Does Wales have a higher education system in Wales or for Wales?
On Tuesday evening, Dylan Jones-Evans, one of the more outspoken critics of Welsh higher education’s current trajectory will ask a London audience that question.
It’s being held at the Honourable Society of Cymmrodorion, a London-Welsh learned society that has been hosting discussions on Welsh affairs since 1751 – and tickets are still going as I type.
The question is one that’s been sharpening since the Welsh Government published its five challenges consultation in January.
But those hoping the government’s own evidence base might settle the argument before the Senedd dissolves will find that two new publications – reports forming the core of the Diamond student finance reforms evaluation – leave plenty unresolved.
The first one – Barriers to higher education in Wales: evidence review – is a literature review synthesising recent Welsh and UK research on what prevents people from entering or progressing in higher education.
The second – Research to inform the evaluation of the Diamond Reforms to student finance in Wales – is a substantial primary research report by OB3 Research in collaboration with Miller Research, drawing on surveys of 880 Year 12 and 13 learners and 811 part-time and postgraduate HE students, focus groups with learners, parents, and current students, and interviews with ten higher education providers and stakeholder organisations.
They do different things. The barriers review is the context – inequality, attainment gaps, cost of living, mental health, the changing labour market. The evaluation research asks how the Diamond system is actually experienced by the people inside it, and whether the three objectives it was designed to deliver – widening access, strengthening part-time provision, and strengthening postgraduate provision – have been met.
Together, they are supposed to tell us whether Diamond is working. That may depend on what you mean, and who’s asking.
At first sight
The evaluation report is the more important of the two, and it contains useful primary data that has been missing thus far. Five findings jump out.
The first is that part-time provision is Diamond’s clearest success. Wales now has the highest proportion of part-time undergraduate entrants of any UK nation – between 36 and 40 per cent of all Welsh-domiciled undergraduates since 2016-17, compared to 16 to 18 per cent in England.
The Open University in Wales saw its undergraduate headcount rise from 7,206 in 2017-18 to 15,613 by 2024-25. Widening access students at the OU – those in the bottom two quintiles of the Welsh Index of Multiple Deprivation – increased by 168 per cent and now account for 54 per cent of new undergraduate registrations.
The OU’s written evidence is unequivocal – the reforms “have enabled thousands more students, especially those from some of Wales’ most deprived communities, to expand their horizons.”
Forty-two per cent of their students lack traditional entry qualifications, 29 per cent are disabled, 15 per cent have formal carer status, and 48 per cent live in Wales’s most deprived areas. This is a policy achievement that complicates any simple narrative that Diamond “didn’t work.”
The second is that prospective students are anxious about cost but poorly informed about what they’re entitled to. Among Year 12 and 13 learners planning to attend university, only 10 per cent felt they understood student finance “very well” and 21 per cent said “not particularly well” or worse. Among those undecided or not planning to go, 60 per cent did not understand student finance well. Learners described the system as “blowing my mind” and parents from lower-income households found it “overwhelming.”
After seven years of implementation, the people Diamond was designed to help often don’t understand what they’re entitled to. If prospective students from lower-income backgrounds are making decisions based on misperceptions of cost and debt, the barriers are informational as much as financial.
The report’s first recommendation – that Welsh Government improve awareness of student finance – is well-evidenced but understated. If 60 per cent of undecided learners don’t understand the system, it may not be a communications problem. It is a design problem.
A vision of ecstasy
The part-time funding structure contains an inequity that students have noticed. A student studying 120 credits per year at the Open University receives about £4,500 in maintenance – because OU courses are classified as part-time regardless of credit intensity. A student studying the same 120 credits full-time at another university receives approximately £12,345.
Focus group participants raised this directly, with one observing that “when you drop to 60 credits, you get roughly £3,000 – getting 60 credits will take longer but over time you’ll end up getting more funding.” The implication is that some students are gaming the system by taking fewer modules per year to receive more total funding over the course.
Meanwhile, postgraduate students are struggling with a single-loan structure that doesn’t work. The postgraduate taught master’s support – a single loan of £19,255 for 2025-26 covering both tuition and living costs – leaves many students unable to cover basics after paying fees.
Around a third of full-time taught master’s students reported being worried about not having enough food, and 31 per cent said their support didn’t cover costs “by a lot.” Fifty-one per cent also worked in paid employment, with 35 per cent of those working 18 or more hours per week. The report’s fifth recommendation – exploring separate tuition and maintenance funding mirroring the undergraduate system – is well supported by the evidence.
The other notable finding is that Diamond was only half-implemented. The HE sector’s core message in Chapter 10 is that the reforms changed student support but did not deliver the expected uplift in institutional funding.
Universities Wales reported that if the Diamond reforms’ assumptions on inflation had been applied, Medr funding should reach at least £427 million by 2025-26. Current funding is reported at £198 million – less than half.
