Back at the start of the year I was waiting (along with our news editor Michael Salmon) for large universities to publish their annual accounts.

Quite a few came in late – something that can be ascribed both to the perilous state of university finances and the capacity of the limited number of independent public sector specialist auditors (who sign off university accounts in the gaps between auditing local councils and NHS trusts).

So if you wanted to sharpen up institutional submissions to the regulator (which happen in parallel to the statutory external publications) you’d fix university finances, or if that seemed like hard work for an overstretched regulator you would invest in auditor capacity and provide advice and support as needed..

But, cleaving to its usual approach of spotting sector problems and adding pressure to make them somehow worse, OfS has issued an F3 notice that changes that formerly iterative process into a single condition-of-registration-backed deadline.

Up until 2024, providers made an initial submission of data 4 months after the end of their financial year which could then be checked and verified. All queries should have been addressed and resolved, and additional statements submitted, five months after the end of the year – before the return was signed off two weeks later.

Why all these deadlines? Well, OfS uses the annual financial returns (AFR) – which extend far beyond what eventually turns up on HESA into projections for three additional years – in regulation. It needs to be sure the figures are accurate, and it is aware that circumstances may change as the external audit processes extends and plans for future years change as a result.

As of 2025, there is a single deadline – five months after the financial year end. At this point a finalised and valid AFR (along with all the rest of the required files) needs to be submitted, validated, and signed off. OfS will then start checking, and errors in your submission could now lead to non-compliance with condition F3 and all of the consequences that entails.

OfS has supposedly diverted all available resources to supporting financially struggling providers – pausing other vital work (registering providers, figuring out how to regulate provision funded via the Lifelong Learning Entitlement) in the process. So why it wants make submitting financial data more stressful and support the process less at this point is something of a mystery.

One other thing the regulators could do is to make accessing the small amounts of available capital funding straightforward. This year OfS has £84m of capital funding to allocate, of which £3.5m will go to Jisc for national services and the remainder will be allocated to providers: £72.25m via a competition and £7.75m via a formula.

Yes – you read that right – providers are being asked to prepare bids in order to receive a share of £72.75m for a single financial year – with funding spent in-year. A single bid is eligible per provider, meaning most larger providers will need to run an additional internal competition to determine which will be “their” bid. And the competition is very much looking for “shovel ready” projects, so all of the pre-emptive scoping and planning work will need to be done (at a cost to the provider) before submission. All this for a maximum of £2.5m – which can be withdrawn if the provider has to rethink the project due to… well, the kinds of fluctuating costs and instability that are everywhere.

So even if you have a small library refurbishment desperately needed and ready to go (maybe you had to cancel a larger project so the plans are there) you still need to meet the OfS criteria. Will it address:

• The needs of employers (as identified in local skills improvement plans which up until very recently haven’t had anything to do with universities)?
• Skills England’s initial priorities in the developing industrial strategy (a finalised version of which is due imminently) across ten pretty tightly defined subject areas.

Now, we can’t entirely blame OfS here – this is what DfE specified. Despite the huge amounts of capital sloshing around in the spending review, the single year settlement in the grant letter was unhelpfully low – meaning that a formula-based allocation would barely touch the sides in most universities (there is still a formula-based allocation: if you don’t want to bid you get a share of £7.75m so that spool of cat-5 ethernet cable of your dreams could still be yours). DfE even advised against funding competitions other than this one unless special permission was granted.

It’s not that universities don’t need capital – they do – it’s that there comes a point when the costs are not worth the possible results. And it’s not that universities don’t know how to prepare accounts and forecasts: it’s just that, right now, it isn’t the easiest to do these things for questionable benefit and under worsening conditions.