London Higher has submitted its response to the Office for Students’ (OfS) consultation on the future of quality regulation, drawing on extensive engagement with members across the capital.
The consultation proposes significant changes to how quality is assessed, including extending the current framework to postgraduate provision, redefining Teaching Excellence Framework (TEF) ratings and linking funding decisions (such as a tuition fee uplift and World Leading Specialist Funding) to outcomes. London Higher supports the ambition for a clearer regulatory approach but argues that substantial refinement is needed to ensure the framework is fair and proportionate for the capital’s diverse providers.
London is home to the majority of England’s postgraduate-only institutions and world-leading specialist providers. Its universities also teach some of the country’s most diverse student populations, with many students commuting, working alongside their studies or balancing caring responsibilities. The response argues that these characteristics require explicit recognition if the new framework is to deliver fair and meaningful assessments.
Our key concerns:
- Postgraduate provision cannot be assessed by simply extending the undergraduate model. At present, the available postgraduate data and benchmarks are insufficiently robust to support reliable assessment, particularly for specialist and postgraduate-only provision.
- Contextual factors affecting London’s diverse students are not captured in headline indicators, risking misrepresentation of providers’ contribution to social mobility.
- London’s specialist institutions need explicit protection. The proposals do not show how TEF will recognise creative and practice-based models.
- The proposed Bronze redefinition would recast what the OfS has called “high quality” as merely meeting minimum requirements, misleading students and parents.
- The implementation timetable is unrealistic. London Higher is calling for a 2029 start to allow time for proper preparation.
London Higher’s full response was informed by workshops, meetings and consultations with institutions across London, including specialist, postgraduate-focused and multi-faculty providers.
Image © Trinity Laban, JK Photography
