Our response to the Office for Students (OfS) consultation on OfS strategy for 2025 to 2030

As highlighted in our recent Blueprint for change, an effective regulatory framework and regulator in England is essential to support a thriving higher education and research sector and uphold public and political trust and confidence in our universities. 

We welcome that the strategy recognises the significant financial challenges facing the sector, the wider economic and global context in which universities are operating, and the public interest in sustaining higher education’s contribution to the UK's economic, social and cultural success.

Financial sustainability

• We support the OfS’s decision to place financial sustainability and sector resilience as central to its work over the next few years. This needs to be reflected in the detail of the strategy – the OfS needs to prioritise its work, be reasonable in its expectations, and minimise any additional regulatory costs. This includes consideration of what the OfS could reasonably stop doing or deprioritise, and consideration of where OfS can work with the sector to share good practice in areas that sit beyond its primary role.

Students and opportunity 

• Placing students more firmly at the heart of the strategy is a welcome development, but the broadly-framed ‘wider student interest’ risks evolving over time which could lead to a steady expansion of regulatory burden.
• We agree that equality of opportunity should run through everything the regulator does, but our view is that equality of opportunity should be included as a lead priority.  

Regulatory burden 

• We are concerned that regulatory burden is not more prominent in the strategy, and we maintain that new regulatory powers and requirements should only be introduced where the public benefits are clear, and costs justified. We recommend the OfS adopts a transparent consultative cost-benefit methodology to review current and proposed regulation. We welcome OfS’s commitment to reducing reliance on formal regulatory levers and working with the sector and relevant networks to share good practice in areas which may sit beyond its primary role, but the starting point must be the work already happening across the sector. 

Building trust

• If the strategy is to be successful, the OfS cannot dial back on the work it has been doing to build trust. This is particularly important if seeking to engage more with providers on their financial health. We would like to see this being more prominent in the strategy. 

Quality and guidelines

• We welcome the opportunity to revisit current quality arrangements and develop an integrated approach to quality with an increased focus on qualitative assessments of on-course experience and enhancement. We are committed to engaging constructively with the OfS and our members throughout 2025 to work towards this shared agenda. In particular, the suggestion to create a Quality Risk Register needs much greater elaboration and consideration.
• We strongly support the explicit commitment to consider realignment with the European Standards and Guidelines (ESG) for quality assessment.  

Risks and progress

• The OfS’s need for up-to-date financial data is valid in the context of its latest analysis of the sector’s financial health. However, this must be balanced against a provider’s financial risk profile and be done in a way that minimises additional burden. We are supportive of the OfS’s intention to address contingency planning for market exit and work with providers to ensure any plans that need to be developed are credible and deliverable, recognising the serious and far-reaching impact that any disorderly exit would have.
• The combination of objectives, goals, activities, and ‘I statements’ makes it unclear how the OfS will measure progress on its strategy. Including a strategic objective focused on the OfS as an organisation may be one way in which this can be addressed by increasing the focus on how the strategy will be delivered and monitored.
• Given that further announcements from government on higher education funding and reform are expected this year and there are aspects of the strategy which remain subject to legislative changes, we recommend the OfS considers their new strategy as interim and in the meantime focuses on areas where the regulatory powers already exist. 

Our response to the Office for Students ‘Consultation OfS strategy for 2025 to 2030’ (pdf)