If Policy Exchange’s new report – Education not immigration: reforming the UK’s international student regime – was really a serious stab at influencing current student visa policy, there’s no reason it couldn’t have come out in the run-up to the immigration white paper in May.

The headline recommendation of scrapping the graduate route, and the associated evidence marshalled in its support, rehearses familiar ground from last year’s MAC review, and will be of no surprise to anyone who remembers a similar case being made by the Centre for Policy Studies last May, or who follows shadow education minister Neil O’Brien’s pronouncements on post-study work (indeed, he is speaking at the launch event later today).

The immigration white paper has already announced Labour’s decision – a reduction for most international students down to eighteen months – even if the exact details about when and how this will kick in have still not been published. So really, aside from getting some press attention, you’re left with the feeling that the think tank is hoping to feed in to future Conservative (or Reform) policy rather than properly speak to the current government.

If anything, it’s markedly more cynical to be using the same claims in summer 2025 that appeared in the run-up to the MAC review – for example, that more than 140,000 main applicants and dependants secured graduate visas in 2023, skating over the fact that dependant figures on the route will dwindle away as a result of already enacted policies. Or citing stats on the numbers moving from study to care worker visas between June 2022 and June 2023, even though that phenomenon has already dissipated and the care worker visa is being abolished.

But when you’re seeking to make a simple and straightforward argument that the UK higher education sector “must return to the business of selling education, not immigration,” these details don’t really matter – it’s about tapping in to public and policymaker perceptions.

Nuts and bolts

There are, however, some new ideas in the report – from the spread of “minimalist” and “maximalist” approaches to be picked from depending on your tastes, to the specifics on how the sector might be divided up into two groups of graduate route haves and have-nots (though the author’s preference is for the graduate route to be scrapped for all not on postgraduate research degrees – presumably they haven’t heard of the rumoured boom in MRes courses).

While restricting the graduate route to high tariff universities or those doing best in international rankings was bandied about during the MAC review process, Policy Exchange has helpfully included an appendix showing exactly who would be in and out (in the current year – it would inevitably change annually). And there’s an additional suggestion:

One possibility is to use the Research Excellence Framework, an evaluation of the research impact of higher education providers in the UK… As part of the REF assessment, a Grade Point Average (GPA) is calculated for each institution to classify the overall quality of research.

Now you can criticise this idea as having nothing to do with teaching and/or graduate outcomes. And you can criticise it for mistakenly assuming that a supposed GPA is actually part of the REF (though a quick search shows many universities have webpages trumpeting their own REF “scores” without making clear it’s not an official measure – you can see why Policy Exchange missed that point). But you can’t say it isn’t novel.

And it’s not all about the graduate route. The report picks up the controversies around growing numbers of student visa holders claiming asylum, but its recommendations here are not too distinct from what the government is already planning.

The potential levy on international fees also gets a mention – Policy Exchange’s suggestion is for a flat £1000 charge rather than a percentage tithe, which it says would raise slightly more cash and put more of the burden onto the low-cost courses which it wants to see fewer of anyway. It suggests that “top” universities could be exempted if required, and that a restructuring regime should be in place for the less prestigious universities that will face inevitable “economic endangerment”.

In some ways this is a helpful contribution to the ongoing horse-trading around a possible levy, for what it surfaces about the implementation challenges. The use of a percentage “tax” on institutions would indeed lead to those institutions charging higher fees forking over more – though this doesn’t necessarily translate to a higher cost, given that they would in many cases find it easier to raise sticker prices rather than swallow the losses, in partial compensation. As disruptive as it would be, DfE’s mooted approach is probably the least disruptive path – one that avoids needing to think about the shape of the HE system more broadly.

Plus the report’s suggestion that the Immigration Health Surcharge is a good model for a flat cash international student charge can serve as a reminder that, if DfE doesn’t find a way to eke money out of international students for its budget, the Home Office probably will – witness the Australian government’s just-implemented raising of visa fees to AU$2000.

A question of language

The other area the report homes in on as an attack line against current university recruitment practices is around English language standards. And while arguing for the abolition of the graduate route feels several months out of date, you can make a reasonable case that this is an area where a shoe is yet to drop.

