The State of Quality Assurance and Enhancement in UK Higher Education
Perspectives of the outgoing CEO of QAA – June 2026
Opening: Why This Moment Matters
For much of the last decade, quality assurance in English higher education has been something that universities have been incentivised by the system to manage largely as a compliance exercise – making sure the paperwork is in order, the metrics meet threshold, the OfS registration secure. You know and I know how hard you have worked to make sure that’s not the whole picture, but it is a reasonable description of where the system incentivised people to put their energy.
I want to make the case today that this approach is no longer adequate. Not for individual universities, and not for the system as a whole. Not because the compliance demands have reduced (they haven’t), but because the external environment has changed so dramatically that quality governance has become an existential question, not one of competitive margin.
Just in the last three or so weeks, we have seen: a major IFS report finding that one in four graduates will be financially worse off after going to university; a Policy Exchange report calling for a 30 per cent reduction in student numbers and the outright banning of franchise provision; the OfS consultation outcomes on TEF published on 11 June; and a Burnham leadership bid gathering pace that will reshape the political terrain for higher education within months – (hopefully for the more positive, if he appoints an ex VC as his Chief of Staff, but it still seems unlikely that universities will be top of the priority board.) We are not in normal times. But we haven’t been in normal times since I arrived at QAA in 2019…
The Political Context: What Burnham Means for Universities and Quality
Andy Burnham entered Parliament on 19 June and is the clear frontrunner for the Labour leadership. For higher education, his likely premiership is neither straightforwardly positive nor straightforwardly threatening – it is conditional.
The evidence from his decade as Greater Manchester Mayor is that he understands the economic importance of universities. The Oxford Road corridor – 86,000 staff, 81,000 students – was a major success story under his mayoralty, and he would come to Downing Street having personally championed R&D-led growth. He knows what universities can do.
But he also has a strong and sincere commitment to technical and vocational education as an equal pathway, not a consolation route. His Greater Manchester Baccalaureate, his championing of T-levels and the Atom Valley project, and his explicit push for “inclusive innovation” rather than city-centre university-as-anchor-institution all point towards a premiership that will ask universities to demonstrate their value to communities beyond their immediate campuses. Institutions that can show place-based, inclusive impact — not just research metrics — will thrive. Those that cannot will find the political weather cold. (Tell the story of Manchester Uni and Moss Side?)
On quality specifically, Burnham has raised the “rigour” agenda: he has spoken about degrees where “the content of those degrees is insufficiently rigorous to render them attractive to employers,” and has supported the scrapping of the 50% HE participation target in favour of a two-thirds target that encompasses high-quality apprenticeships. This is not necessarily bad news for quality enhancement – it is a direct invitation to demonstrate that what we do is rigorous and valuable. But it does create risk for institutions that have grown rapidly on low-entry-qualification, high-volume models. We need to be thinking about this now, not when the next set of political announcements lands.
The emerging consensus across the political spectrum – from Burnham on the Labour left to Policy Exchange on the Tory right – is that the sector expanded too fast, that some provision is not good enough, and that accountability needs to be strengthened. In that environment, where the system lacks a supportive regulator or a HEFCE-type body incentivising enhancement, QAA membership should be part of the answer to that challenge, not an optional extra.
Within that context, I want to offer you five thoughts.
Thought 1: Quality Enhancement is Not a Luxury – It Is the Core Business
There is a tendency in the current regulatory environment to treat quality assurance and quality enhancement as two different activities: assurance is what you do for the regulator – it’s a burgeoning and expensively muddled set of requirements; enhancement is what you do when you have time and money left over. This is a false and dangerous distinction, and it’s particularly widespread in the development of English policy.
Scotland has demonstrated – through the Tertiary Quality Enhancement Framework and the Enhancement-Led Institutional Review – what it looks like to put enhancement at the centre of a quality system. The question is not “does this provider meet the minimum threshold?” but “how is this provider improving, and is that improvement structured and evidenced?”. Wales asks similar questions in Medr’s new enhancement-led system. These questions are not incompatible with accountability; they are a more demanding and more honest form of it.