The sector describes itself as under pressure to reduce costs and make redundancies, with limited capacity to deliver on Welsh Government objectives. This is the finding that will dominate institutional lobbying in the election campaign, and it reframes the entire evaluation – if Diamond was designed as a system-level reform but only the student support component was implemented, judging the whole initiative by participation outcomes alone is, at best, incomplete.
Find light in the beautiful sea
The companion barriers review is a competent but cautious literature review that largely restates known findings. Its core argument – that barriers to higher education in Wales are layered and structural, rooted in poverty, prior attainment, geography, and an increasingly outdated delivery model – is important but well established.
The FSM data is stark – learners eligible for free school meals are less than half as likely to enter HE (19 per cent versus 43 per cent) and the gap in GCSE results between disadvantaged and other pupils in Wales is equivalent to 22 to 23 months of educational progress, compared to 18 months in England. Welsh boys have the lowest HE participation rates across all UK nations.
What makes the review analytically interesting is the tension it creates with the evaluation research. Wales offers the most generous student maintenance support in the UK, yet has the lowest 18-year-old participation rate at 29.2 per cent against 36.3 per cent across the UK.
The review notes this “paradox” – originally identified by the Senedd – but does not resolve it. The answer, as the evaluation research implies, is that the binding constraint on 18-year-old participation is the Level 3 pipeline, not student finance.
The barriers review traces this carefully: the proportion of young people progressing to AS levels fell from 52 per cent in 2017-18 to 49 per cent in 2024-25, fewer Welsh pupils take A-levels than elsewhere in the UK, and the shift from school sixth forms to FE colleges is channelling more learners into lower-level vocational routes.
But it’s where the framing matters. If Diamond is judged primarily on 18-year-old participation rates – as the barriers review’s structure implicitly encourages – it will look like it failed, because the constraint it faces sits upstream of the problem it was designed to solve. If it is judged on the quality of participation it enables and on part-time and mature access, the picture is very different.
Eye to eye
What I’m getting at is that most conspicuous feature of these publications is what they omit – and there are significant enough to shape how the evidence base is received.
The 2021-22 Student Income and Expenditure Survey – the most recent joint exercise covering students from both Wales and England – showed that full-time Welsh students had mean commercial credit of £694 compared to £3,989 for English students, mean overdraft borrowing of £179 compared to £983, and mean arrears of £120 compared to £969. The median figures were zero across all three categories for Welsh students.
These are not student loan differences repayable on an income-contingent basis – these are debts to banks, credit card companies and landlords that follow graduates regardless of earnings. It’s the strongest piece of evidence that Diamond’s progressive universalism is working as designed, and it appears in neither report.
The evaluation research also explicitly excludes full-time undergraduate students – the largest cohort in the system. This was a scoping decision (the evaluation focuses on widening access, part-time, and postgraduate provision) but it means nobody in the evaluation is capturing the experience of the 20,000-plus full-time Welsh-domiciled undergraduates actually living with the Diamond system day to day.
The Year 12 and 13 data captures intentions and anxieties. The part-time and postgraduate data captures experience. The mainstream full-time experience is a gap.
Shine bright tonight
Both reports land in a pre-election context where the incoming government will need to make decisions about the future of the Diamond system quickly. The question is which narrative it establishes.
If the frame is “Diamond hasn’t increased 18-year-old participation,” the path of least resistance for an incoming government is to follow England’s lead toward less generous, more heavily means-tested support – or to redirect student finance spending toward the Level 3 pipeline. The evaluation research provides ammo for this reading – most universities could not give direct evidence that the reforms increased entry from under-represented groups, the 18-year-old entry rate is at its lowest since 2016, and the gap with England stands at a record 7 percentage points.
If the frame is “Diamond created a system where students can afford to actually be students, where commercial debt is far lower, where part-time participation has doubled, and where the quality of the experience is measurably better,” the policy response looks different – protect and restore the progressive architecture through threshold uprating, address the OU funding inequity, fix the postgraduate single-loan structure, and tackle the Level 3 pipeline as a separate problem requiring separate investment.
The evidence base supports the second frame more strongly than the first. But the evidence that makes the strongest case – the SIES comparative data, the NSS satisfaction results (Welsh universities exceeding UK averages across all question themes in 2025), the SAES data showing Welsh students less likely to work during term time and more likely to say their experience exceeded expectations – sits outside these publications entirely.
The evaluation research itself seems to acknowledge this tension. Its eighth and final recommendation calls for the scope of the evaluation to be broadened beyond the three objectives currently under consideration, noting “a need to revisit HE funding arrangements and tackle the widening participation gap between Wales and the rest of the UK through a broader systems level approach.”
The researchers are, in effect, telling the government that the questions they were asked to answer are too narrow to assess whether Diamond is working.
The danger is that, on reflection, the evaluation’s narrow scope creates a verdict by omission. Diamond’s best evidence – on commercial debt, on the quality of participation, on part-time access – either sits outside these reports or is buried in sectoral data that the publications do not foreground. The worst evidence – the 18-year-old participation decline – dominates the framing but is driven by constraints that student finance was never designed to address.
