Consultation on the future approach to quality regulation
Published 18 September 2025
Annex I: Draft quality risk monitoring tool
- This annex provides an initial draft quality risk monitoring tool, outlining:
- Our initial view of the factors that are associated with increased risks to quality, and why.
- What data and information we could use to monitor these risk factors. For this purpose we would aim to use up-to-date or current data as far as possible, rather than lagged indicators, so that we can anticipate emerging risks to quality.
- We invite views and evidence about the factors associated with risks to quality. Through this call for views we aim to build a shared understanding with the sector about the main factors associated with risks to quality.
- The intended purpose of the quality monitoring tool is different from that of the equality of opportunity risk register. The latter is intended to be used by providers to inform their work to improve equality of opportunity, and should be considered by providers when writing their access and participation plans. The main purpose of the proposed quality monitoring tool is that it would be used by the OfS for ongoing monitoring of quality, to understand where there are risks to quality. We would use it to:
- identify whether we should engage with or gather further information from a provider
- prioritise or select a provider for further investigation
- assess, alongside a provider’s TEF outcome (of Requires improvement or Bronze), whether there is an increased risk to quality
- consider whether to bring forward a provider’s next TEF assessment.
- We would use the tool and consider risks by looking at the range of factors and data we hold about a provider, rather than relying on a single indicator to form a view of risk.
- The tool would also be intended to provide transparency about the factors that might lead to increased scrutiny of a provider, so providers could also use the tool to identify and mitigate areas of potential risk.
|
Risk factor |
Rationale |
Evidence we would use |
|
Very high or increasing student:staff ratios |
We consider that student:staff ratios that are materially increasing or are outliers at the high end present a risk to quality. The financial viability and sustainability enquiry project found that financial pressures are leading some providers to reduce staffing, or rely increasingly on temporary staff or non-academic staff to deliver programmes. It also indicated potential negative impacts of this on quality. |
Data derived from student and staff returns:
|
|
Rapid or significant growth in student numbers |
Evidence from B3 and other quality investigations that providers do not always successfully manage rapid increases in student numbers, for example by not ensuring equivalent increases in academic staffing, student support, library facilities etc. This risk is likely to be more significant when combined with other risk factors such as growing partnership provision or recruiting more students onto foundation years or with low entry qualifications, as these students are more likely to have additional support needs. |
Increases of student numbers based on Student Loans Company data, and forecast growth in annual financial returns. |
|
Recruitment of students with very low or no entry qualifications |
Student outcomes data shows that across the sector continuation rates for full-time first degree students with certain types of entry qualifications have fallen below the minimum threshold. Evidence from B3 and quality investigations that providers recruiting students with low entry qualifications do not always successfully provide for the additional or differing support needs that arise. |
OfS size and shape data UCAS data (noting that some students with no or low entry qualifications may be recruited outside of UCAS) |
|
Large or growing volume of foundation year provision |
Student outcomes data shows that across the sector as a whole continuation rates for full-time first degree students studying with a foundation year have fallen below the minimum threshold. Evidence from B3 investigations that some providers have sought to increase student numbers by substantially increasing the number of students it recruits via foundation years, and that providers have not always managed the different needs of growing numbers of foundation year students. |
OfS size and shape data Student outcomes data |
|
Large or growing portfolio of delivery through domestic partnerships |
Student outcomes data shows that across the sector continuation rates for full-time first degree students delivered via a subcontractual partner have fallen below the minimum threshold. |
OfS size and shape data Student outcomes data Reportable events indicating new partnerships or termination of partnerships |
|
Low continuation rates |
Evidence from quality investigations that below threshold continuation rates can indicate issues with the quality of the student academic experience. Continuation is more timely than other outcome measures. |
Student outcomes data Student Loans Company term 1 data |
|
Notifications and other regulatory intelligence indicating material concerns |
Where they appear to be credible, notifications can indicate significant concerns about quality. Information from other regulators or agencies can relate to concerns about the quality of a provider’s higher education courses. |
Notifications sent to OfS indicating quality issues Relevant regulatory intelligence shared by professional, statutory and regulatory bodies, other regulators, the Student Loans Company or other agencies |
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