OfS announces reforms to its registration tests to protect students and public money

Universities and colleges must be registered with the OfS if they want certain benefits, including access to student loan funding from the Student Loans Company for their students.

In February 2025, the OfS consulted on a new approach to assessing institutions seeking registration. The proposals included new initial conditions of registration relating to treating students fairly and effective governance, which institutions would need to satisfy to be registered. The OfS also proposed changes to its registration application requirements to enable it to more efficiently register institutions that are well-prepared to enter the regulated higher education sector.

Following analysis of feedback from the sector and students, the OfS has decided to introduce new initial conditions of registration which will come into force on 28 August 2025.

New initial condition C5 will help the OfS ensure that universities and colleges are treating their students fairly at the point of registration. Institutions seeking registration will be required to provide students with clear, easy to access information about what will happen if changes are made to their course, as well as fair processes for refunds and compensation and complaints.

New initial requirements on effective governance will ensure that institutions registering with the OfS have arrangements in place to provide a high quality academic experience, safeguard financial sustainability, and deliver value for money for taxpayers.

This includes having staff with the knowledge and expertise needed to make sure their institutions can comply with the OfS’s ongoing regulatory requirements and comprehensive arrangements for detecting, preventing and stopping fraud and misuse of public money. The new initial condition proposed in the consultation has been split into three new initial conditions (E7, E8 and E9) to make it easier for institutions to understand and engage with the requirements.

The OfS is also implementing its proposed changes to the registration application process. These changes are designed to incentivise the submission of high quality applications and make the process more efficient. They will also allow the OfS to more quickly identify and refuse applications from institutions that are not ready to enter the regulated higher education sector.

OfS Director of Regulation, Philippa Pickford, said:

‘I’d like to thank everyone that took the time to respond to our consultation – your views have directly informed these important reforms to the way we approach registration.

‘Registration with the OfS is the gateway to the regulated higher education sector in England and it allows institutions to access significant public and student funding. Our reforms will ensure that we can efficiently register well-prepared institutions that will deliver high quality education and treat their students fairly.

‘Our new registration requirements will also help us to swiftly and clearly identify and refuse registration for institutions that are not ready to do this. We will be holding a briefing for institutions seeking registration on 16 September 2025, where they can find out more about these changes and ask us questions.

‘We’ll reopen for new applications for registration, degree awarding powers and university title on 28 August 2025, after a temporary pause when we refocused our resources on the financial challenges facing universities and colleges. In response to feedback, we have also updated our evidence requirements for institutions applying for degree awarding powers to streamline the process.

‘As we explained in June, we will prioritise our work on universities and colleges with paused applications before beginning assessment of new entrants. We understand there may be several institutions waiting to apply for registration, and we have increased our capacity to be ready to meet a rise in demand.’

Notes

1. The Office for Students is the independent regulator for higher education in England. We are currently developing a new strategy for 2025-2030 which seeks to ensure that students from all backgrounds benefit from high quality higher education, delivered by a diverse, sustainable sector that continues to improve.
2. New initial condition C5 (treating students fairly), which tests whether a provider applying to register will treat students fairly, will replace existing initial conditions C1 (guidance on consumer protection law) and C3 (student protection plan). Institutions registered under initial condition C5 will be required to publish a set of student-facing documents, forming their student protection plan. Ongoing condition C3 (student protection plan) will therefore not apply to those institutions. 
3. New initial conditions E7, E8 and E9 (effective governance) will replace existing initial conditions E1 (public interest governance) and E2 (management and governance).  
4. In December 2024, the OfS announced a pause in accepting new applications for registration, and for degree awarding powers and university title. The OfS will reopen for applications on 28 August 2025.
5. The new initial conditions C5, E7, E8, E9 and the majority of the changes to the requirements for a registration application come into force on 28 August 2025. This means that they apply to any new applications for registration including, in the case of the new initial conditions of registration, any application from registered providers for registration in a different category of the OfS Register, received by the OfS on or after 28 August 2025. 
6. The restriction preventing an institution from reapplying within 12 months of receiving a final decision by the OfS to refuse registration will not come into force until 1 January 2026. That restriction will then apply to any new registration applications made on or after 1 January 2026, where the application on the basis of which the OfS made the final decision to refuse registration was also made on or after 1 January 2026. 
7. The new requirements for a registration application will not apply to any application by a registered provider for registration in a different category of the OfS Register. Instead, the OfS will establish the application requirements for each application to change registration category in a bespoke notice issued to the relevant provider under section 3(5) of the Higher Education and Research Act 2017. 
8. The new initial conditions and registration requirements will not generally apply to any application for registration made before 28 August 2025. This includes applications that the OfS is currently assessing or that are currently paused. However, if the OfS identifies particular regulatory risks posed by an institution, including an institution with an application currently paused, the OfS may consider whether to apply one or more of the new initial conditions, or parts of those conditions, to that institution. If the OfS proposes to do this, it will consult on an individual basis with the institution affected.