Our response to the international student levy technical consultation

The details of the International Student Levy were set out at the Autumn Budget. This consultation seeks views on the technical design of the levy, including:   

• clarity on the providers and students in scope 
• potential impacts on provider and student behaviour due to its design 
• administration including calculation of students, timing and payment of the levy 

The government intends the international student levy to fund the introduction of maintenance grants in academic year 2028/29. We welcome the government’s commitment to introduce maintenance grants, which we have called for over many years to support some of the most disadvantaged students to succeed. However, funding maintenance grants through an international student levy risks exacerbating existing financial vulnerabilities in the sector at a time when universities face the cumulative effect of other financial sustainability challenges.  

Given these risks to universities, and consequently their ability to deliver on key priorities for government and their wider communities, government must take the time to get its design and implementation of the international student levy right so that risks are mitigated. 

We call for a delay to the introduction of the levy until the government has: 

• Committed to an impact assessment of the levy including how price elasticity will affect international student demand and the subsequent impact on universities.   
• Confirmed it will invest excess levy funds on supporting students in higher education.   
• Legislated for the annual automatic domestic tuition fee uplift. 

In implementing the levy, we recommend that the government:  

• Assess the evidence by committing to regular reviews of the levy and the take up of grants. 
• Mitigate financial risk by increasing the levy-free allowance from 220 to 500 students and reducing the levy for institutions with over 20% of students from free school meals (FSM) backgrounds. 
• Legislate for sunset clause so that the levy does not become a permanent feature in a changeable market. 

• Exempt students from the levy whose participation: 
  • Directly supports UK Government policy objectives, including international mobility, research and partnership schemes. 
  • Generates limited or no tuition fee income for institutions. 
  • Conflicts with the levy policy intent. 

• Resolve a technically complex process including: 
  • Providing clarity and further consultation on data collection methods, future-proof the levy to adapt to future changes.  
  • More appropriately aligning payment with institutional cashflow. 
  • In addition, The Office for Students (OfS) must provide further information on how it will ensure transparent and robust data verification processes that mitigate the risk of errors and double counting students that attract the levy.

Our response to the international student levy technical consultation [PDF]