Our Response to the Consultation on OfS Strategy for 2025 to 2030

The Office for Students (OfS) consultation on its 2025–2030 strategy outlines its proposed priorities for the regulation of higher education in England over the next five years. The strategy sets out how the OfS intends to protect students’ interests, ensure financial sustainability in the sector, and promote quality and opportunity across higher education. Given the significant role the OfS plays in shaping the student experience, we welcome the opportunity to respond.

We have laid out a summary of our comments on the proposed strategy below:

1.  We welcome the student interest being centred within the strategy. We think this can be best achieved by including democratically elected students’ union representatives within OfS governance. We propose that this be achieved through the establishment of an advisory panel of elected students’ union representatives to ensure that student voices are effectively represented in regulatory decision-making, replacing the current model of a hand-picked student panel.  

2. The strategy acknowledges that student concern extends beyond teaching and learning, with the OfS’ own research into the student experience highlighting the non-academic features of higher education which play an important role in shaping students’ experiences.  We agree that these features are fundamental to the educational experience. We recommend the OfS recognise that these distinctive features, often delivered through students’ unions, and that institutions should endeavour to support these activities with appropriate funding and practical support.  

3. We support the OfS’ integration of equality of opportunity throughout their work. However, we are concerned that the commitment to “ensure that in the face of financial pressures, choice and opportunities for students from disadvantaged backgrounds and underrepresented groups continue to expand rather than reduce” lacks specificity and clear direction. The recognition that students face increasing financial pressures is commendable. We would like to see the OfS take a leading role in highlighting the needs of students and collaborating with universities and the Government to implement practical support that alleviate these pressures. Additionally, we believe the OfS should examine how these pressures manifest and address them at all levels of study.  

Students’ unions across England have also been instrumental in highlighting the increasing cost of living and addressing inequalities. With 94% of students across the Russell Group concerned about the cost of living crisis, the necessity of this work cannot be underestimated.

We would also like to see the OfS engage further with postgraduate and international students, ensuring that their needs are experiences are represented in regulatory frameworks, particularly within the proposed student interest committee. For example, postgraduate students often face inadequate funding and struggle with their sense of belonging and loneliness, while international students, who contribute significantly to the UK higher education sector, often encounter unique challenges, including visa restrictions, higher living costs, and sometimes disproportionately low levels of institutional support. Given the significant intersection between these two bodies of students, their voices should be embedded within the OfS’ work. This would ensure that the strategy accurately reflects the ‘diversity of the higher education sector’.  

4.  Acknowledging the financial challenges that the sector is currently facing, we support the OfS’ decision to prioritise financial sustainability and quality in the sector. We believe that the student interest, and student representatives, need to be central in a national conversation on the future of higher education funding. Students must also be active participants in discussions at an institution level where the OfS have identified a provider as financially unstable or high risk.  

The OfS should take a convening role to support universities to stabilise their finances in a way that does not increase the debt burden on students. The OfS should also work with universities to support high quality higher education provision across England, ensuring a regional balance of providers and a range of high-quality courses.

However, we are concerned that balancing both financial sustainability and quality may be challenging. Student representation must be built into processes when institutions and the regulator are addressing these tensions.  

5. The strategy rightly highlights the impact that “rising” accommodation costs are having on the student experience, with specific reference to the challenges that students from low-income backgrounds face in absorbing these costs. Given that accommodation is fundamental to the life of the majority of students at residential universities, we propose the inclusion of a condition of registration that requires all residential universities to provide appropriate, affordable, high-quality student accommodation. We believe that universities should not treat student housing as a commercial venture, but as an essential component of student success. 

6. As Russell Group students’ unions, our institutions represent nearly 60% of all postgraduate research students studying in the UK. Given the financial instability facing higher education, and the current research deficit, we would like to see greater emphasis on how the OfS will support the Research and Development (R&D) sector to contribute to economic growth, recognising that a reduction in R&D output could significantly damage the reputation of UK higher education and the economy. We believe that a sustainable approach is needed; one that balances fairness and affordability for students and taxpayers, while also safeguarding the pipeline of science, skills, and innovation necessary for the growth and prosperity of the UK economy, is urgently required.