DfE’s desperation on equality impact-assessing student finance reaches a new low

There was a time when it came out on gov.uk alongside the headline announcement – but for a few years now it’s been appearing later and later.

Then tonight I spotted that it had been posted up on the Education (Student Fees, Awards, Support and Loan Repayments) (Amendment) Regulations 2026 page.

As usual, the assessment frames the inflationary uplift of 2.71 per cent to maximum maintenance loans as “maintaining students’ spending power at current levels”, without noticing that the household income threshold below which students qualify for maximum maintenance support has been frozen at £25,000 since 2007.

And if anyone thinks that inflation will be as low as 2.71 per cent come Q1 in 2027 (it’s a projection), I’d suggest turning on the news.

It also (again as usual) builds its headline analytical framing almost entirely around a single question – are people still enrolling? Since participation hasn’t collapsed, it concludes all is fine.

That framing treats the decision to enrol as the only outcome worth measuring. What happens to students once they are in higher education – whether they can afford to eat, whether they are forced to work so many hours that their studies suffer, whether they consider dropping out – is barely considered as a category of analysis.

Alongside the uplift, several forms of targeted support are being frozen at 2025/26 levels. Maximum Disabled Students’ Allowance, the Adult Dependants’ Grant, the Childcare Grant and the Parents’ Learning Allowance are all cut in real terms.

Where the EqIA does engage with the student experience data, it notes that in the HEPI/Advance HE Student Academic Experience Survey 2025, 68 per cent of students were in paid employment during term time in 2025, up from 56 per cent in 2024.

But then it presents a breakdown of reasons for working.

The proportion citing “supplementing living costs” fell from 74 per cent to 61 per cent, while those citing work experience and career exploration rose. The EqIA concludes that the sharp increase in employment:

…can be attributed more to an increase in students wishing to gain work experience and explore possible career paths than to help cover the costs of study.

Oh can it now. Good grief.

Set aside for a minute that it’s quoting a survey of undergraduates that includes all four nations, degree apprentices and international students. If DfE had bothered to commission any data of its own since 2021 it might have a more accurate picture, but we are where we are.

The bigger issue is that the EqIA shows the figures as a percentage of working students. When rebased as a percentage of all students – which is what you have to do if all students working has increased – the picture looks very different.

There’s been a 4 percentage points rise overall in students working to supplement living costs over two years. Students domiciled in England saw a larger increase, as did BAME students (nearly double the overall average). Students in POLAR4 quintile 1 areas – those with the lowest rates of participation in higher education – saw a 7pp increase, compared to +2.6pp for quintile 5. Disabled students rose +5.5pp.

Meanwhile some students are also working more for the work experience/career paths reasons DfE likes the look of – the combined figure rose from 28.2 per cent to 40.0 per cent over the period – but the increase was overwhelmingly concentrated among more advantaged groups.

Private school students saw a +15.2 percentage point increase compared to +6.3pp for state school students. Students who were not first in their family to attend university rose +15.3pp, compared to just +2.1pp for first-in-family students. Men rose +15.4pp versus +9.8pp for women. Polar 5 is higher than Polar 1. Poor students are doing food delivery for the rich students planning their next career move.

The picture is worse on the separate measure of students working to provide financial support to friends or family. Across all students, it rose from 11.0 per cent to 17.2 per cent over the three years – an increase of more than half. One in six full-time undergraduates is now working not just to cover their own costs but to support other people financially. Disabled students doing so rose from 11.5 per cent to almost 1 in 5.

There are other bits of SAES it could have noticed. 78 per cent of students report cost-of-living concerns have notably impacted their studies. Independent study hours have fallen from 14.5 per week in 2023 to 11.6 in 2025, with the SAES explicitly attributing this to the displacement effect of paid work. 29 per cent of students considered leaving their course in 2025, up from 25 per cent the previous year, with financial difficulties now the second most common reason. Cost of living overtook tuition fees as the primary driver of poor value-for-money perceptions back in 2023.

There really is no point in producing an equality impact assessment if the objective is to reach a predetermined conclusion. The Public Sector Equality Duty requires due regard to equality issues. Due regard means looking at the evidence – all of it, not just the parts that confirm what you have already decided to do.

If the department is spending money producing paperwork rather than analysis, the students whose interests it is supposed to be weighing are paying for it in hours they should be spending studying.