UK’s stiffening compliance regime already having an impact on international student recruitment
- UK Visas and Immigration is reportedly “stepping up” its compliance audit activity of UK institutions, ahead of the anticipated implementation of more stringent compliance thresholds later this year
- Institutions are responding with a renewed focus on compliance, and, in some cases, by limiting or suspending admissions for fields of study and/or sending markets where they feel there is greater compliance risk
It would be fair to say that compliance is top of mind for international educators in the United Kingdom these days. The May 2025 immigration white paper from the UK government sets out a number of new requirements for UK institutions, including more stringent compliance thresholds. Those have yet to be implemented but they are coming soon. In the meantime, some universities are already adjusting their recruitment strategies, and most others are actively working to ensure they stay on the right side of key compliance benchmarks. In the process, compliance is ever more moving from the purview of an individual compliance officer or team within the institution to a much broader concern that reaches across all aspects of international recruitment.
The question hinges on the core immigration mechanisms for international students in the UK. In order to apply for a student visa, an international student must first obtain a Confirmation of Acceptance for Studies (CAS) document. Only a sponsor – that is, an educational institution licensed by the Home Office to sponsor international students for visas – may issue a CAS. In effect, the sponsor is vouching for the student-applicant and his/her eligibility to study in the UK.
That sponsor status places a number of obligations on the institution, and particularly that a sponsor must apply for a Basic Compliance Assessment (BCA) every 12 months. When UK Visas and Immigration (UKVI) carries out the BCA, it currently assesses the sponsor based on the following thresholds for three "core requirements":
- a visa refusal rate of less than 10%;
- an enrolment rate of at least 90%; and
- a course completion rate of at least 85%.
The linkage there is quite explicit: the institution is expected to carefully evaluate each applicant to determine that they are eligible for admission but also, once admitted, will have a high likelihood of following through to take up their spot in their intended programme of study and then go on to successfully complete that programme. In other words, the university or college's ability to continue to admit international students rests on its ability to recruit qualified, bona fide students that are committed to their intended programme of study.
Institutions that are found to have fallen outside of those benchmarks may be placed on a UKVI action plan. This is essentially a probationary mechanism, typically ranging from three to six months, that provides "a sponsor who has committed a breach, short of a serious breach, an opportunity to improve its processes in order to avoid any further breaches." UKVI adds that, "An action plan sets out specific actions that a sponsor must take by a given review date," pending the successful conclusion of which a sponsor may be taken off the action plan and carry on in good standing.
In the worst case, a sponsor found to be in more serious breach of compliance requirements, or who does not successfully progress through the action plan process, could have their sponsor license revoked by UKVI for up to two years.
Coming back to the white paper
When the immigration white paper was released in May, a lot of the initial reaction centred around the government's decision to curb post-study work rights for international students by reducing the term of the Graduate Route from 24 to 18 months.
In the months since, however, the more stringent compliance requirements set out in the white paper have come to be seen as its most impactful component. In short, the government intends to increase the compliance thresholds by 5% across the board so that the new core requirements for the BCA will be:
- a visa refusal rate of less than 5%;
- an enrolment rate of at least 95%; and
- a course completion rate of at least 90%.
The white paper also sets out a number of related measures, including the following.
- A new, public-facing Red-Amber-Green banding system indicating the BCA performance of each sponsor, "so that it is clear to them, the authorities and the public which institutions are achieving a high rate of compliance, and which are at risk of failing."
- Beyond the action plan, new measures for sponsors that are falling short of, or straying too close to, the BCA compliance thresholds, including "limits on the number of new international students they can recruit."
- A requirement that all sponsors that are engaged with education agents sign up to the Agent Quality Framework.
The Home Office has indicated that these new measures will be implemented for the 2025/26 academic year, beginning as early as September.
A more stringent approach
There is already some indication that UKVI has been applying a more rigorous approach in BCA assessments this year. Earlier this month, for example, the University of Essex and Glasgow Caledonian University were placed on action plans. They join the University of Central Lancashire, which has been on an action plan since December 2024, and a small group of additional education providers who have moved in and out of action plans through the first half of 2025.
Commenting on LinkedIn, Nous Group Director Nicholas Dillon said, "Looking at the two universities affected, you can see variants on the same story - a massive increase in in full-time [postgraduate taught] students from Pakistan, Nigeria, and India…These are far from the only universities with this narrative - though they are the ones caught up right now. And the change from a 10% to a 5% refusal rate will only make this a larger challenge."
In a related comment to Times Higher Education, Jonathan Hill, a senior manager with the immigration law firm Fragomen, said that UKVI had "stepped up" its audit activity this year. He added: “We are seeing quite a stringent view on these audits by UKVI and they’re taking quite a hard-line approach when it comes to how they’re assessing institutions, so that can also cause an action plan.”
How will this affect recruitment?
There is an element of risk management at the heart of the CAS-sponsor-compliance model. Indeed, these mechanisms rest a great deal of responsibility for student performance and student outcomes with the institution itself.
"The tougher BCA thresholds will require student sponsors to reassess their international student recruitment strategies in order to protect their BCA metrics," says immigration lawyer Anna Blackden.
Some institutions are already responding reducing or suspending recruiting activities in countries that are seen to be associated with higher risk. "Higher risk" in this sense being defined as markets where students are more likely to not follow through on their study plans or to complete their programmes of study – often for reasons relating to academic background, language skills, or financial difficulty.
Last month, for example, London Metropolitan University said that it would suspend admissions for Bangladeshi students. Deputy Vice-Chancellor Gary Davies has attributed the decision to high rates of visa refusals for Bangladeshi students in particular, which were putting the university's compliance at risk.
Other UK institutions have reportedly – although less publicly – made similar decisions to limit or suspend admissions from specific markets and/or for particular fields of study where there is seen to be undue compliance risk.
A related commentary from Universities UK International (UUKi) says of the heightened BCA thresholds: "UK universities welcome talented students from around the world. These changes will help prevent abuse of the visa system by non-genuine actors. Agents have a very important role to play in supporting visa compliance and universities will continue to work closely with their agents to make sure their processes are as effective as possible.
UUKi will work closely with UK universities and the Home Office on rolling out a phased approach to implementing these tightened BCA thresholds, and on what constitutes each of the red-amber-green bands. These measures will not require rules changes but rather updates to sponsorship guidance for institutions recruiting international students."
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