What do UK immigration reforms mean for student sponsors? Charlotte Ashton, head of immigration at ESP Solicitors, outlines the proposals

The UK government’s Immigration White Paper – announced on 12 May – outlines a series of proposed reforms aimed at reducing net migration and strengthening border control. These will have a significant impact on student sponsors – education providers who can sponsor international students and pupils to study in the UK. While public attention has largely focused on work visa changes, these proposals also carry significant implications for the education sector including independent schools, which must prepare to respond swiftly.

The key changes affecting the education sector are:

Tighter basic compliance assessment thresholds
The basic compliance assessment (BCA) is an annual assessment used to monitor a sponsoring institution’s (such as an independent school recruiting international pupils) level of compliance. It is based on three metrics for any international student or pupil it recruits: a visa refusal rate of less than 10%; a course enrolment rate of at least 90%; and a course completion rate of at least 85%. These are designed to ensure that pupils are genuinely coming to the UK to study, and to prevent the student sponsor route being misused.

The government believes the current thresholds are too relaxed and leave the system open to abuse. It is therefore proposing to increase the thresholds by five percentage points putting the enrolment rate to 95%, the course completion rate to 90% and the visa refusal rate to 5%. While the basis of the government’s concern appears to be higher education institutions, independent schools will still be required to meet these stricter thresholds. Schools with smaller cohorts of sponsored pupils will be more at risk of missing the thresholds given that it would take a smaller number of issues to arise to change the percentages significantly.

Red-amber-green (RAG) rating system

A new publicly-available rating system will classify sponsoring institutions based on compliance performance. The public nature of such a system could have a negative effect on future international student and pupil recruitment, particularly as those viewing the rating, such as prospective parents, might not have a full understanding of the red, amber or green criteria being used.

New interventions for sponsors failing their metrics

The government plans to introduce new interventions for sponsors who are at risk of failing the new BCA metrics. These will include bespoke actions plans to improve compliance, and limiting or barring recruitment of new international students and pupils, while being subject to a compliance plan. This poses a significant risk for any sponsors who might not meet the new stricter BCA criteria.

Agent quality framework

Institutions using agents to recruit international students and pupils will be required to sign up to the agent quality framework. While this is currently best practice, the government wants to make this mandatory to ensure that sponsors retain accountability for ensuring visa applicants are genuinely coming to the UK to study.

Consideration of local impact
The White Paper proposes that sponsors will be required to show that local impacts have been considered and are taken into account when making decisions about international student recruitment. There is no detail on this requirement or whether it will only apply to higher education institutions or will apply to all student sponsors. Sponsors should ensure they stay up to date with this proposed requirement as and when more details are forthcoming as it could add an extra layer of difficulty when seeking new Confirmation of Acceptance for Studies allocations.

What can independent schools do to prepare?

Although these reforms are still at the proposal stage and not yet law, they signal a broader policy trend toward reducing net migration and tightening oversight of student visa routes. Independent schools and other education sponsors should take proactive steps to prepare.

1. Conduct a compliance health check
   Evaluate your current metrics against the proposed BCA thresholds: enrolment, course completion, and visa refusal rates. Identify any areas which may fail to meet the new criteria and act early to improve compliance.
2. Strengthen data and reporting systems
   Implement reliable tracking for pupil attendance, academic progress, and visa status. Use automation where possible to improve accuracy and support audit readiness.
3. Ensure applicants are supported

To minimise the risk of applications being refused, ensure you have a clear process for applicants to follow, including template supporting documents and, where possible, support to ensure that applications don’t get refused due to mistakes on the application form.

4. Review and regulate agent partnerships
   Audit your current recruitment agents and ensure alignment with the agent quality framework. Provide agents with clear guidance and training to minimise visa refusals and misrepresentation.
5. Prepare for the RAG rating system
   Consider publishing a green rating as a good news story. Develop a communications plan to reassure prospective pupils and stakeholders for any rating other than green.
6. Engage stakeholders
   Keep leadership, admissions and compliance teams informed and coordinated of any changes. Maintain clear communication with current and prospective pupils regarding your institution’s response to the changes.
7. Collaborate and advocate
   Engage with sector organisations to exchange insights and shape policy responses. Contribute to government consultations and provide feedback to the Home Office whenever possible.

Charlotte Ashton