Stricter Basic Compliance Assessment thresholds: The government has stated that the current Basic Compliance Assessment (BCA) thresholds are too lenient and have left the route open to abuse and exploitation. As such, it is proposed that the BCA thresholds be tightened by a further five percentage points, meaning they would change to:

• An enrolment rate of 95% (up from 90%)
• A course completion rate of 90% (up from 85%)
• A visa refusal rate of 5% (down from 10%)

These changes are designed to prevent abuse of the student visa system and ensure only high-performing institutions can continue sponsoring international students.

Introduction of a Red-Amber-Green (RAG) rating system: A new RAG rating system will be implemented to publicly show which sponsors have a high rate of compliance, and which are at risk of failing. Where sponsors are at risk of failing, they may be put on a bespoke action plan and restricted from recruiting new international students while they improve.

Mandatory adoption of the Agent Quality Framework: All Student Sponsors that use recruitment agents for overseas students will be required to sign up to the Agent Quality Framework (AQF). This aims to ensure that institutions take full responsibility for the students they sponsor, rather than relying on third-party agents. Sponsors must ensure that students are genuinely coming to the UK to study and meet all visa requirements. The AQF will set clear standards to improve accountability and reduce visa refusals linked to poor agent practices.

Requirement to consider local impact: Student sponsors will be required to demonstrate that they are considering local impacts – with regard to their community and resources -when taking decisions on international student recruitment.

Proposed 6% levy on international tuition fees: The government is considering imposing a 6% levy on higher education provider income from international students. The aim is to reinvest this into the UK’s higher education and skills system. Further detail is expected in the Autumn Budget.

Shortening of Graduate visa route: The current Graduate visa allows international grduates to stay in the UK, unsponsored, for two years after completing their course (three years for PhD students). The government plans to reduce this period to 18 months (PhD student are expected to be unaffected) – meaning that there will be a shorter period for a graduate visa holder to find sponsored employment and potentially making the UK less attractive to international students.

While these reforms are still proposals and not yet law, they reflect a broader policy shift toward reducing net migration and tightening control over the student visa system. Independent schools and other student sponsors should act now to prepare for the potential changes and protect their sponsor status.

Action steps for all education sponsors

1. Conduct a compliance health check

• Review your institution’s current performance against the proposed BCA thresholds: enrolment, course completion, and visa refusal rates.
• Identify any gaps and implement corrective measures early.

 

2. Strengthen data and reporting systems

• • Ensure you have reliable systems in place for tracking student attendance, progression, and visa status.
  • Automate reporting where possible to reduce human error and improve audit readiness.

3. Review and regulate agent partnerships

• • Audit your existing recruitment agent relationships and ensure they meet the standards proposed under the AQF.
  • Provide training and clear guidance to agents to reduce visa refusals and misrepresentation.

4. Prepare for the RAG rating system

• • Understand how your institution may be rated and what the implications are for recruitment and reputation.
  • Develop a communications strategy to address concerns from prospective students and stakeholders.

5. Model financial impact

• • Assess how the proposed 6% international student levy could affect your revenue and budgeting.
  • Explore diversification strategies to reduce over-reliance on international tuition income.

6. Engage internal and external stakeholders

• • Keep your leadership, admissions teams, and compliance officers informed and aligned.
  • Communicate openly with current and prospective students about how your institution is responding to the changes.

7. Collaborate and advocate

• Work closely with sector bodies (e.g., Universities UK, Independent Schools Council, Association of Colleges) to share insights and influence policy development.
• Participate in consultations and provide feedback to the Home Office where possible.