therefore, while the post-Dearing system has facilitated the increase in historically excluded students attending HE, the incoherence of the system has meant that this facilitation has not stretched so far as to consistently enable all students to achieve at the level that might have been thought appropriate at the turn of the millennium.

Information and guidance

Dearing’s entire logic depended on “well-informed individual students” making rational decisions at seventeen. But every government document since has promised “better information” while none has promised guidance – and these are not the same thing. Information is Discover Uni printing the average salary of graduates from a course. Guidance requires agents who know students, their circumstances, and the system, helping work out what that information means for the individual student’s specific situation. No other area of consumer protection works on the assumption that providing data is the same as providing advice, which is why getting a mortgage is a more involved process than using a comparison website alone. The system requires guidance but funds only information, and funds even that poorly.

The 2011 white paper promised “much better information on different courses,” leading to the establishment of what is today Discover Uni. The 2016 white paper required publication of application, offer, and progression rates broken down by ethnicity, gender and socioeconomic background, and LEO data now links graduate earnings to courses. But there is no evidence that this data drives choice in the way the model assumes. Students cite distance, the choices of friends, and the positive impressions created through pre-university engagement as at least as important as any published metric. Where Discover Uni data does exist, Dickinson’s work on franchise provision shows it is frequently missing or misleading – students often cannot tell which institution will actually teach them, or what the outcomes data refers to. The information exists; the mechanism by which it is supposed to produce rational choice does not.

Meanwhile, governments have not merely neglected guidance – they have systematically built it up and then torn it down in a cycle that perfectly illustrates Achtenhagen’s model applied to a single control factor. Connexions (2001) was too broad and collapsed under its own remit. AimHigher (2004) was funded at £136m a year, establishing 42 area partnerships and seven years of accumulated relationships, expertise, and trust with schools. It was abolished in 2011, with a three-year gap before anything replaced it. The National Networks for Collaborative Outreach (2014) was funded for just two years, then defunded. Its successor, NCOP, now Uni Connect (2016), launched at £60m and has been progressively cut to £20m. Each cycle destroyed the institutional memory, the relationships with schools, and the staff expertise of the last.

The consequences are measurable. Research by the National Education Opportunities Network found that participation among students eligible for free school meals grew by 1.22 percentage points annually during AimHigher’s lifetime (2005–2012), falling to 0.79 percentage points in the decade after it was defunded. The FSM access gap widened from 17.5 percentage points in 2012–13 to 20.8 percentage points in 2022–23. Entry rates from the south west are now more than 30 percentage points behind London. Defunding the guidance infrastructure had direct, measurable consequences for the very students the system was supposed to serve.

Where public guidance has been defunded, the vacuum has been filled by commercial recruitment agents – operating in shopping centres, on social media, and door-to-door – selling higher education to precisely the populations who most need guidance and least have access to it. This is not an accidental failure; it is a structural consequence. When you defund public guidance and leave the market to fill the gap, the market sends salespeople, not advisers.

Moreover, the fee system has been compromised by conflating the population of students in the system at the time of its enactment with the population it was intended would enter the system over time. That HE but not other state provision could be funded by fees depended on convincing the public that 18-year-olds should be required to take on enormous loans to fund their education. For such a system to be sustainable and fair requires that young people at the end of schooling be genuinely capable of making a borrowing and investment decision with enormous lifetime consequences in full knowledge of its likely impacts and effects.

Plausibly, this was true of those students who entered full-time higher education in 1996 or even 2004, predominantly from more privileged backgrounds, with successful academic educational experience, family histories of HE involvement, and the resources to make contingencies if HE did not work out. However, as the system expanded to take in more of those historically excluded from full-time HE, it became less clear this would be the case. The current arguments from Plan 2 loan holders suggest that students did not feel adequately informed or fully understand how the terms of their loans would work.

The failure of this single control factor does not stay contained. The entire funding mechanism depends on informed choice. The accountability mechanism depends on students choosing on quality. The selection and gatekeeping mechanism depends on students allocating themselves rationally across providers. All of these assume information and guidance is working. It is not – and the government has actively ensured it cannot, by repeatedly defunding the only infrastructure that could make it work. This is the clearest example in the essay of what happens when control factors are not managed as distinct aspects of the system: a failure in one does not merely damage that factor, it undermines the coherence of every other factor that depends on it.

