Following a consultation period, a revised Higher Education (HE) Code of Governance (the Code) was issued on 17 June 2026 by The Committee of University Chairs (CUC). This updated version replaces the previous 2020 iteration and includes substantial changes, reflecting the increasing complexity, scrutiny and financial pressures facing the sector.
The new Code introduces a clearer and more structured framework, built around principles and provisions. The principles set out what effective governance looks like at a high level, while the provisions translate this into specific actions for governing bodies.
Provisions expressed as ‘MUST’ define the minimum standards required to be compliant, whereas those expressed as ‘SHOULD’ require boards to apply judgement and explain their approach where they do not follow the code. This reflects an “apply or explain” model, designed to enhance transparency and accountability to stakeholders.
Importantly, the Code moves beyond broad guidance and is more explicit and operational in nature, setting clearer expectations of governing bodies and how they demonstrate effectiveness in practice. It is intended to be used as a framework for continuous improvement, with boards expected to regularly assess their own performance, including undertaking annual self-assessments and periodic independent reviews.
Stronger focus on financial resilience and risk
One of the most significant shifts is the greater emphasis on financial resilience and sustainability. Governing bodies are expected to take a more active role in understanding and challenging assumptions around income, costs and investment, supported by robust scenario modelling, stress testing and contingency planning.
The Code reinforces the need for boards to integrate strategy, risk and financial oversight, ensuring that long-term plans are underpinned by clear evidence, realistic assumptions and a strong understanding of potential risks and opportunities.
Greater accountability, culture and board effectiveness
In line with the updated Charity Governance Code, the updated HE Code also places increased emphasis on accountability, governance culture and board effectiveness.
Boards are expected to:
- demonstrate collective responsibility and provide constructive challenge
- foster a culture of integrity, openness and transparency
- clearly articulate how they obtain assurance over risk management, internal controls and academic governance.
There is also greater clarity on the roles and relationships between the Chair, executive leadership and the board, alongside stronger expectations around board composition, engagement and ongoing development. These relationships are crucial for effective and robust governance and issues around culture can very easily impact decision making.
Supporting governance in a more demanding environment
We are undoubtably in a continued period of change and instability, as higher education providers navigate a demanding environment with regulatory pressures, financial challenges, technological change and public scrutiny. The new Code recognises this backdrop and is designed to support governing bodies in responding to these challenges by strengthening leadership, improving oversight and ensuring governance arrangements remain robust, adaptable and focused on long-term sustainability and institutional purpose.
How can Crowe help?
We have an experienced Governance and Advisory team that provide a number of services to support the sector, including:
- External Governance Reviews – aligned to the HE Governance Code, we can undertake either a full Governance Review of the Institution or facilitate self-assessments and light touch reviews.
- Governance Transformation – we support organisations in governance change, either through seconded experts working within project teams or as standalone projects. This includes benchmarking structures, aligning and refreshing committee terms of reference and undertaking Board development work.
Contact us