The focus on minimum thresholds has a legitimate purpose: students and taxpayers need assurance that baseline standards are being met. But the OfS model, as it has evolved through six iterations of TEF, has unfortunately not moved us beyond that minimum threshold mentality. A TEF Bronze is not, in the language of the framework, a failure – and yet the regulatory consequences of receiving one are significant enough that providers rationally invest money and effort in avoiding it rather than in asking harder questions about their academic culture. As David Kernohan noted on Wonkhe, the incorporated monitoring tool flags risks but does little to address them beyond bringing forward a TEF cycle – it does not help a student whose lecture was cancelled last Tuesday.
Enhancement requires internal investment: in student representation, in module feedback that institutions actually act on, in peer observation, in communities of practice between academic staff and across providers. These are the mechanisms that change quality in real time. You are the custodians of many of these systems. You deserve investment, and investment is hard to argue for in the current environment of financial constraint.
Thought 2: Internal Quality Processes Are the Only Mechanisms That Help Students in Real Time
You are not peripheral figures in quality governance. You are, in most institutions, the designers and operational custodians of the systems that actually make a difference to student experience from week to week: module feedback loops, student academic representation, the committee structures that turn evidence into action, the academic appeals and complaints processes that are the safety net when everything else fails.
The OfS’s regulatory model is explicitly retrospective. TEF ratings reflect data on students who graduated between 2019 and 2022. The B3 continuation and completion thresholds are based on cohorts that started before COVID (22/23 data). The regulatory system cannot, by design, respond to a quality problem that emerged last semester. Only you can.
The York Consulting review of OfS investigation reports — which Wonkhe wrote about in November last year — found that participants wanted “a more constructive regulatory approach, less focused on deficiencies, more transparent in design, that more explicitly engages with context, and includes provider responses”. That language describes, fairly precisely, what a well-functioning internal quality culture looks like: proportionate, contextual, improvement-focused. The lesson from that review is not just that OfS should do better — it is that the sector needs to demonstrate that it already has mechanisms that do what regulation cannot.
One practical challenge for academic registrars right now: the LLE launch brings modular provision into the funded mainstream. OfS has confirmed it does not yet have outcome measures for modules under B3. That regulatory gap will persist for years. The responsibility for quality assurance of modular provision will fall primarily on institutional processes — on you. This needs to be a priority before the gap between funded modular delivery and regulatory oversight becomes a crisis.
Thought 3: Partnership Quality Cannot Be Outsourced to Threshold-Based Registration
No agenda in the sector has moved faster in the last two years than the governance of partnership provision. The government’s franchise reforms, laid in April 2026 and entering force in May 2026, require delivery partners with 300 or more students to register with OfS. This is progress – belated, but real.
But QAA’s consultation response to the DfE made an important point that I want to reinforce here: the size of a franchised provider does not equate to the level of quality risk. And QAA’s recent data analysis of franchised provision proved that conclusively. It’s not size, it’s the rapidity of expansion that creates risk. A provider with 2000 students who’s delivered nursing degrees to vulnerable communities for the last 20 years can represent a far lower quality risk than a provider with 500 students in its first cohort even if the latter is delivering a well-managed business qualification from a respected institution. The threshold-based registration model addresses governance and financial risk – it does not, in itself, assure quality.
The Post-18 Project’s Cashpoint Campus Comeback report – published in June 2025, with a title that captures the problem precisely – warned that England had undergone a form of “institutional amnesia,” repeating the mistakes of the FE sector’s subcontracting scandals. Policy Exchange, in its Tarnished Towers report of 8 June 2026, went further: it recommended banning franchise arrangements altogether, describing their “minimal benefits” as “outweighed by the significant detriment to students and the taxpayer”. It is not hard to see why such a conclusion has political force, given the cases that have damaged confidence, but that recommendation will not, and should not, be accepted wholesale – there are legitimate and high-quality franchise arrangements, as the recent QAA analysis shows – but it reflects a real and serious problem with the system’s failure to distinguish good from bad provision.
The practical tools exist. There’s a wealth of guidance, and in particular QAA’s new Advice and Guidance on Principle 8 of the 2024 Quality Code, which was published last year, provides a comprehensive framework for partnership governance: due diligence, contractual arrangements, student support, review and monitoring processes. The people responsible for institutions’ partnership portfolios should already be drawing on this. I am also about to publish a paper in this.
Thought 4: EQAR Membership Matters – and You Should Care About It
This one may feel abstract. It isn’t. It is, however, a long-term problem. England’s exclusion from the European Quality Assurance Register – the fact that England is the only part of the UK not compliant with the European Standards and Guidelines – is not a technicality. It is a strategic vulnerability with direct operational consequences for every institution that delivers programmes internationally, partners with European universities, or seeks to have its degrees recognised abroad.