Institutional development

The post-Dearing system has not entirely ignored institutional development, but its approach has been shallow and reactive. OfS conditions of registration address financial sustainability and governance at a compliance threshold, and the Committee of University Chairs (CUC) maintains a voluntary governance code. These are not nothing. But they amount to a minimum floor with no mechanism for driving improvement above it. There is no equivalent of the National Professional Qualification for Headship that exists in schools – a vice chancellor can take charge of an institution with a turnover of hundreds of millions of pounds and responsibility for thousands of students without any formal preparation for institutional leadership. When governance fails, as it has at numerous providers in recent years, the regulatory response is reactive: intervention after the damage is done, rather than any systemic investment in ensuring institutions are well-led in the first place.

OfS’s 2025 proposals for a revised TEF illustrate both the system’s awareness of this gap and its inability to address it coherently. The consultation proposes integrating quality assessment with the TEF, so that every registered provider is assessed, with ratings linked to regulatory consequences – Bronze-rated providers would face restrictions on student number growth, and ratings may in future determine maximum fee limits. This is a significant expansion of the original TEF concept, which was framed as an enhancement tool rather than a regulatory instrument. But what the proposals actually do is use a single mechanism – TEF ratings derived from proxy metrics – to manage institutional development, accountability, and funding simultaneously. The Engineering Professors Council has argued that the shift transforms TEF from enhancement to compliance, and that proxy measures remain inadequate for assessing teaching excellence. The pattern is familiar: because the system lacks distinct management of each control factor, it reaches for the nearest available tool and overloads it.

Contrast this with schools, where Ofsted explicitly inspects leadership and management as a distinct judgement, and where a failing leadership team can trigger intervention. In higher education, an institution can be badly led for years before anyone with regulatory authority notices – and when they do, the tools available to them are blunt instruments designed for other purposes.

Professional development

The system has noticed professional development as a factor, but has not managed it. Advance HE maintains the Professional Standards Framework, through which university teaching staff can gain fellowship recognition at four levels – Associate Fellow, Fellow, Senior Fellow, and Principal Fellow. Increasingly, institutions expect or encourage staff to hold fellowship, and some require it for probation or promotion. This is the closest thing to a teaching qualification in higher education, and it would be wrong to dismiss it entirely.

But the framework is voluntary, employer-driven, and carries no regulatory force. Nobody is prevented from teaching in higher education without it. In schools, Qualified Teacher Status is a legal requirement – the state has determined that it matters enough to enforce. In higher education, a world-leading researcher with no training in pedagogy can be put in front of 300 first-year students, and the system has no mechanism even to know this is happening, let alone to address it.

The deeper problem is structural. Promotion, prestige, and pay in higher education are overwhelmingly driven by research output. Teaching excellence is rewarded rhetorically – in institutional strategies, in TEF submissions, in vice chancellors’ speeches – but not structurally. The incentive system actively discourages sustained investment in the professional development of teaching, because an hour spent improving one’s teaching is an hour not spent on the research that determines career progression. The TEF was supposed to counterbalance this, but as we noted above, it measures proxies – NSS scores, continuation rates, graduate outcomes – rather than the quality of teaching practice itself. An institution can achieve a Gold TEF rating without any systemic investment in how its staff teach, provided its students are satisfied and its graduates find employment. These are not irrelevant outcomes, but they are not the same thing as teaching quality, and treating them as if they are is precisely the kind of factor-collapsing the control factors framework warns against.

The connection between both of these factors is that institutional autonomy over leadership and professional development is not inherently wrong – but autonomy without transparency, without systemic oversight of whether it is producing the outcomes the country needs, and without any mechanism for identifying and addressing failures, is not autonomy. It is abdication.

Curriculum content

Of all the control factors, curriculum content is the one where institutional autonomy is most fiercely defended and most clearly justified. Higher education’s purpose includes the creation and contestation of knowledge, and a nationally prescribed curriculum would be antithetical to that purpose. There should be no national curriculum for universities. But the absence of any systemic view of what is being taught, at what level, in what sequence, and to what standard means that nobody – not the state, not students, not employers – can assess whether the system as a whole is producing the graduates the country needs.