Again, we get some shaky reasoning. One academic speaking to the BBC for a documentary becomes “an investigation by the BBC”, and refers only to English levels on one course. The Sunday Times’ belated exposé of franchising – which concerns students with UK residency – is the only example the think tank can muster to support its argument that agents are marketing courses to international students with low English proficiency. But both of these meagre datapoints do touch on real concerns shared by many within the sector.

The report draws on the recent Home Office student route evaluation surveys, of both providers and student visa holders, to help back up its argument that there is a problem with standards. It finds that only 38 per cent of students demonstrated language proficiency at CEFR level B2 via a Secure English Language Test (SELT) – but this is a tricky question to survey students on, and a similar percentage said they took a lower level SELT (presumably topped up with a pre-sessional or similar) or a provider’s own exam. The remaining 22 per cent gave a hodge podge of different answers or weren’t sure.

Similarly for the provider survey – Policy Exchange’s press release picks out the fact that “18% of universities that complete their own assessments claim no prospective student has ever failed their language tests.” But this represents seven out of only 40 institutional responses to a question (“what proportion of prospective students do not meet English language assessment standards?”) that is easy to misinterpret. A read-across to a supposed claim about students never failing is seriously ropey.

Strength of evidence aside, if you’re a journalist or policymaker looking for a citation to support your case that English language standards are an area of concern, you now have something to lean on.

The report makes a couple of plausible (and to the sector, probably quite scary) recommendations. First, raising the entry requirements for degree-level study to CEFR C1 (sometimes referred to as “advanced”) from the current B2 (“upper intermediate” or “vantage”). This is an idea that many teaching and working with students in the sector would probably be quite well-disposed towards – but on the flipside would move the UK out of step with competitor countries in a way that would likely be pretty disastrous to headline recruitment. And second:

The incentives for higher education providers to admit international students make them an inappropriate body to oversee language assessment. The right of universities to manage their own assessments should therefore be ended.

This is another sensitive subject. Earlier this year the Home Office began a review of English language self-assessment practices, driven – according to Universities UK International in a December 2024 sector update – by “growing concern around underlying reasons for reports of students being picked up at the border or entering UKHE with low levels of English.”

As is typical for anything run out of UKVI, there’s little being said publicly about how this review is progressing – universities are certainly keen to see no changes. Any shake-up in how institutions can certify English competency would be an enormous shift. But in the absence of a window into what’s going on, it’s hard not to feel – given how high-stakes and securitised all elements of international student policy are becoming – that this particular slice of sector autonomy in danger of becoming a low-hanging fruit for a future government, if not this one. Which would be a shame, as running bespoke language assessments suitable for a cohort’s context, when done right, is surely preferable to relying on off-the-shelf tests.

How to find out

It’s sometimes said that the higher education sector is reluctant to do much research on its own operations, and English language needs would be a perfect subject where it would be helpful to have better evidence – in its absence, anecdote and gut feelings prevail. The alternative is a future government picking up on ideas like Policy Exchange’s, of putting questions “on the impact of international students on domestic student experiences” into the National Student Survey. It would also be nice to properly dig into what international students themselves think, as the BBC File on Four report did in a basic way – many are often quite keen on higher levels across cohorts.

The same could be said for finding out what English language entry standards are really needed, in what contexts and how demonstrated, rather than relying on conveniently broad CEFR levels and rarely interrogated comparability with other countries.

One of the few bits of ongoing evaluation in this area that I’m aware of is being conducted by the British Council and partners. Its initial findings include some institutions tightening English language test requirements – after a general loosening during the pandemic – and a general sense of dissatisfaction around which tests are being offered and to what extent international students are well prepared for academic study.

While the contribution of international students to overall GDP is now pretty well established, there are a whole host of areas – as pinpointed by this report, for all its flaws – where the responses of the sector still aren’t cutting through. If anything, for a think tank seeking to spotlight international student “problems”, it’s a surprise that housing, rents, impact on local areas, and various other possible attack lines don’t get wheeled out.

And it’s probably for the best that they are not, as the rebuttals are largely struggling to land. A wider range of research evidence and a more open conversation couldn’t but help.