Proposals for a new approach to consumer and student protection

Executive summary

Higher education has the power to transform lives. It enables students to develop new skills and broaden their horizons. It gives them access to opportunities that benefit not only them as individuals but also the wider economy and society. Students make a major investment of time, effort and money to pursue these opportunities. It is therefore essential that they can rely on clear information about what their courses will offer, and that the education they receive aligns with those commitments.

While many students have positive experiences, this is not universal. Recent research commissioned by the Office for Students (OfS) indicates that a substantial proportion of students do not feel their institution has fully delivered on the promises made to them. Although experiences vary, more than three-quarters of respondents to our polling said that some commitments were not met in full.²

Our ongoing engagement with students reinforces that fairness is fundamental to their experiences. They expect providers to honour their commitments and ensure that they receive the experience they were promised. This is why we are proposing changes to our ongoing conditions of registration relating to consumer protection, to ensure students are treated fairly.

Consultation proposals

To achieve our aims, we propose to remove two of our existing conditions of registration: Guidance on consumer protection law (C1) and Student protection plan (C3) for all registered providers. We propose to replace these with one new ongoing condition: Treating students fairly (C6).

Proposed new ongoing condition: Treating students fairly (C6)

This condition would require a provider to treat students fairly in relation to its higher education provision and the services that support it.

It would introduce an overarching requirement for higher education providers to treat students fairly, accompanied by a set of underpinning principles, specific information requirements and prohibited behaviours. Under this approach, rather than requiring a registered provider to demonstrate due regard to relevant guidance on consumer protection law (as required by ongoing condition C1), a provider would need to consider whether its arrangements were fair to students overall. These proposals draw on consumer protection, build on our regulatory experience and aim to establish a clear and shared understanding of what fairness means in the higher education sector.

The proposed new ongoing condition would also require a provider to have and publish a consolidated set of clear and accessible documents for students on a single page of its website,³ alongside mandatory standard wording explaining its student protection arrangements. This would replace the current requirement for an approved student protection plan.

We have already strengthened our regulatory framework through a new initial condition for treating students fairly (C5), which providers must now satisfy before they can be registered with the OfS.⁴ The proposed new ongoing condition would build on the standards we require at registration and apply to all registered providers on an ongoing basis.

Reasons for this consultation

Driving improvement in this area is a priority for the OfS. Our strategy for 2025 to 2030 sets out our goal that students receive the higher education experiences they were promised.⁵ Treating students fairly throughout their higher education experience is essential to achieving this.

For most people, choosing whether, what and where to study higher education is a one-off decision and, once made, students make a significant investment of time, effort and money. Once enrolled, it can be difficult, disruptive and costly to change course or provider. It is therefore essential that students have the information they need to make informed decisions from the outset and that the commitments made to them are honoured.  

However, recent research commissioned by the OfS highlights important gaps. Only half of students who responded to recent polling said they understood and could describe their rights and entitlements as a student.⁶ This would limit their ability to hold providers to account or enforce their rights where necessary. Students have told us that they expect to be treated fairly by their universities and colleges and that they expect promises made to them to be delivered. Students have told us that this matters to them.

Prospective students should be able to rely on clear, accurate and comprehensive information when making choices. Existing students should be confident that their provider will deliver the experience that was promised. Where expectations are not met, students should have accessible and effective ways to raise concerns and seek redress and resolve issues when they arise.

We believe that changes to our regulation will help students make informed choices, recognise when their provider has not met its commitments and understand their rights as students if this happens.

Our proposals are intended to strengthen accountability across the higher education sector with providers setting out consistently clear and accurate information about their higher education offering. This increases trust, supports student decision making and encourages providers to improve their overall offer to attract students.

Engagement with stakeholders

We recognise the important role played by other bodies in protecting students, including the Competition and Markets Authority (CMA),⁷ and the Office of the Independent Adjudicator for Higher Education (OIA), which operates the statutory complaints scheme.⁸ We have engaged with these partners, as well as other stakeholder groups, in developing our proposals.

In November 2025, we spoke to a range of stakeholders to gather feedback on our developing proposals for a new ongoing condition focused on fairness and including mandatory requirements (or rules) and principles. We held a series of meetings and roundtable discussions, including with sector representative bodies, the OfS Student Interest Board,⁹ the National Union of Students, the OIA, the CMA and National Trading Standards (NTS).

Overall, stakeholders welcomed the OfS’s ambitious and collaborative approach to a proposed new condition. Their feedback has played a key role in shaping the proposals outlined in this consultation. Further detail on what stakeholders said is set out in the introduction.

Next steps

Students, staff at universities and colleges and sector bodies are invited to join us at one of our consultation briefing events to hear more about our proposals and ask questions.

The consultation will close on 9 July 2026. We will then analyse and consider the responses and make decisions about our proposals. We will publish our final decision in autumn 2026.

Depending on the responses we receive, we are proposing a phased approach to implementation of the proposed condition.

We will also continue to engage with the sector on our work to strengthen and improve student contracts.

² OfS, ‘OfS explorations: Consumer rights’, 2025, paragraph 5.

³ These documents would include, for example, contractual documents that set out standard terms and conditions and other relevant policies and process documents.

⁴ OfS, ‘Condition C5: Treating students fairly’ and ‘Guidance’.

⁵ OfS, ‘The OfS strategy 2025 to 2030’.

⁶ OfS, ‘OfS explorations: Consumer rights’, 2025, paragraph 1.

⁷ The CMA is responsible for enforcing consumer protection law across all sectors of the economy in the UK, with sector regulators such as the OfS in higher education having a role in addressing sector-specific issues.

⁸ OIA, Our Scheme. The OIA is guided by its Good Practice Framework, which sets out principles for fair and transparent complaints processes, academic appeals and disciplinary processes.

⁹ OfS, ‘Student Interest Board’.