The system is not entirely without tools here. The QAA Subject Benchmark Statements provide voluntary reference points for what a graduate in a given discipline should know and be able to do. Professional, statutory and regulatory bodies (PSRBs) – in medicine, engineering, law, nursing, and a number of other disciplines – provide genuine curriculum coherence, specifying content, standards, and assessment requirements as conditions of professional recognition. Where PSRBs operate, there is a form of systemic oversight that works. But coverage is patchy: most humanities and social science degrees have no equivalent external framework, and the sector has never attempted to develop one.

Meanwhile, the state is already making curriculum decisions – it is simply doing so covertly. The Lifelong Learning Entitlement makes modular provision eligible for student loan funding in ten specified subject groups aligned with the government’s industrial strategy: computing, engineering, architecture and planning, physics, mathematics, nursing, allied health, chemistry, economics, and health and social care. This is de facto curriculum policy, delivered through the loan book. The state has decided which subjects merit the flexibility of modular study and which do not, but because the decision is framed as a funding condition rather than a curriculum intervention, it is not subject to the scrutiny, consultation, or democratic accountability that would attend an explicit curriculum decision. The control factors framework does not require the state to prescribe curriculum content – but it does require that wherever curriculum decisions are being made, they are made transparently, by a capable agency or through appropriately transparent distributed arrangements, with their interactions with other factors understood.

Pedagogy

Pedagogy is the control factor the English HE/state nexus has most completely ignored. There is no systemic view, at any level – regulatory, governmental, or sectoral – of how students in higher education should be taught. Individual institutions make pedagogical decisions, individual academics develop their own teaching practice, and the system as a whole has nothing to say about whether any of it works.

The consequences of this neglect have been made visible by generative AI. The assessment-heavy, contact-light pedagogy dominant in many parts of the sector was already failing to verify whether students had understood what they had produced. AI has made the gap between production and understanding costless to exploit. Recent research found students describing six distinct modes of AI use, determined almost entirely by assessment design rather than by institutional AI policies. Where students knew they would face a future moment at which they must personally demonstrate understanding – an exam, a viva, a supervised practical – they used AI to deepen their learning. Where no such accountability moment existed, the same students used AI to generate work they could not explain.

This is not an argument for the state to prescribe how universities teach. It is an argument that pedagogy cannot be treated as a factor that requires no systemic attention whatsoever. The revised TEF proposals touch on pedagogy obliquely – they will assess “the student experience” – but through proxy metrics, not through any direct engagement with the quality of teaching practice. The system has a pedagogical crisis it can describe but no framework for addressing it.

Assessment and qualifications

Assessment is the control factor where the system has been most aware of failure and least willing to act. The external examiner system – the principal mechanism by which English higher education assures comparability of standards across institutions – has been reviewed, criticised, and recommended for reform in a cycle that now stretches back decades. The House of Commons Innovation, Universities, Science and Skills Committee raised concerns in 2009. HEFCE commissioned a review in 2015 which concluded the system needed to be strengthened and the role professionalised, and subsequently funded a five-year Degree Standards project through the Higher Education Academy (now Advance HE) to develop professional development for external examiners and explore approaches to the calibration of standards. Yet the fundamental problems identified in 2009 – inconsistency, lack of transparency, inability to ensure genuine comparability – remain substantially unaddressed. The problems feel contemporary and yet exacerbated by a decade of expansion, and the recommendations remain largely undelivered.

Shifts in grading distribution have only made this problem more obvious. The proportion of students awarded firsts and upper seconds has risen dramatically over two decades, and the trend has been exhaustively documented by OfS. The sector’s own attempt at structural reform – the proposed Graduate Outcomes Classification, which would have replaced the degree classification system – collapsed under institutional resistance. Employers increasingly report unhappiness with the information provided by degree outcomes. Every year, OfS generates an “unexplained grade outcomes” report, and every year it is suggested that there may be many explanations of why such grades are not inexplicable – yet no coherent attempt is made to actually explain them.