ESG Principle 2.1 establishes a specific and important idea: that external quality assurance should address the effectiveness of internal quality assurance processes. This is philosophically different from what OfS does. OfS takes direct regulatory responsibility for quality everywhere, all the time – it does not assess whether an institution’s own processes are working; it imposes its own metrics on top of them. That inversion of the ESG model is why England falls outside EQAR.
OfS has now committed to work towards EQAR membership “at the appropriate time” in response to consultation, and QAA’s formal response in June 2026 welcomed this commitment. But “at the appropriate time” needs to be pressure-tested. You are well placed to ask, specifically, what the EQAR membership roadmap looks like and what conditions need to be met. This is not a matter of regulatory tidiness; it is about the international credibility of UK qualifications at a time when the sector’s international strategy is under enormous pressure. Increasingly, it will also be about the value of UK degrees in the international context – for graduates wishing to study in Europe, and for graduates seeking employment overseas. These are long-horizon problems, and I am sometimes told I’m scare-mongering. But early signs are beginning to appear, and we owe it to our students to monitor the horizon, as well as the icebergs immediately in our path.
Thought 5: The Sector Must Build Quality Into Restructuring – Not Bolt It On Afterwards
I want to end with the thought that is, frankly, the most uncomfortable. The sector is in serious financial difficulty. OfS’s own modelling suggests that 45 per cent of providers face deficits in 2025-26. A third of UK universities have now posted financial deficits.
In this environment, the pressure to cut is intense, and I doubt any of you are *not* experiencing it to some extent or another. Staff-student ratios will rise. Course portfolios will contract. Module and department closures will accelerate – the QMUL union’s live tracker currently lists dozens of restructuring programmes running simultaneously across the sector. The question for you now is not whether restructuring will happen – it will – but whether quality governance will be preserved or dismantled in the process.
The Post-18 Project’s April 2026 report Blood, Debt, Toil and Arrears argues that the post-Dearing settlement failed at its foundation – that per-student funding in 2025–26 is worth approximately what it was in 1997 in real terms, despite the entire machinery of fees, loans and market competition being designed to raise it. The current financial crisis is, in that reading, not an external shock but the inevitable outcome of a broken system. Whether one agrees with that analysis or sees the financial crisis as the result of a series of policy and economic pressures compounding over time, it is difficult to argue that repair alone will be enough.
The demographic pressures compound this. The Post-18 Project’s June 2026 policy signal documents a peak in the 18-year-old population around 2030-31, followed by a sharp fall back to approximately 2016 levels by 2040 – and I’ve spoken before about my own worries about current early primary school non-participation rates meaning a declining proportion of 18-year-olds who will be able to access HE, within that demographic decline. The sector was built for expansion. It has no restructuring framework, no managed closure protocol, and no government-sponsored transformation programme adequate to what is coming, although Scotland’s University Transformation Fund may help fill this void north of the border.
You need to be in the room when these restructuring decisions are made. Not as professional service staff simply managing the process, but as advocates for quality governance. Which course closures will affect articulation and partnership commitments? Which staff redundancies will undermine the communities of practice that sustain internal quality? Which financial decisions will damage the student experience before any regulatory metric captures it? You are the people who know the answers to these questions. You need to be asking them clearly and persistently.
Closing: The Opportunity
The arrival of a new political settlement – whether under Burnham or whoever follows – is an opportunity as much as a risk. There will be pressure to demonstrate rigour. There will be a premium on place-based, inclusive impact. There will be an appetite, across the political spectrum, for a quality system that is credible rather than merely compliant.
QAA, as it transitions to new leadership, retains the infrastructure that a better system needs: the Quality Code, the new Advice and Guidance suite being published through to mid-September 2026, the Enhancement-Led review capability in Scotland, Medr’s new framework in Wales, the work to develop a new system in Northern Ireland, the international accreditation work, the partnership quality frameworks. You are the professional community that can make those tools work inside institutions.
The case to make – to governing bodies, to vice-chancellors, to ministers, to OfS – is simple: enhancement-led quality governance produces better outcomes for students, builds stronger academic cultures, and creates the institutional resilience that a sector under financial and demographic pressure desperately needs. This is not an argument for less accountability. It is an argument for accountability that actually works.
