As the dust settles on the breaking news about changes to the UK’s immigration system under a long-anticipated white paper, The PIE News has identified 10 key questions still to be answered:
1. When will these changes be implemented?
This is the question on everybody’s mind. There is no clear timeline for any of these proposed changes, which makes managing the message to prospective students challenging.
Some key milestones to look out for are:
- When will the shorter 18-month Graduate Route visa be implemented?
- When will the 10 year qualifying period for citizenship be introduced?
- Which recruitment cycle will be subject to stricter compliance metrics?
Some of these changes are likely to require a change to primary legislation, which would mean implementation can’t happen until the next parliamentary session in 2026. It would also be sensible to allow universities to prepare for the changes.
2. What will the proposed levy on international income be used for?
This one must have been a shock for university vice-chancellors, who have been repeatedly calling for financial assistance for the sector. Instead they got a proposed levy on their international income stream.
The white paper models a 6% levy on higher education, which would likely be passed on to international students in higher fees. Provisional analysis suggests that student visa demand could fall by up to 7,000 main applicants per year if this were the case.
This idea appears to have been lifted directly from the Australian government’s Accord as way to link use of university finances to specific policy priorities. The white paper states the funds will to be “reinvested into the higher education and skills system”.
So what would this money be used for by government? We already know international student fees subsidise domestic student fees – so would the levy be used to formally redress that balance? If not, then the funding crisis for universities would undoubtedly deepen to critical levels.
Details are to be set out in the Autumn budget review, which signals a crunch time for higher education funding.
3. How many universities would already be in the ‘red’ under stricter BCA compliance metrics?
The proposal is to raise the minimum pass requirement of each Basic Compliance Assessment (BCA) metric by five percentage points, so that a sponsor must maintain a course enrolment rate of at least 95% and a course completion rate of 90% in order to pass the compliance threshold.
A traffic-light system of green, amber, red will be created to publicly identify which universities are in breach of their sponsor licence – with red signalling a major breach.
The suggestion from the report is that lower-ranked universities (601-1200 THE World Rankings 2025) have been over-recruiting. So, surely there are universities already in the red zone?
According to data from the 2023–24 BCA, 22 HEIs would not have met at least one of the new criteria set out in this paper, so perhaps the real question is, how will they be managed and how long will they be given to improve?
4. Is the government prepared to revoke sponsor licences or even let universities go bust as a consequence?
The message from the Prime Minister was clear: the UK government is prepared to reduce net migration at any cost.
A recent ONS report indicated 43% of universities in the UK are in financial deficit. The proposed changes offer very little to help that situation.
The white paper offers a breakdown of forecast reductions in international student numbers, linked to policy changes, that include:
- 18-month Graduate Route (12,000 less students)
- International income levy (7,000 less students)
- Stricter BCA requirements (12,000 less students)
These policies alone represent 31,000 fewer students, a huge black hole in finances for the sector to absorb.
Cases of UK universities losing their sponsor licence in previous years have been rare, with Newman University (2017) and London Metropolitan University (2012) both having had their licences revoked in the past.
In recent years, ‘action plans’ have become more appropriate for universities identified by the UKVI as having compliance issues, but it remains to be seen if that tolerance will now change and at what point warnings will move towards more tangible measures in the new system.
5. Will the international income levy also include TNE and offshore activity?
Many universities are already diversifying recruitment activity into articulation agreements with international university partners, or by going directly to the source of international demand by launching overseas campuses.
But does the government intend to levy all this activity or only those linked to inbound student visas?
The answer will dictate the future shape of the industry, as universities either invest more into TNE, or curtail activity if it is not financially viable. This view on education exports should be clarified in the imminent International Education Strategy (IES).
6. Does stricter compliance mean diversity targets are now impossible for a new International Education Strategy?
‘High-risk’ markets have already been identified as having a higher potential for asylum claims and therefore will now be subject to even stricter visa processing from the UKVI.
The current IES highlighted the risk of the sector dependancy on high numbers of students from China and India. But with less room for potential visa rejections in the new immigration system, will universities be forced to shelve diversity plans and stick to competing in tier one cities in established markets?
It will be fascinating to see how this is handled by the international education champion, Sir Steve Smith, within the context of identifying low-risk priority markets for UK recruitment.
There’s not much wiggle-room for student recruitment activity in this new context, so expect a greater focus on TNE.
7. Is the requirement for more frequent English language assessments for migrants linked to the proposed HOELT?
A key theme of the white paper is testing the English language levels of all migrants on an annual basis, to ensure ‘improvements over time’ and ensure that people are integrating into society.
Many of the language test providers will be eyeing this news up as a major opportunity to use their testing services to prove this proficiency. But is this actually linked to the ongoing consultation to create a Home-Office branded English language test? And what role will university-assessed English play for future visas?
Onshore testing could become a huge income-generating exercise for the UK government, if made mandatory.
8. Why was the MRes not a focus of the white paper?
The changes to student visa rules around removing the ability to bring dependants has clearly had a major impact on international recruitment for the UK. The latest ONS statistics are rumoured to show a decline in net migration largely fuelled by lower numbers of students and care workers.
In recent weeks, MRes courses have been highlighted as a potential immigration loop hole, as agents promote the course as an alternative route to bring family members to the UK.
This appears to be an easy policy change that seems to have been overlooked – but why? Perhaps it is too soon to show universities have created more MRes courses, or that students are applying to them in any greater numbers. However, we could see future action taken on this route.
9. Has the UK just missed a golden opportunity to take advantage of US disruption?
Just as the US faces huge disruption in education policy, funding and work rights, does the UK’s proposal squander the chance to capitalise on attracting global talent?
A route to permanent residency and citizenship is one of the biggest pull factors for any study destination trying to attract top international students. However the UK’s proposal to extend the period to a standard 10 years is double the US requirement.
In a policy claiming to want to attract the best minds in key industries, this would appear to be self-defeating at a time of incredible opportunity to realise the goal of becoming a global science superpower.
10. Are international graduates now better off starting their own business or trying to transfer to the UK from within a multinational company?
While the immigration white paper outlines a reduction in length of the Graduate Route visa – the window that graduates can remain in the UK to look for jobs – it promises to review the Innovator Founder visa. This, it hopes, will ensure that it supports entrepreneurial talent currently studying at UK universities to move into the visa so that they can build their business and career in the UK.
There is also a promise to “double the number of workers that an overseas business can send to the UK”, with the aim of establishing a presence in the UK – an alternative route that could dovetail the recent UK-India trade deal announcement.
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