The external examiner saga is the Achtenhagen cycle in miniature: a problem is identified, a review is commissioned, recommendations are made, a partial reform is attempted, the underlying problem persists, and another review is commissioned. The system has been going around this loop for the assessment factor alone for nearly twenty years. It is difficult to imagine a clearer demonstration of the cost of managing control factors in isolation rather than as an interconnected system.

It is a matter of some irony that, despite ferocious (and justified) resistance to the general idea of government control of HE curricula, the state is already exercising control over curriculum, pedagogy, and assessment through funding conditions, regulatory metrics, and market pressure. But because it does so covertly rather than through a transparent framework, these interventions cannot be debated, scrutinised, or held to account, and their interactions with each other and with the other control factors go entirely unexamined. We ought not to override institutional autonomy, but to ensure that autonomy operates within a system that is coherent enough to deliver the outcomes the country needs.

In Oates’s original work, no control factor is inherently more significant than any other – it is the inter-relations between the factors that matter. However, in a higher education/state nexus, governance is the X factor in the nexus – the control factor whose presence, or absence, determines whether any of the others cohere. Governance occupies this special position, because of the particular claims of necessary distance between the two, created by the nature of higher education itself.

Because HE in all societies has a function of knowledge creation, curation, and communication, and because the creation of new knowledge inevitably requires inquiries which reach beyond the currently known and accepted, academic freedom and institutional autonomy are not mere buzzwords but concepts that require both respect and enforcement. However, they are not an unfettered licence for a lack of accountability. The current English HE/state nexus has proved remarkably unsuccessful in properly and sustainably defining and embedding these concepts.

Institutional autonomy and academic freedom

HE providers will often point out that the Higher Education and Research Act 2017 makes the first duty of OfS “to protect the institutional autonomy of English higher education providers” and then criticise actions taken by OfS for being insufficiently mindful of this. But the duty is, in fact, a “have regard to” duty – a relatively weak form of statutory language. State agencies can and do actively choose to undertake actions that impair such duties where that activity can be shown to serve other duties they hold, and OfS has a further eight such duties, including “the need to encourage competition between English higher education providers” and “the need to promote value for money in the provision of higher education”. It may well be correct that the protection of institutional autonomy is only one of a number of issues OfS ought to consider, but this is clearly not a matter fully accepted by the sector itself. The issue of who is empowered, and by what means, to determine how the governance of the sector ought to operate is not properly settled.

Worse, the assumption that student choice would be the motor of the system has had a secondary, insidious effect: it has de-skilled government itself. Ministers have believed they were granting unprecedented freedom to the sector; meanwhile, the state still sets the fee cap, the loan terms, the visa regime, the regulatory conditions, and the research funding formula. The freedoms are narrower than they appear, the constraints are tighter than they are acknowledged to be, and the statecraft capable of managing either has atrophied.

The dispute over academic freedom illustrates this governance challenge. Previous legislation had laid duties on higher education providers regarding academic freedom, but subsequent legislation went further, creating a duty to promote freedom of speech within the law and establishing a dedicated complaints mechanism. This was perceived by much of the sector, and strongly intimated by the then-government, to be a measure designed not to stabilise these concepts within a sector that valued them, but to defend ideas the sector would not. It is not necessary here to give a full account of that dispute or to adjudicate on who had the right of it. What matters is what the dispute reveals: a system with functioning governance mechanisms would have had a forum in which this argument could have been resolved without primary legislation. The fact that it required an Act of Parliament to address a question about the boundaries of academic freedom – a question that any mature HE/state nexus should have the internal capacity to negotiate – is itself damning evidence of governance failure.

None of the actors within the system – not the state, not the sector, and not the students whose interests the system is supposed to serve – have access to transparent, enduring, and coherent justifications for their rights and duties within the HE/state nexus. Therefore there can be no usefully robust debate and subsequent agreement about who should be responsible for what, by what mechanisms they can legitimately undertake their responsibilities, what would constitute illegitimate activity, or what processes need to exist and be used to resolve the inevitable tensions about any of this.

