Proposals for a new approach to consumer and student protection

Proposal 4: Require publication of specified documents and information

145. We propose to include, in ongoing condition C6, a requirement that a provider must publish specified documents (or a collated list of active, publicly accessible links to these) on a single page on its website.
146. We are proposing that the specified documents would be published alongside mandatory standard wording provided by the OfS. We have included the proposed wording at Annex E.
147. As set out in further detail under Proposal 5, we propose that the specified documents would constitute a registered provider’s arrangements for student protection. This would replace the need for an approved and published student protection plan, as we currently require for registered providers under ongoing condition of registration C3.
148. The documents covered by our proposal largely mirror those that we require providers applying to register to submit under initial condition C5,⁷⁸ with some differences as discussed below. A provider registered under initial condition C5 is already expected to publish these documents on a single page on its website within two weeks of its registration. We are now proposing that we would require all registered providers to publish similar documents.
149. We are proposing that each registered provider would need to submit a declaration confirming it has published the specified documents and standard wording, within a specified time following the introduction of the condition. We have set out our proposal for this under Proposal 6 below.

Why are we making this proposal?

150. It is important that students have easy access to key information throughout the student lifecycle (before offer acceptance, during their course and after, where relevant). This supports students to understand and assert their rights as consumers, at the point they are making important decisions about what and where to study and if things go wrong after they’ve taken these decisions. If students struggle to locate important information, this creates a barrier to actively claiming and defending their rights and entitlements. This ultimately leads to frustration and disempowerment and allows information asymmetry between providers and students to persist.
151. As outlined previously, independent research commissioned by the OfS found that only 50 percent of students said that they understood and could describe their rights and entitlements as a student, while 40 per cent said they did not or could not, suggesting a systemic barrier to being able to uphold their rights.⁷⁹
152. CMA guidance already sets out an expectation that higher education providers inform students about important documents prior to signing a contract.⁸⁰ However, as students receive large amounts of information at the start of their course, they may overlook policies they do not expect to need. If problems arise later, they may not remember receiving these documents or may find it hard to locate them on provider websites or in old emails.
153. We consider that making key information available as a ‘one stop shop’, on a single webpage (and in a consistent and comparable format across the sector) should improve accessibility and support students to understand and uphold their rights.
154. In publishing its documents, a provider would be making a public statement about the services students should expect to receive. This should help students to hold their provider to account where services are not delivered as promised. This requirement could also help those advising students (such as Citizens Advice, or students’ unions) to support students in finding the information they need to exercise their rights.
155. We consider that a provider’s website is the best place to consolidate key information. OfS-commissioned research indicated that ‘the most likely source of information for students on the topic of their rights was their university website’.⁸¹

Detail of the proposal

156. We propose that a provider would need to publish, on a single web page, the following student-facing documents:

1. higher education contracts
2. any separate contracts that set out terms and conditions for the following ancillary services:
1. library services
2. disability support packages
3. scholarships
4. accommodation
5. sports facilities
3. policy (or policies) related to course changes
4. any documents that set our complaints handling processes
5. refund and compensation policies
6. a list of any agents that work on behalf of the provider and information explaining how students can raise any concerns of complaints in relation to these.

157. We consider that the proposed documents represent the minimum a provider needs to manage a consumer relationship with a student. Our initial view is that these documents would set out the key information a student needs to understand their rights and responsibilities and how they should expect to be treated by their provider (including practical information about how pursue a complaint or seek redress if things go wrong).
158. As well as this important information about student rights we would, of course, expect a provider to publish clear, accessible and sufficiently detailed information about its courses and other services elsewhere on its website. We have set this out under our proposals for an OfS information requirements list (see Proposal 2, paragraphs 82 to 88).
159. We propose that a provider would need to publish all the specified documents to satisfy the requirements of Proposal 5, except where stated in paragraphs 160 to 161. The effect of our proposal is that a provider may need to create one or more of the specified documents, where necessary, to satisfy the proposed publication requirement.
160. A provider would not be required to publish contracts for the ancillary services specified at paragraph 156b in the following circumstances:

• The provider does not offer the specified services.
• A third party does not offer the specified services on behalf of the provider.
• The terms and conditions governing the provision of the specified services are included within the contract for the provision of higher education.

161. A provider would not be required to publish a list of agents where there are no agents that offer services on its behalf.
162. Our proposal aims to ensure that students have easy access to comprehensive information about their rights, including where responsibilities for students are shared. Responsibilities may be shared:

• between providers in relation to academic provision
• between providers and other third parties, for example:
  1. in the case of apprenticeship or other employer-sponsored provision
  2. where a third party delivers ancillary services on behalf of a provider to its students.

