The Department for Education (DfE) has published a statement of expectations on student accommodation.
This was a key promise in the Skills White Paper, which noted that rising rents and accommodation shortages are making higher education less accessible, especially for students from low-income backgrounds.
It also noted that average rents nearly consume the maximum student loan in England and exceed it in London, affecting where students study and whether they can enrol or complete their course.
The promise was therefore to work with the sector and others so that the supply of student accommodation meets demand, including increasing the supply of affordable accommodation where that is needed.
The government also committed to working with the sector to draft a “statement of expectations” on accommodation, which it said would call on providers to work strategically with their local authorities to ensure there is adequate accommodation for the individuals they recruit.
There’s no sign of any government work with the sector and others “so that the supply of student accommodation meets demand” – this is very much the government’s expectations of everyone else.
And the statement itself runs to a grand total of… 293 words.
Providers are to consider the supply and affordability of accommodation against anticipated intakes, across all years of study and at least five years ahead, engaging the local planning authority “on need” and factoring in the Renters’ Rights Act.
Where a shortfall looms they should form or join partnerships with other providers and planning authorities, explore private renting, new builds, refurbishments, and repurposing, and involve developers and landlords “as appropriate”.
They should, it says, be clear and accurate about any accommodation guarantee, and take “reasonable steps” to prioritise care leavers, care-experienced students, and estranged students, including with access outside term time.
And that’s yet lot. There’s no definition of affordability and no link to the maintenance loan. There’s nothing on quality, safety, contracts, deposits, or charges, and no route to redress.
International students, commuters, postgraduates with families, and clearing entrants are nowhere to be seen. Nothing has to be published, nobody checks anything, there’s no review date, and the Office for Students doesn’t get a mention – more than seven years after the Augar review asked it to examine the cost of student accommodation and get a grip on data about rents and profits, and more than three years after OfS’ own equality of opportunity risk register identified suitable accommodation as a capacity risk.
For crying out loud. Universities UK’s 2023 briefing for senior leaders managed to run to over 3,000 words – with 23 questions for senior teams and case studies. At the time I worried about basic demand assessment being framed as mere “considerations”, but it was nevertheless a great first stab at a condition of registration.
DfE has kept the skeleton (plan ahead, talk to the council, be honest about guarantees) and binned off the flesh. UUK told universities which data to use, from HESA term-time addresses and council tax exemptions to HMO licence registers. It asked them to plan scenarios for international recruitment, dependants, and graduate route students, to decide whether they are the housing provider of last resort, to offer travel grants when students can’t be housed nearby, to secure a range of price points, and to work with their SU on advice. DfE doesn’t bother.
It’s weaker than what a Conservative minister was saying six years ago. In January 2020 Chris Skidmore told the sector that premium prices for accessible rooms were “tantamount to a tax on disability”, and that he wanted “the steep trajectory of rent rises” to end. And it looks thin next to Europe – in the Netherlands, for example, there’s a national monitor of new student homes every year, and in Ireland, a new strategy puts a number (42,000 beds by 2035) on what it needs.
It’s pathetic even by the standards of statements of expectations. When the Home Office published its statement of expectations on violence against women and girls in 2016, it came with a service transformation fund and a two-year fund for refuges, and the 2020 statement on supported housing arrived with £3 million for pilots in five areas and was followed three years later by legislation. Even OfS’ own statement of expectations on harassment and sexual misconduct was independently evaluated and then hardened into a condition of registration. This one comes with no money, no pilots, no evaluation, and no sense of what happens if nobody bothers.
It doesn’t even get the problem right. Local planners have managed to define affordable student housing – the London Plan pegs it to 55 per cent of the maximum loan in the capital – but DfE hasn’t, and its obsession with supply meeting demand misses that Nottingham has 3,541 empty purpose-built beds while Cushman and Wakefield reckons 17 per cent of beds now cost more than the maximum maintenance loan, against under 4 per cent a decade ago.
Its information clause, confined to first year guarantees, asks for less than consumer law already does, given the CMA has long treated accommodation availability as material information for applicants. And it says nothing at all about the part of the market universities actually control – their own halls, where students can still be tied into fixed terms and asked for rent upfront, and where the codes that exempt them from the Renters’ Rights Act don’t match Awaab’s Law.
It would be generous to call it lazy. in June its own regulator published research on first years’ accommodation finding that 61 per cent had hit at least one quality problem, almost two in five had been given inaccurate information before they moved in, three in four had borrowed from family or friends to cover their costs, and 44 per cent had taken out loans on top of their student finance.
The telling bit is who the document gives a job to. Planning authorities are to be engaged. Developers and landlords are to be involved. Students get no role at all – they appear as “intakes”, as demand to be forecast, or as vulnerable groups to be prioritised. And the only mention of the Act likely to significantly affect supply treats it as something to be planned around. By universities.
It’s a design choice – a statement of expectations with no expectations of government, no interest in what students think, and none of the things a department brings to a problem it actually wants solved.
There’s no monitoring – Augar wanted OfS gathering consistent data on costs, rents, profits, and quality, and the new private rented sector database could flag student lets tomorrow, but instead providers are asked to forecast demand five years ahead for plans that nobody will ever see. There’s no action either – the one lever DfE holds outright, the maintenance package, doesn’t get a mention, and OfS isn’t asked to do anything at all.
And nothing changes the incentives. Universities without the local space will carry on hoovering, all while the OfS research found clearing and insurance entrants squeezed out of university stock – the statement only asks providers to be “clear and accurate” about the conditions on their guarantees, which blesses leaving those students out as long as it’s written down.
And there’s no analysis – the financial analysis of PBSA operators’ profits that Augar called for has never been commissioned, ministers had published no assessment of what the Renters’ Rights Act would do to student supply by the time it passed, and when Diana Johnson asked about Nottingham-style partnerships in 2022, the answer was that neither DfE nor DLUHC had made any assessment.
DfE knows there are huge problems – mainly caused by a market whose volatility is now driving rents up for everyone in some cities while leaving ghost blocks in others. If it really thinks its statement will fix those problems, it’s stupid. But because I suspect it knows all too well that its 300 words won’t make a scrap of difference, it’s hard to conclude that it views students with anything other than raw contempt.