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It’s important to state at the outset that universities are not opposed to robust regulation. A sector with no regulatory oversight is unlikely to be a healthy one and none in the sector dispute the need for proportionate, evidence-based regulation to ensure all students have access to high-quality education. But with higher education one of the UK’s biggest international success stories, educating millions of students every year, the relationship between regulator and regulated must be a functional and healthy one. As of this moment, it is arguable whether this is the case.

Many are concerned that the OfS is not implementing a fully risk-based approach, that it is not genuinely independent and that it is failing to meet standards we would expect from the Regulators’ Code.

There is a definite sense of scope creep when it comes to the OfS, much of it stemming from ministerial pressure. Since its inception, the regulatory framework has expanded and looks to continue to swell with new measures on harassment and sexual misconduct, on free speech and growing activity on quality and standards. MillionPlus does not dispute the importance of these areas, but this represents an expansive growth in activity from the regulator in a short space for time. It is not clear that any other areas have been deprioritised, to account for these new priorities.

Not only does this become overly burdensome in the sheer amount of time university staff have to dedicate to ensure they are in compliance, but it has a pure cost implication too, with MillionPlus members facing an increase in their registration fees of over 10% this year. Meanwhile, with tuition fees frozen, inflation eats away at university’s principal income stream and a cost-of-living crisis continues to bite.

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