Research: the exception proves the rule

One area where British higher education is genuinely world-leading is research. UK research output is cited 54 per cent more than the global average when adjusted for size and subject-mix; the UK’s impact-per-paper has been higher than the United States’ since 2007; and the proportion of UK papers co-authored with international researchers has doubled since the late 1990s. These are significant achievements.

To this point, I have not given much attention to research. In part, this is because it is not a control factor in Oates’ original framework, because it is not a common function of compulsory schools systems. But it is also because, aside from the fact that the British government persistently underfunds the work on this area it asks universities to do, it is the one area where, in control factors terms, the system has something approaching coherence.

Research is not managed through student choice and competition at all. Research funding in Britain is explicitly driven by direct government investment, channelled through systems built and staffed by research communities themselves. The Haldane principle – that those within academic disciplines are better placed to determine what ought to be funded than government ministers – has governed distribution of research funding since before the Second World War, and one of the few bright spots of HERA 2017 was its codification of this principle into law. While it is true that the government has insisted on more accountability for how this money is spent, largely framed around the Research Excellence Framework, this remains an expert-mediated, nuanced endeavour in which judgements directly shape funding flows. It is not a choice and competition system predicated on the decisions of those who have just left school. Funding, accountability, professional expertise, and governance are aligned and mutually reinforcing.

This is not an argument for untouched insulation: UKRI is explicitly tasked with coordinating the whole research ecosystem in the public interest, and nothing in the Haldane principle prevents it from reprofiling distribution according to national priorities. The current debates about challenge-led versus responsive-mode funding are themselves evidence of the system working as it should – through transparent negotiation between expert community and public interest, rather than through opaque market-like mechanisms.

A minority of the HE system is research active, and therefore benefiting from this coherence. But all of it is teaching-active, and tied into a system that has none of these things. The contrast is instructive – and damning.

Indeed, the very success of research has exacerbated the dysfunction in teaching. The composition of the HE workforce has shifted as teaching has increasingly been handed to non-research-active staff, often on casualised contracts. The number of academics on traditional teaching-and-research contracts has fallen significantly while overall student numbers have grown by more than 400,000. The incentive structure is clear: an institution’s reputation, its ability to recruit the best staff, and a significant portion of its income all flow from research performance. Teaching is what happens alongside the thing that actually matters. This is not a moral failing on the part of individual academics or institutions – it is a rational response to the incentives the system has created. A system that properly managed the control factors to produce a coherent system across research and teaching would produce different behaviour. The current one does not.

Consequently, both the sector and the government frequently undertake broad measures with unwarranted confidence in the legitimacy of their decisions, which in turn generates often fierce, even aggressive, responses from other actors – including students, but also the business community and other stakeholders within the system. In turn, this results in limited, sometimes negative, progress in reaching stated policy goals. When that happens, someone (often the government) tries again to get what they want, and the system takes another turn around the cycle of planned failure. This is precisely the pattern identified in Table 1.

Primary recommendation: a new comprehensive review

The English HE/state nexus is both under-theorised and over-active. Too little sense of who should do what and why – and who definitely should not – leading to a great deal of activity, and insufficient amounts of productive change.

This cannot be fixed by regulatory reform alone, nor by another funding review, nor by yet another set of conditions of registration. What is needed is a governance concordat – a transparent, negotiated settlement between the state, the sector, and students about who is responsible for what, by what mechanisms, with what limits, and with what processes for resolving disputes when they arise. Codified in statute, but capable of evolving through agreed mechanisms set up explicitly to address the inevitable tensions.

Such a concordat should be the first product of the comprehensive review this paper calls for. Government should commission a review to make recommendations on how the purposes, shape, structure, size and funding of post-18 education, including support for students, should develop to meet the needs of the United Kingdom over the next twenty years. That review must cover the entirety of post-18 education – higher education, further education, and in-work technical training – because the gravity well of HE means none of these can be fixed in isolation. It should adopt the control factors framework as its analytical structure, not as a prescription for what the answers should be, but as a guarantee that every factor will be considered and, crucially, that the interactions between factors will be examined. The single most important methodological commitment the review can make is that it will not recommend changes to any one factor without publishing its assessment of how that change will interact with every other factor.