163. We have identified below, for each document type, where we think this shared responsibility is most likely to be relevant and what we would expect in these circumstances.
164. Where any of the specified documents are already published in another location on a provider’s website, we propose that the ‘single webpage’ requirement could be satisfied by publishing links to existing file locations. However, we propose that these links would need to take the reader directly to the specified documents in a single ‘click’.
165. We expect a provider may need to update these documents over time. We propose that a provider would need to clearly identify which version of a document applied at any given time by making historical versions available for an appropriate period and being transparent about any changes made. In the draft guidance we have included at Annex C, we propose that ‘an appropriate period’ would mean the length of time that a student (including a former student) would reasonably expect to have access to a particular document. For example, where a former student has an ongoing complaint, they would reasonably expect to have access to documents setting out the provider’s complaints handling processes that were valid at the time they raised their complaint. They would also reasonably expect to have access to other documents relevant to their complaint, for example, the terms and conditions and refund and compensation policies that applied.

Mandatory standard wording supplied by the OfS

166. We propose that we would require a provider to publish standard wording, alongside its documents. We are proposing that this wording would largely mirror that which providers registered under initial condition C5 are already expected to use, but updated for the purpose of the proposed new publication requirement (see Annex E).
167. For the avoidance of doubt, while we are proposing mandatory standard wording, a provider would still be free to add additional text or visual aids to help explain the documents being published and support students in understanding their rights and responsibilities. A provider would also be able to publish additional documents on its webpage where these would help students to understand their rights and responsibilities.
168. This proposal is intended to ensure students have access to a minimum amount of information about their rights, and the provider’s obligations described in an accessible and consistent manner, to mitigate existing information asymmetries. It also aims to reduce inconsistency between providers and strengthen student confidence in the arrangements the provider has put in place to protect students. Information about the role and remit of the OIA and OfS will ensure students are both aware of and understand how to complain to the OIA and raise concerns with the OfS, respectively. This proposal aligns with the proposed principle of promoting students’ understanding of their consumer rights.

Higher education contracts

169. The proposal would require publication of any documents that form the higher education contract with its students. As a minimum, this would include the standard terms and conditions for the provision of higher education that are applicable to different groups of students. This would include terms related to any tuition fees and additional costs that would be payable by students. For the avoidance of doubt, the proposal would not require a provider to publish the contract that exists with an individually named student. The proposal is concerned with the standard terms and conditions that would apply to the contract.
170. We would require a provider to publish any other documents that constitute the ‘higher education contract’, regardless of the title given to a particular document by a particular provider. Depending on each provider’s context, and the documents which constitute the contract at that provider, this might include, for example, policies, agreements or codes.
171. We would require a provider to publish all higher education contracts that apply to its students, including:

• where the provider is a delivery partner in a subcontractual arrangement (this means all contracts between itself and students, and between the lead provider and students); and
• where the provider is a lead provider in a subcontractual arrangement (this means all contracts between itself and students, and between the delivery partner and students).

172. All documents should be clearly labelled to set out which courses and students they apply to. A provider working in subcontractual arrangements would need to collaborate with its partners to ensure students have access to clear information about which provider holds responsibility for which aspects of their student experience. Where a provider works in partnership with another provider, we propose that it may provide a link to relevant documents published on the partner provider’s website to fulfil this requirement.
173. We are proposing a requirement to publish higher education contracts because we think it is important for students to have easy access (in one location) to all the documents that form the contract with their provider. By improving the visibility of terms and conditions (and other documents with contractual effect) we aim to address the current gaps in students’ awareness of their rights and entitlements. We have identified these gaps through the findings of independent research we commissioned (see Executive summary). If students’ have easier access to information about their rights, they will be more able to identify if a breach of their rights has occurred and ultimately more able to hold their provider to account. This proposal aligns with the proposed principle of promoting students’ understanding of their consumer rights.

Ancillary service contracts

174. We are proposing that providers must publish contracts setting out standard terms and conditions for the provision of ancillary services, where contracts between a provider and its students exist (and are separate to the contract for the provision of higher education). For example, if a provider’s library service’s terms and conditions are included in its higher education contract, it would not need to create a separate contract for library services.
175. We are proposing this publication requirement because we think improving visibility of terms and conditions (to improve students’ understanding of their rights) should extend to the wider student experience. We think it important for students to be able to identify when their rights have been breached in relation to services integral to their higher education experience, but which fall outside the higher education contract. This is in line with our proposed principle of promoting students’ understanding of their consumer rights.
176. Further, we propose that this requirement should extend to those ancillary services delivered by third parties on the provider’s behalf. This is to ensure that students have as complete a picture as possible about their rights. Therefore, where ancillary services listed at paragraph 156b are delivered by a third party on behalf of a provider, we propose that we would require a provider to publish the standard contractual terms that students would have to agree to with the third party. We propose that a provider could satisfy this requirement by providing a link to the page on the third party’s website that hosts applicable terms and conditions.
177. The proposal would not require a provider to publish:

• any contract that exists between the provider (or a third party) and an individually named student (the proposal is concerned with standard terms and conditions); or
• any contract between the provider and a third party (the proposal is concerned with standard terms and conditions that apply to students, not to specific terms and conditions that apply to the provider).

