Complaints are going up and nobody knows why

The Office of the Independent Adjudicator (OIA) has published its 2025 Operating Report, and the big headline is that it received 4,234 complaints last year.

That’s the highest in its history, a 17 per cent increase on 2024, and the seventh consecutive year of rises.

It closed 3,950 of them, 8 per cent more than the year before, with an average time to close of 81 days – down from 125 days just two years ago.

It also exceeded all of its timeliness KPIs, settled 13 per cent of cases against a 10 per cent target, and had no cases over 12 months old, and unit cost held below £1,700 per case.

By any operational measure, the OIA is running a tighter ship than it has in years, and doing so while the tide keeps rising.

What the report doesn’t do is explain why complaints have risen by 17 per cent in a single year – or why they’ve been rising for seven years straight – after all, there hasn’t been a 17 per cent increase in students.

They’re going up, up, up, up, up, uuuuup

Something is driving sustained, accelerating growth in the number of students who feel they’ve been treated unfairly and want an independent body to say so.

Some of the growth may be awareness – SU advice services promoting their services, the OIA itself has invested in outreach, and more students are being told the service exists and supported to use it.

Some of it may be the consumer consciousness shift that’s been building since the pandemic, when fee strikes and group litigation normalised the idea that you could and should complain about what you’re getting for north of £9k a year (and much more if you’re international).

Some of it may be new categories of dispute that barely existed a decade ago – AI detection challenges, fitness to practise contestations, harassment cases generating complaints from both reporting and accused students.

And some of it, I suspect, is that internal complaints processes at providers under financial pressure are getting worse, not better – the student caseworkers and faculty office staff who handle complaints are exactly the roles that get cut in efficiency drives, which may mean slower responses, less empathetic engagement, and more students who feel unheard and escalate. But these are guesses.

Independent Adjudicator Helen Megarry explains it as follows:

the complexities of people’s higher education experience, especially those who are disabled, international or mature students is driving a consistent upward trend.

To be fair to the OIA, it has started two pieces of work that might eventually shed some light. It’s begun engaging with providers that generate high volumes of OIA complaints to explore what’s driving them, and separately with providers that rarely engage with the OIA at all – testing whether low complaint volumes reflect good practice or just poor awareness of rights.

The latter is an important question, because the real volume of unresolved grievance across the sector could be considerably higher than even the record numbers suggest.

There are other clues around.

Joining the dots

OfS-commissioned research published last November found that only 8 per cent of students had heard of the OIA, more than a third couldn’t identify a single external complaints route, and 36 per cent said the biggest barrier to complaining was doubt that it would make a difference.

Then in January, further OfS polling found that 83 per cent of students who’d noticed cost-cutting measures felt the experience they’d been promised had changed – larger classes, more online delivery, reduced support – with a quarter considering dropping out.

As I’ve argued across both, OfS has known about these dynamics since at least 2019, and real student protections remain perpetually on the horizon. The OIA, meanwhile, is presumably receiving the complaints that flow from exactly these failures – and is seeing record volumes as a result.

Then on disabled students, OfS’ research suggests students are succeeding despite rather than because of institutional support, fighting for reasonable adjustments rather than receiving them as a matter of course.

If the OIA is saying that disabled students make up 40 per cent of its caseload, students might wonder what the regulatory plan is demonstrates the learning from the casework.

For all the coordination referenced between the two bodies, neither body seems willing to connect the dots – that providers under financial pressure are cutting the things students were promised, that students don’t believe complaining will change anything, that providers don’t seem capable of delivering reasonable adjustments consistently, and that the small minority of students who do fight through to the OIA potentially represent the tip of a much larger iceberg of unresolved grievance.

And the rest

A few other bits in the report are worth pulling out.

The OIA’s work with SUMS Consulting on provider closure produced a report in July – “Putting students first: Managing the impact of higher education provider closure” – drawing on interviews with around 40 people including restructuring consultants, legal advisors, and student representatives.

The OIA is now explicitly pushing three options for students left without remedy after market exit: a dedicated fund, an insurance scheme, or legislative changes to prioritise students in insolvency proceedings.

It’s also been engaging with OfS to get early warning on providers at risk of closing quickly.

The Welsh expansion is significant too. It is preparing to extend into Welsh further education complaints as part of the tertiary integration, working with Medr on implementation timetabling.

And it continues to flag a gap it’s been highlighting for some time – that students studying for awards from Ofqual-regulated awarding organisations through OIA member providers don’t have access to independent redress.

There’s a single sentence about “supporting students to understand their behavioural contract with the OIA through updated policy” – which implies they’ve had enough trouble with complainant conduct to formalise something, though the report offers no further explanation.

And the Digital Markets, Competition and Consumers Act 2024 gets a passing mention and a note that the OIA achieved “fully compliant” in its CTSI audit as an approved ADR body.

One final thing not in the report – the OIA hasn’t updated its guideline amounts for “distress and inconvenience” awards for nine years now. £5000 would be worth just under £7,000 now, and so on.

Is Reading some sort of inflation-free freeport or something?