The review must not be a funding review. Augar was a funding review that tried to be a system review and failed at both. Funding is one of fourteen factors. A commission that treats it as the only one will produce another sticking plaster. It must not be rushed – Dearing took two years, and this should take at least as long. Short-termism is part of the pathology the commission exists to cure. It must not be captured by the sector: the composition should include people from outside HE – from schools, from FE, from industry, from the professions, from student organisations, and from international comparators. And it must not produce a report that sits on a shelf: the terms of reference should require the government to respond formally to each recommendation within six months, with a public explanation for any recommendation it declines to adopt.

Interim recommendations

However, given that the recommended length of time would be beyond the period of this Parliament, government should also take action now to ensure that the system is sufficiently healthy that the comprehensive review can do its work. Drawing on the analysis in this paper and considering constraints of public funding and legislative timetabling, we propose the following actions, with at least one recommendation per control factor. These measures are not solutions; they are the diagnostic groundwork and pre-emptive action to enhance the quality of the review and to ensure there is enough of a system left to review.

Curriculum content

1. The secretary of state should commission a report on the state of curriculum coherence across English HE – not to prescribe content, but to establish whether the system has a baseline understanding of what is being taught, at what level, in what sequence, and how it fits together. This is a diagnostic exercise, not an intervention.

Pedagogy

2. OfS should be directed to include, within its revised TEF framework, a requirement for institutions to describe their pedagogical approach and how they evaluate its effectiveness – not to prescribe how universities teach, but to make visible whether they have a considered view of how their students learn.

Assessment and qualifications / Accountability

3. Require all institutions to publish external examiner summary reports in a standardised, comparable format. This is already within OfS’s existing powers under the conditions of registration and was recommended by the 2015 HEFCE review, but has never been enforced.

4. Commission Ofqual, the examinations regulator, to produce a report on the validity and reliability of HE qualification assessment, drawing on comparisons with assessment regulation practice in other education sectors.

Institutional development

5. OfS should require all registered providers to publish an annual statement on how they invest in institutional leadership development and the dissemination of good practice in teaching – not prescribing what they do, but making visible whether they do anything at all.

Institutional forms and structures

6. Publish the evaluation of the Institutes of Technology programme. It has cost £300m of public money and no evaluation has been published. This is not a policy decision; it is an accountability failure the government can correct immediately.

7. DfE should issue guidance clarifying the respective roles of HE and FE in foundation-level provision, using existing powers under the post-16 white paper. Not legislation – guidance that OfS and Ofsted can reference in their regulatory activity.

Governance

8. The Office for Students should treat the CUC governance code as the core document for sector governance on a comply-or-explain basis, enforced through the conditions of registration. CUC should, in parallel, indicate that it will not accept as a member any Chair of a Board that does not demonstrably and publicly adhere to its code.

Professional development

9. Require all OfS-registered providers to publish, in a standardised format, what proportion of teaching contact hours are delivered by staff holding Advance HE fellowship or equivalent. This creates an accountability mechanism without mandating the qualification: institutions that have invested in teaching development can demonstrate it; those that have not are visible.

10. In parallel, Advance HE should be commissioned to publish an assessment of the value and applicability of the UKPSF to those entering HE teaching from outside the conventional academic route – industry, practice, clinical, or creative. A wider range of teaching entrants is welcome; but wider entry is not a reason to lower the expectation that those teaching know what they are doing.

Inspection

11. In finalising the TEF consultation, OfS should explicitly separate the compliance function (does this institution meet minimum thresholds?) from the enhancement function (how good is teaching here?). Using one mechanism for both confuses market signalling with regulatory enforcement.

12. Do not allow providers to charge different fees on the basis of TEF outcomes. The fee system is already unworkable, and the TEF is not a sufficiently calibrated instrument to bear the weight of such decisions.

Funding

13. Government should commit publicly to a multi-year fee trajectory so institutions can plan beyond a single spending review. This costs nothing; it is a communication decision. The refusal to signal direction is itself a policy choice that generates instability.

14. Direct OfS to publish an annual report on real-terms per-student funding, including the RAB charge trajectory, in a form accessible to the public. Transparency costs almost nothing and makes it harder for Treasury to adjust loan terms by stealth.

