The OfS has published a new strategy outlining its approach to risk-based regulation. In a separate “roadmap” document, the regulator explains its main areas of work to deliver those objectives. In the course of developing the strategy it has gathered the views of students, institutions, and other stakeholders through a public consultation and feedback events. While the new strategy will directly affect English institutions only, elements of it may influence the future direction of regulatory HE policy elsewhere in the UK.
The new strategy and roadmap can be found at: The OfS strategy 2025 to 2030 – Office for Students
At-a-glance:
- The OfS will focus on three priority areas – quality; student experience and support; and sector resilience – while setting out four “attitudes” to guide its approach: ambitious, vigilant, collaborative and vocal. Challenges identified in the strategy document include universities with financial deficits, sexual harassment on campus, student mental health, poor value courses, the rise in students undertaking part-time work and the regional HE participation gap (p1 and p3 Strategy)
- The OfS reiterated its commitment to intervene where there are concerns that public money is not being used as intended, while also ensuring that in return for their investment of time, money and hard work, students benefit from high quality higher education experiences (p8 Strategy)
- A “strengthened” focus on governance will see the OfS working with institutions and sector agencies to identify and address barriers to strengthened governance more broadly. The OfS warns of “swift action wherever management and governance issues arise”. Should institutions fail to strengthen their governance sufficiently, the OfS will consider regulatory intervention (p8 Strategy, p11 Roadmap)
- Building on the Teaching Excellence Framework (TEF), the OfS will develop an integrated approach to quality assessment that drives continuous improvement. Assessments will continue to hold institutions to account for the experiences and outcomes of students from disadvantaged backgrounds and underrepresented groups (p5 Roadmap)
- The OfS will report on the outcomes of free speech complaints to safeguard the robust exchange of ideas that underpins a high quality education (p5 Roadmap)
- Institutions are expected to leverage regional partnerships in the development and execution of evidence-led plans that support access and participation (p6 Roadmap)
- Institutions are expected to develop and execute evidence-led plans to support students from all backgrounds and to evaluate the impact of their interventions (p8 Roadmap)
- Regulation to prevent harassment and sexual misconduct is aimed at ensuring institutions respond effectively when incidents occur (p8 Roadmap)
- Universities involved in significant partnerships activity will face increased regulatory requirements (p11 Roadmap)
- The OfS will work with institutions to improve planning for potential closures. Institutions facing “a material risk of closure” will be required to have credible and deliverable plans to minimise disruption for students (p10 Roadmap)
Implications for governance:
The Office for Student’s new strategy and roadmap flow from its current assessment of the risks and opportunities likely to shape the higher education sector over the coming years.
It warns that many institutions are facing financial challenges and may need to consider major changes to their operating models to prevent financial risks from crystalising. The decline in the real-terms value of income from UK students and increased reliance on fee income from international students, together with inflationary and economic pressures, have created complex challenges for institutions to navigate that are unlikely to abate in the short term, it says.
The 10-page document outlines how the regulator plans to protect students’ interests within that context, taking into account the policy direction set out in the Post-16 Education and Skills white paper.
Governing boards will note the frequent mentions in the strategy and the roadmap of a “strengthened” focus on governance. The regulator warns that as risk in the operating environment increases, institutions will need “different capabilities” to manage the challenging circumstances they face and that “effective leadership is essential to the responsible stewardship of public funding in the interests of students and taxpayers”.
There are few details of what this focus will practically entail however, beyond saying that the aim is for all institutions to have the effective governance needed to navigate increased financial and strategic risk successfully, and that “strengthened oversight of governance” will concentrate monitoring and compliance activity where risks are most acute.
Swift action is promised “wherever management and governance issues arise” and the roadmap warns that should institutions fail to strengthen their governance sufficiently, the OfS will consider intervening – although it does not indicate how.
In light of this focus, the Committee of University Chairs (CUC) is undertaking a refresh of the Higher Education Code of Governance and governors can contribute to a consultation which closes on 28 November.
A main area of work in the OfS strategy will be the development of a new quality assessment regime that “builds on” the Teaching Excellence Framework (TEF). A consultation on the principles, scope and structure of a revised system runs until 11 December. A second consultation is planned in Autumn 2026 and will look at how the new system would work in detail.
Equality is also a focus, with a wish to see evidence-led interventions. Institutions are expected to “leverage regional partnerships” in support of access and participation. Franchise partnerships, however, will come under more regulatory scrutiny, with interventions where there are concerns that public money is being misused.
Plans in the strategy to report on the outcomes of free speech complaints could present a reputational risk to institutions. In a speech in October, Arif Ahmed, OfS director for freedom of speech and academic freedom, highlighted three areas of particular concern: compelled speech, such as mandatory EDI commitments in academic job posts; foreign interference; and contractual obligations on staff that ban criticism of the institution.
Given the intense financial pressures on the sector, the need for planning for potential closures is also an OfS priority. It wants to see a “normalising” of conversations about preparedness and for those institutions most at risk to have credible roadmaps which protect students’ interests.
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