Recommendation 21

As a condition of registration, the OfS requires each higher education provider to have in place and publish a student protection plan setting out what it would do to safeguard students’ interests—such as by making arrangements for continuity of study— if it, as an institution, were in difficulty.40 The OfS reported in October 2019 that, when assessing applications for initial registration of providers, it had found student protection plans very variable in quality. Because it believed it was not in students’ interests to delay registration, it nonetheless approved a number of plans that were significantly below the standard it would expect. It identified weaknesses including providers being over- optimistic about the risks they faced, lack of detail about what specific actions providers would take, and weak refund and compensation policies. In the small number of cases where the OfS had required providers to undertake more detailed planning, it had found that existing student protection plans had been the starting point for discussion, rather than a set of actions that could be taken. We asked whether the OfS was now confident that student protection plans are fit for purpose and would adequately protect students. The OfS acknowledged that protections for students did still need further review and told us that it was committed to doing this over the course of the next 12 months as part of its next business plan.41