National frameworks / Selection and gatekeeping

15. UCAS and Discover Uni should clearly distinguish franchised provision from directly delivered provision in all public-facing materials, so that a prospective student can tell, before applying, who will actually teach them.

Information and guidance

16. Ringfence Uni Connect funding for a minimum of three years rather than confirming it annually. This does not require new money – it requires a commitment not to cut existing money.

Allied social measures

17. Ensure the student maintenance loan is reviewed against actual living costs annually, rather than being allowed to fall behind inflation by default. This is a Treasury decision, but the Secretary of State for Education can and should make the case publicly.

None of these recommendations requires primary legislation. All are achievable within the current parliament.

We should not shy from the tragedy of the current moment: thirty years of work has left us with a higher education system no better off and significantly less well governed than when we started. Ministers feel they can get nothing done. Universities and colleges feel nothing they do is ever right. Students feel exhausted and unsupported, struggling through a system they value that seems to little value them, despite the government attaching cash to each and every one of them.

As it stands, the system is unworkable, not merely not working. Until the full range of control factors which determine the success of an education system are each properly accounted for, and the interaction between them all made properly coherent, the system will never work.

Blame is widely shared and beside the point; what matters is that the system cannot self-correct. That the preferences of a small group of technocrats could reorient entirely the governing architecture of Britain’s fifth largest services export sector may well be a mistake, but it was not an accident. Higher education, indeed all of post-18, has been treated as a technical problem to be solved, not an essential component of a high-functioning constitutional democracy with a broad-based economy.

More than a compulsory schooling system, the need for higher education to be kept at some distance from the state makes it essential that both the principles and mechanics of its governance are understood by all those involved, and everyone can be held separately accountable for their role in the system, and collectively for the overall health of the system.

Politicians must no longer shy away from building powerful mechanisms for agreeing and enforcing arrangements on the form and function of post-18 education that can hold them accountable too. It is not fair to students to unwittingly enlist them to drive change to institutions who, while they doubtless need it, are unlikely to be able to make such change without a clear statement from the government about what is expected of them. Nor should we be surprised that institutions are unable to deliver what is asked when they have justified doubts that immediate resources will be provided, or that the wider policy framework will endure long enough for any strategy to come to fruition and for meaningful accountability to occur.

The post-Dearing project failed – not because it was implemented badly, although it was; not because it was underfunded, although it was; not because it was not clear what was desired of HE policymakers over the past 30 years, because that at least was repeated everywhere and by everyone. It failed because its mechanics were broken from the start; like a badly-wired plug, it operated, but the longer it did so, the more likely it would spark. The current financial state of the sector suggests that, somewhere, the fire has already begun. Government needs to act now to stop it spreading, and establish a proper review to fix the wiring for good. If not, institutions doing work the country desperately needs will face closure; local economies founded on the employment provided by the local university will founder; world-leading research will dissipate.

But more than anything else, our young people will suffer: paying costs their elders do not bear, enduring university experiences their elders did not have to face, experiencing labour market failures their elders would not tolerate.

English higher education has demonstrated, again and again and again, that it has the power to change lives, enhance communities, spread prosperity and stimulate transformation. But everywhere those benefits are achieved, it is in spite of the state/HE nexus, not because of it; contrary to the incentives that have been established, not in line with them; driven by the altruism of public service, not the advancement of private interest. We can have a system that makes those values its organising principles – it will not be easy, or immediate, and things will go wrong. Tensions must arise, that will need to be mediated openly and fairly.

But, thirty years on from the Dearing review, we must acknowledge that the system built to its specification has left us no better, indeed in many cases much worse, off than when we started. At every point where the ratchet was turned harder, in 2004, 2010, 2012, 2017, and 2024, the system never managed to deliver what its creators promised or the country needs. With the hard-won learning of the past three decades, we should start again: a new review, a new system, and a better chance for success.

The English student loan system is doomed. Not because it’s a bad deal – on paper, it’s remarkably generous. But those who built it did not factor in what it would feel like once the repayments started ramping up.

To a generation of graduates now entering their early 30s, watching 9 per cent of every paycheck disappear while their debt total somehow keeps growing, it feels oppressive. It feels like an incomprehensibly unfair deal they did not understand and now cannot escape. And a system that feels so suffocating to so many is fundamentally broken, no matter how many graphs about average graduate salaries we make.

