The Office for Students (OfS) opened a consultation in September 2025 to seek views on proposed changes to the way it regulates and assesses the quality of higher education in England.
The consultation set out proposals on:
- Modifications to the overall quality system
- Modifications to the Teaching Excellence Framework (TEF)
The consultation ran from 18 September 2025 to 11 December 2025. A summary of responses to the consultation is expected in spring 2026.
Our response
In our response, we welcome the prospect of an integrated quality system and strongly support integration in principle. However, we have concerns about the proposed approach and the implications for smaller and specialist providers.
The current proposals do not sufficiently integrate across the different elements of OfS quality and assessment related activity. We urge OfS to fully integrate quality models to ensure scheduling does not conflict with other processes examining similar issues. We perceive the proposed approach to linking TEF ratings with DAPs not as genuine integration but as a mechanism for punitive action, which will leave providers - especially new applicants - facing uncertainty, shifting requirements and potential delays without clear solutions or assurances.
We caution against an over-reliance on TEF as a mechanism for judging all providers. Our response highlights that the proposed model is not suitable for providers with fewer than 500 students or those delivering pathway and other models of partnership provision. Data-driven approaches cannot fairly assess these providers. We recommend an alternative qualitative model focused on enhancement plans and contextual evidence, supported by small n methodologies. This will allow providers to demonstrate progress without being constrained by limited or incomplete data which fails to provide adequate evidence of excellence or is unrepresentative of the student body. We also propose introducing Provisional TEF (PTEF) ratings for new entrants, assessed during registration, to avoid gaps in published ratings and unnecessary delays.
IHE remains committed to working with OfS to design a system that promotes enhancement, transparency, and fairness across the sector, ensuring that regulation supports diversity and innovation rather than creating new barriers, disincentives and disproportionate burden.
Other points we raised in our response:
- Innovation should be recognised as a positive enhancement, not treated as a risk. We recommend that OfS incorporates commendations into the TEF model as a mechanism to incentivise innovation. Commendations would encourage providers rated Silver or Gold to go beyond maintaining their current position and actively develop new models that respond to emerging student and industry needs.
- We call for clear timelines and indicative scheduling for TEF assessments. This approach will enable providers to plan effectively and forms part of broader efforts to maintain financial sustainability.
- We welcome the retention of the student submission and support alternative methods for student participation. We call for practical measures to enable student assessor contributions, including a reframing of the value of these roles for students that are not sabbatical officers. OfS should also offer clear guidance for providers without independent student unions on how to support independent submissions.
Read our full response using the download link below.