178. Providers seeking registration under initial condition C5 are not required to submit ancillary service contracts between third parties and students. This means that registered providers would face additional obligations through the proposed publication requirement. We have set out our proposals for the implementation of the publication requirement below. This includes what we would require a newly registered provider to do and when (see Proposal 6, paragraphs 228 to 231 and Table 6).

Policies relating to relevant changes

179. We propose that, for each of the following, a provider would need to publish a policy (or policies) detailing provisions to protect students if it (or a third party delivering higher education on its behalf) has to make changes to any of the following:

• Courses (including changes to material components or contents of a course, changes to one or more subject areas or modules offered and course closure).
• Qualifications to be awarded (including circumstances where a validating partner has withdrawn validation, or the OfS has varied or revoked the provider’s degree awarding powers (DAPs), or has not extended the award of such powers beyond any relevant probationary or other time-limited period).
• Mode of study (including full-time, part-time, online and hybrid provision, and including measures to address the needs of specific student groups, including accessibility needs).
• Teaching location and facilities (including closure of a campus, building or other facilities and including measures to address the needs of specific student groups, including accessibility needs).
• Course fees and other related fees or charges (for example, additional fees to resit exams).
• Types of student to be recruited or taught (including where a provider loses a relevant licence, which means it is unable to recruit or honour commitments to international students).

180. A provider would not, however, need to include information about its plans if it were to be at risk of fully or substantially ceasing the provision of higher education. As explained below (see Proposal 5, paragraph 201), we can already compel a provider to produce a detailed plan for institutional closure (a ‘Market Exit Plan’) in these circumstances, under ongoing condition of registration C4 (Student protection directions).
181. We propose that a provider’s policies should include measures to address the needs of specific student groups, including accessibility needs, if it would make changes to modes of study, teaching location or facilities. For example, where a provider ceases to deliver part-time provision, this may have a significant impact on students who have registered for this mode of study because it fits with their existing caring responsibilities, working patterns and other commitments. Where a provider moves its teaching from one geographical location or building to another, there may be a number of accessibility issues, including but not limited to access for disabled students.
182. Where there is shared contractual responsibility for the provision of higher education, we propose that a provider’s policies should refer, where relevant, to the roles and responsibilities of other providers or organisations. For example, a teaching provider (delivery partner) in a subcontractual partnership may need to refer to its lead provider. A provider delivering an apprenticeship or other employer-sponsored course may need to refer to the role of a student’s employer, according to the terms set out in the contract between the provider and the employer (and between the employer and student).
183. Our initial view is that the proposal to publish policies relating to relevant changes is particularly important considering our further proposal that ongoing condition C6 would replace ongoing condition C3. If C3 did not apply, we would no longer require a registered provider to publish a student protection plan. Without publication of an alternative policy, we think this would leave a gap in published information about protections for students in the event of a significant change to their course.
184. We consider it important that students understand how their provider will respond in a broad range of circumstances. We think that students should have confidence that their provider has plans in place to protect their interests if it needs to make changes. This would provide certainty and reassurance about what they can expect. As with the publication of contracts (including terms and conditions), we think that improved visibility of a provider’s plans will help students to identify if their provider does not act in the way that it has promised and hold the provider to account if it does not honour the commitments it has made. This proposal aligns with the proposed principles of promoting students’ understanding of their consumer rights.
185. The requirements for the policies set out at paragraph 179 a-f. reflect the existing requirements for providers seeking registration under initial condition C5. However, our proposals for C6 additionally set out circumstances related to:

• variation, revocation or non-extension of DAPs
• changes to the type of students to be recruited or taught, including loss of a sponsor licence.

186. We did not include these for initial condition C5 as these circumstances would not ordinarily apply to providers before they have registered with the OfS. However, we consider that students (or particular groups of students) studying at providers that hold DAPs or a sponsor licence are more exposed to risks that may affect the continuation and completion of their studies. When studying at these providers, students should be able to understand the additional protections a provider has in place to address these risks.

Documents containing complaints handling processes

187. We propose that a provider’s complaints handling processes should address complaints that relate to the offering and provision of higher education and ancillary services, whether through a single process or separate processes. Where a provider has different complaints handling processes for different services or for different categories of student (for example, for applicants compared with registered or enrolled students), we propose that the provider should publish documents that set out all its processes.
188. Where there is shared contractual responsibility for the provision of higher education, we propose that a provider’s process documents should refer, where relevant, to the roles and responsibilities of other providers or organisations for the handling of complaints. For example, a delivery partner in a subcontractual partnership may need to refer to the role of its lead provider. A provider delivering an apprenticeship or other employer-sponsored course may need to refer to the role of the student’s employer, according to the terms set out in the contract between the provider and the employer (and between the employer and student), as these relate to complaints handling.
189. We think that students should have easy access to documents setting out complaints handling processes. By publishing these on the same web page as contracts and course change policies, a student should be able to:

• identify their rights and the provider’s commitments
• identify if their rights have been breached or a provider has not delivered on its commitments
• where applicable, see clearly how to raise a complaint.