Those defending the system say that, whatever graduates think about it, it is a bargain: the taxpayer will lend you fees (about £9k a year) plus living costs (around £5-10k a year), and you will pay nothing back until you earn above a certain level, stop paying if your income goes back below that number, and have whatever is left written off at some point near retirement.

No private bank would offer such generous terms. The intention was to permit 18 year olds to pursue their uni dreams without worrying if it’ll be financially beneficial – because if it isn’t, you’ll never pay back what you borrowed, and you’ll never have to pay your student loan back ahead of, say, buying food.

But it isn’t playing out like that: the frozen repayment threshold means that even those at an entry level of their profession can earn enough to have them paying back, but their debt is such that, unless they reach the very, very top earning brackets, they aren’t going to be clear of it before that retirement write-off. Worse, every year the Student Loans Company sends them an update, and for many, it shows they’re now further in debt than they were when they left university.

In one sense, that shouldn’t matter – if you were never going to pay the loan off before it was written off, that there is now more of it for you to never pay off is really more of a problem for the Treasury than for you.

But it doesn’t feel that way: it feels overwhelming, to lose nearly a tenth of your earnings to not even make a dent in your borrowing, especially as the cost of living gallops up around you. That you won’t be paying your student loans out of your pension isn’t, it turns out, much comfort.

Even the fact that this current crisis relates to only a subset of graduates (those who attended university between 2012 and 2022) doesn’t help. Partly that’s because the system in place since 2022 has its own problems, including a write-off date ten years later than other grads, but more because pointing out to the so-called “Plan 2” students that this isn’t happening to everyone just compounds their sense of unfairness. They know it isn’t happening to everyone: they are working with more senior colleagues who had exactly the same education experience but went to university 12 years (or even 12 months) earlier, and have already paid their loans off. Or at the next desk, there’s someone whose parents had the resources necessary to mean no money had to be borrowed in the first place.

Government ministers, clearly concerned that the system is too fragile to change, are defending the arrangement on its merits, but it’s a futile task. Actuarial neatness is no match for lived experience, and spreadsheets cannot rebut a widespread sense of injustice. The English higher education system, despite much criticism, really is world-leading, and it should be one in which social justice is done and is seen to be done. The student loan system now fails that second test.

The question, therefore, is not whether the system must change, but how and when. Delay carries costs. While recent debate has focused narrowly on fees and loans, the underlying fragility of university finances has not abated. Institutions are responding with short term retrenchment, eroding quality and reputation in ways that will be hard to reverse.

Labour should be deeply worried that the students who will be hit hardest by such panicked measures are those most disadvantaged already, who the party historically has done so much for. The sense that higher education leaves many worse off is already shaping choices further upstream, deterring those from poorer backgrounds from applying to the best course for them, and undermining decades of effort to widen participation.

But all young people are watching, and that means the impact is electoral too. On social media sites frequented by the voters of tomorrow, influencers with vast followings are raging about a system they compare to payday loans – that the comparison is unfair will be cold comfort to Labour, as young people lend their vote to populist forces who are more willing to assert they can and will fix such failures. The Greens, for example, are today capturing 45 per cent amongst young voters, up from 26 per cent four months ago.

A review of higher education funding now feels unavoidable. The choice for government is whether to lead it, or be forced into it by crisis. It can act deliberately, with time to balance graduate contributions, taxpayer support and institutional stability, and a message that it understands young people’s anger and is seeking to help.

Or it can wait until a succession of failing universities, mounting public anger and relentless media scrutiny make reform both urgent and chaotic. For all that there are no easy policy solutions, that isn’t a very hard choice at all.

Professor John Blake is the first Director of The Post-18 Project, the think tank for new thinking, ideas & policy solutions for post-18 education in the UK. He was previously Director for Fair Access and Participation at OfS and before that, he worked across education policy and practice in a variety of school trusts and social reform organisations, including Ark, Now Teach and the think tank Policy Exchange. He also works for the University of Salford as Professor of Social Innovation and Public Policy.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

“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.

“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.

“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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.