The Office for Students began a consultation process on its 2025-30 strategy back in December 2024. Alongside the usual opportunities for written responses there have been a series of “feedback events” promoted specifically to higher education provider staff, FE college staff, and students and student representatives held early in 2025.
In the past OfS has faced arguably justified criticism for failing to take sector feedback on proposals into account – but we should take heart that there are significant differences between what was originally proposed and what has just been finalised and published.
Graphic design is our passion
Most strikingly, we are presented with four new attitudes that we are told will “drive delivery of all our strategic goals in the interest of students” – to hammer the point home individual activities in the “roadmap” are labelled with coloured, hexagonal, markers where “a particular activity will exemplify certain attitudes”. We get:
- Ambitious for all students from all backgrounds (an upward arrow in a pink hexagon)
- Collaborative in pursuit of our priorities and in our stewardship of the sector (two stylised hands in the shape of a heart, yellow hexagon)
- Vigilant about safeguarding public money and student fees (A pound-sign on a teal hexagonal background)
- Vocal that higher education is a force for good, for individuals, communities and the country (a stylised face and soundwave on a purple hexagon)
Where things get potentially confusing is that the three broadly unchanged strategic goals – quality (tick, yellow circle), sector resilience (shield, blue circle), student experience and support (someone carrying an iPad, red circle) – are underpinned both by the attitude and the concept of “equality of opportunity” (teal ourobouros arrow). The only change at this conceptual level is that “the wider student interest” is characterised as “experience and support”. Don’t worry – the subsections of these are the same as in the consultations
Fundamentally, OfS’ design language is giving openness and transparency, with a side order of handholding through what amounts to a little bit of a grab-bag of a list of interventions. The list is pared down from the rather lengthy set of bullet points initially presented, and there are some notable changes.
Quality
In the quality section what has been added is an assurance that OfS will do this “in collaboration with students, institutions, and sector experts”, and a commitment to “celebrate and share examples of excellence wherever we find them”. These are of course balanced with the corresponding stick: “Where necessary, we will pursue investigation and enforcement, using the full range of our powers.” This comes alongside clarification that the new quality system would be build on, rather than alongside the TEF.
What is gone is the Quality Risk Register. An eminently sensible addition to the OfS armoury of risk registers, the vibes from the consultation were that providers were concerned that it might become another arm of regulation rather than a helpful tool for critical reflection
Also absent from the final strategy is any mention of exploring alignment with European quality standards, which featured in the consultation materials. Similarly, the consultation’s explicit commitment to bring transnational education into the integrated quality model has not been restated – it’s unclear whether this reflects a change in priority or simply different drafting choices.
Students
In the section on students, language about consumer rights is significantly softened, with much more on supporting students in understanding their rights and correspondingly less on seeking additional powers to intervene on these issues. Notably absent are the consultation’s specific commitments – the model student contract, plans for case-report publication, and reciprocal intelligence sharing. The roadmap leans heavily into general “empowerment” language rather than concrete regulatory tools. And, for some reason, language on working with the Office for the Independent Adjudicator has disappeared entirely.
A tweak to language clarifies that OfS are no longer keen to regulate around extra-curricular activity – there will be “non-regulatory” approaches however.
New here is a commitment to “highlight areas of concern or interest that may not be subject to direct regulation but which students tell us matter to them”. The idea here looks to be that OfS can support institutions to respond proactively working with sector agencies and other partners. It is pleasing to see a commitment to this kind of information sharing (I suspect this is where OIA has ended up) – though a commitment to continue to collect and publish data on the prevalence of sexual misconduct in the draft appears not to have made the final cut.
Resilience
The “navigation of an environment of increased financial and strategic risks” has been a key priority of OfS over most of the year since this strategy was published – and what’s welcome here is clearer drafting and a positive commitment to working with providers to improve planning for potential closures, and that OfS will “continue to work with the government to address the gaps in the system that mean that students cannot be adequately protected if their institution can no longer operate”.
Governance – yes, OfS will not only consider an enhanced focus, it will strengthen its oversight on governance. That’s strategic action right there. Also OfS will “work with government on legislative solutions that would stop the flow of public money when we [OfS, DfE, SLC] have concerns about its intended use.”
Also scaled back is the consultation’s programmatic approach to governance reform. Where the consultation linked governance capability explicitly to equality and experience outcomes, the final version frames this primarily as assurance and capability support rather than a reform agenda. The shift suggests OfS moving toward a lighter-touch, collaborative posture on governance rather than directive intervention.
Regulation
OfS will now “strive to deliver exemplary regulation”, and interestingly the language on data has shifted from securing “modern real-time data” to “embedding the principle collect once, use many times” and a pleasing promise to work with other regulators and agencies to avoid duplication.
Two other consultation commitments have been quietly downgraded. The explicit language on working with Skills England to develop a shared view of higher education’s role in meeting regional and national skills needs has disappeared – odd given the government’s focus on this agenda. And while the Teaching Excellence Framework remains present, the consultation’s push to make TEF “more routine and more widespread” has been cooled – the final version steps back from any commitments on cadence or coverage.
What’s missing within the text of the strategy, despite being in the consultation version, are the “I statements” – these are what Debbie McVitty characterised on Wonkhe as:
intended to describe what achieving its strategic objectives will look and feel like for students, institutions, taxpayers and employers in a clear and accessible way, and are weighted towards students, as the “primary beneficiaries” of the proposed strategy.
These have been published, but separately and with a few minor revisions. Quite what status they have is unclear:
The ‘I statements’ are a distillation of our objectives, as set out in our strategy. They are not regulatory tools. We will not track the performance of universities and colleges against them directly.
We can see some of the rationale for changes in the consultation response document. As I have have a paper coming to a committee next week that features the ‘I Statements’ – I turned to those first. There’s perhaps more change than meets the eye in there. Firstly we only have student statements – those aimed at institutions (such as ‘I understand the OfS’s regulatory priorities and requirements…’) taxpayers and employers are gone. Then there’s some quite large changes to language – moving sentiments from one statement to another and completely dropping the ‘I can choose from a range of… Read more »
The legal principle of legitimate expectations is being weakened, as it forms the core of the guidance from the CMA and the cornerstone of consumer contract law, if the universities were selling a product or a service.
What is the purpose of the OfS? Not then to ensure accountability in the use of the student loan system.
The TEF is a standardisation process using the analogy of statistical process control. It is destroying the idiosyncratic knowledge of academics and the distinctiveness of courses, degrees, faculties, and universities. Farewell to the jewels in our crown.