Recommendation 10

Some providers use agents or offer financial incentives to recruit students, practices that are not regulated.20 DfE told us it is planning to look at the use of agents, focusing particularly on whether there is any mis-selling of courses from agents to individuals, such as promising individuals guarantees on to courses.21 It said it has started a rapid investigation into the use of agents, both domestically and internationally, to protect students’ interests and, more recently, has entered into a partnership with National Trading Standards, which is able to enforce consumer law.22 We also heard that Universities UK is reviewing the Agent Quality Framework (AQF) and making recommendations to identify and address bad practice, including a commitment to ensuring that all its members sign up to that framework.23 DfE told us weaknesses in lead providers’ controls can suggest an insufficient grip over the recruitment activity of their franchised providers, including where agents are used.24 Transparency over franchise arrangements