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20 December 2017

��۱���������ϴ�ȫ submissions to the Office for Students (OfS) consultations on regulatory framework, market entry and registration fees.

We welcome the principles on which the regulatory framework is based, namely risk-based, proportionate regulation in the interest of students.

The UK has a world-leading HE system and the Office for Students (OfS) has a key role to play in its future success for the benefit of students, communities and all UK citizens. 

We welcome the intention to introduce greater competition, innovation, and student choice. However, appropriate safeguards must be put in place to protect students. This means maintaining a robust baseline of quality.

Greater clarity is required about the criteria which providers must meet before being granted New Degree Awarding Powers (NDAPs) – as well as expectations of progress over the course of the probationary period. Without a clear threshold for access to NDAPs, it is difficult to see how decisions can be made consistently and confidence in the process maintained. 

We welcome the commitment in the Higher Education and Research Act 2017 for the Office for Students to operate in a proportionate and accountable manner, and to take a risk-based approach to regulation.

The proposals relating to registration fees do not deliver on this approach however. Larger providers in the “Approved” categories will face high fees whilst smaller providers and those in the registered basic category will pay a minimal fee, irrespective of the risk they pose.  

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