The proposal to include complaints handling documents in the publication requirement aligns with the proposed principles of promoting students’ understanding of their consumer rights and enabling students to access timely clear and effective advice to navigate complaints handling and redress.

Refund and compensation policies

190. We propose that a provider must publish any policy or policies that set out refund and compensation arrangements for students.
191. We recognise that there may be circumstances where a provider may not charge tuition fees to some students for some courses. This may include, for example, where a student’s employer pays these fees to the provider, or where students are liable to pay tuition fees to another provider (as may be the case in a subcontractual partnership). However, even in a circumstance where a provider does not charge tuition fees to any students, students may still be liable for other types of fees or payments that the provider charges them directly. We are proposing that the published documents should reflect the entirety of the refund and compensation arrangements are applicable to the provider’s responsibilities towards students. It may also be helpful to refer to the responsibilities of third parties where relevant, to support students in understanding how they should pursue any claims.
192. Building on the requirement to publish contracts, course change policies and complaints handling processes, the publication of refund and compensation policies on the same page should allow students to understand the process and rules for financial redress where an issue has occurred and a complaint raised. We recognise that refunds and compensation may not always represent the best or only possible outcome when things go wrong and other forms of redress may be appropriate. However, we think it is important for students to be well informed about a provider’s policies for refund and compensation, so they can consider these alongside other forms of redress that may be appropriate according to their particular circumstances. This proposal aligns with the proposed principles of promoting students’ understanding of their consumer rights and enabling students to access timely clear and effective advice to navigate complaints handling and redress processes.

List of agents

193. The proposed condition holds a provider accountable for the actions of any agent working on its behalf. Proposal 3 (paragraphs 126 to 131) explains our rationale for this. Under Proposal 4, we would require a provider to publish a list of agents working on its behalf, as well as information about how students can raise a concern or complaint about these agents.
194. For the avoidance of doubt, this requirement would not require the disclosure of commercially sensitive information, such as commission rates. To meet this regulatory requirement, a provider would only need to publish information that is necessary for a student to confirm whether an agent is acting on behalf of the provider and to understand how to raise any concerns or complaints. This could include providing a link to any existing page of the provider’s website where this information is already available.
195. A provider currently holding a student sponsor licence is already required to provide UK Visas and Immigration (UKVI) with a wider set of information in relation to third parties used to recruit international students.⁸² Our initial view is that it should be relatively straightforward for a provider to comply with our proposed requirement by repurposing (and editing as appropriate) existing information.
196. We consider students should be able to verify whether an agent is authorised to represent a provider before engaging their services or when seeking to exercise their consumer rights. Many providers already publish lists of agents they work with; however, this is not universal, especially in relation to domestic agents. Requiring a provider to publish a list of agents (international and domestic) acting on its behalf would give students clarity about these relationships and help them identify appropriate routes for redress if they have concerns (for example, if they consider their consumer rights may have been breached by an agent operating on behalf of a provider). This aligns with the proposed principles of promoting students’ understanding of their consumer rights and enabling students to access timely clear and effective advice to navigate complaints handling and redress processes.
197. Although a provider is not required to submit similar information with its application for registration, if we implement this proposal a provider seeking registration under initial condition C5 would need comply with the requirement to publish this information once registered. We have set out our proposals for the implementation of the publication requirement below. This includes what we would require a newly registered provider to do and when (see Proposal 6, paragraphs 228 to 231 and Table 6).

Alternative options considered

198. We have considered alternative options to this proposal which are set out in Annex B. These are:

• not to include a publication requirement
• to exclude contracts between students and third parties from the publication requirement.

Notes

⁷⁸ This requirement has applied since 28 August 2025 when initial condition C5 (Treating students fairly) came into force. These documents are set out in ‘Annex A: Application requirements notice’, available at OfS, ‘Regulatory advice 3: How to register with the Office for Students. Supporting documents’.

⁷⁹ OfS, OfS explorations: Consumer rights, 2025.

⁸⁰ Gov.UK, Consumer law advice for higher education providers

⁸¹ OfS, OfS explorations: Consumer rights, 2025.

⁸² See ‘Sponsorship duties’ available at Gov.UK, ‘Student sponsor guidance’, (version 04/2026), see paragraphs 2.36, 3.24 to 3.31 and 7.2.