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Higher Education sector developments

Jayne Rowe
11/08/2025
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To support the Higher Education sector, we have gathered some of the most important regulatory, governance, VAT and tax updates that you need to be aware of.
Updated August 2025

If you are involved in the Higher Education sector, it is vital to remain up-to-date with the various requirements that may impact you and your organisation.

Regulatory updates and sector developments


OfS and National Trading Standards reform SP Jain’s student contracts

The Office for Students referred SP Jain London School of Management to National Trading Standards over concerns that its student contract contained unfair terms under the Consumer Rights Act 2015. Following the referral, SP Jain removed or amended these terms in its 2024–25 enrolment contracts and the OfS opted not to pursue further regulatory action once the changes were made.

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UUK welcomes strategic collaboration between Greenwich & Kent Universities

Universities UK (UUK) has welcomed the announcement that the University of Greenwich and the University of Kent plan to formalise their long-standing partnership, calling their collaboration “a powerful example of creative thinking” in response to sector-wide financial challenges. UUK’s Chief Executive, Vivienne Stern, praised the move as evidence of how universities are adapting to rising costs and declining income by working more closely together, she said such collaboration will strengthen the resilience and impact of the higher education sector.

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OfS Data reveals weaker outcomes for students on subcontracted courses

The Office for Students has published data revealing that students on subcontracted courses fare worse than those on directly taught programs. Continuation rates are 77% vs 88%, completion rates 74% vs 87% and progression to positive outcomes 57% vs 71%. The OfS Deputy Director of Quality, Jean Arnold warn lead providers must maintain full responsibility for quality and support and urges institutions with such partnerships to understand and address the performance gap.

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The OfS is developing a future approach to quality assessment

The OfS has outlined its vision for a more integrated and improvement-focused quality assessment system. Building on their 2023 Teaching Excellence Framework, the proposed approach aims to streamline assessments, enhance student outcomes, and reflect sector diversity. A formal consultation is expected later this year.

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Embracing innovation in higher education

The OfS has set out its principles-based approach to regulating AI in higher education. It’s encouraging institutions to experiment responsibly while safeguarding student outcomes. With AI use among students surging, the OfS highlights the need for clear guidance, equitable access, and collaboration to harness AI’s potential in teaching, learning, and assessment.

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Effective governance: in conversation with chairs

Following sector-wide roundtables, the OfS has published its reflections on the importance of robust governance in a challenging financial climate. Chairs of governing bodies shared insights on board structure, risk management, and innovation, with the OfS signalling future regulatory expectations to strengthen governance across diverse providers.

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University of Sussex fined £585,000 for free speech and governance breaches

The OfS has fined the University of Sussex for failing to uphold freedom of speech, academic freedom, and for governance failings. The investigation found that university policies created a “chilling effect” on lawful expression, breaching registration conditions and prompting a call for sector-wide reflection on compliance and decision-making processes.

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OfS publishes proposals for tighter control of subcontractual arrangements in higher education

In response to growing concerns over subcontracted provision, the OfS has proposed new registration conditions for lead providers with 100+ subcontracted students. The measures aim to improve transparency, protect students, public funds and ensure robust oversight.

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OfS publish business plan to drive benefits for students, universities and colleges and taxpayers

The OfS’s 2025 - 26 business plan outlines priorities including a refreshed approach to quality, enhanced consumer protection, and financial oversight. The plan reinforces the regulator’s commitment to student outcomes, institutional resilience, and safeguarding public investment in higher education.

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New analysis reveals rapid rise in uni start-ups

Universities UK reports a 70% rise in university start-ups since 2014, with over 64,000 jobs created. However, leaders warn that without sustained investment and support, the UK risks losing these ventures to global markets. The report calls for long-term funding and policy backing to help start-ups scale domestically.

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Why universities are critical to the Industrial Strategy

Universities UK argues that higher education institutions are essential to delivering the UK’s industrial strategy. From developing high-level skills to driving innovation and regional growth, universities must be embedded in sector plans to ensure sustainable economic development and global competitiveness.

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Research Excellence Framework (REF) panels must reflect the diversity of the UK higher education sector

As preparations for REF 2029 begin, sector leaders call for panel diversity to match the breadth of UK institutions. Inclusive representation is seen as vital to fair assessment, credibility, and recognising excellence across all research contexts, from civic universities to specialist colleges.

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DfE sets out the detail on the free speech act

The Department for Education has outlined its revised implementation of the Higher Education (Freedom of Speech) Act 2023. While retaining core duties for providers, the government has scaled back controversial elements, including direct regulation of students’ unions and the statutory tort, aiming for a more workable and proportionate framework.

View the policy paper

Committee of University Chairs: The Higher Education Code of Governance

The Code sets out a flexible, values-led framework for effective governance in UK higher education institutions. It’s centred on six interrelated elements: Accountability, Sustainability, Reputation, Inclusion and Diversity, Effectiveness, and Engagement. Institutions are encouraged to adopt the Code on an ‘apply or explain’ basis, tailoring governance to their context while upholding core values such as integrity, excellence, and community.

View the Code of Governance

View the Committee of University Chairs Code of Governance Compliance Checklist

Charity Commission updates and other guidance


You can view these updates and more as part of our Charities Alert.

  • CC11 Charities paying a trustee or a connected person
  • Section 37 Trustee Alert – Virgin Media v NTL Pension Trustees judgement
  • The Charities Act 2022
  • Investing Charity money
  • Charity Commission: Charities and AI
  • Cyber security breaches survey 2025
  • Failure to prevent fraud and other economic crimes

VAT and tax


You can view these updates and more as part of our Charities Alert.

  • Stamp Duty Land Tax
  • Employment Tax: what’s keeping us hot this summer?
  • VAT rates on new buildings, energy supplies and disabled building works

Contact us


Jayne Rowe
Jayne Rowe
Partner, Social Purpose and Non ProfitsLondon