As first published in The Scotsman newspaper on Tuesday 2 June, our Convener, Professor James A Miller FRSE has written a opinion piece on the changes to the BCA metrics. You can find the associated news piece by Catorina Stewart here and the opnion piece here.
Universities support the need for a robust and fair immigration compliance regime. It is not in our interests to recruit applicants with ulterior motives.
However, from this month, UK institutions will face a significantly tighter international student visa compliance framework, as introduced by the UK Government, that risks unintended consequences for universities and the Home Office. Recent increases in visa delays and widely reported inconsistent refusals have already heightened concern in the sector.
UK Government Ministers are clear that the objective is to reduce misuse of the student route, including rising asylum claims. Yet reforms are being implemented at pace, with limited data and insufficient safeguards. The result could be financial and reputational damage to largely compliant institutions, and harm to the UK’s global standing as a study destination.
The sector does not oppose robust compliance. Universities expect credible border controls and action against abuse. But the new framework risks penalising institutions for factors beyond their control – particularly Home Office operational issues and persistent data asymmetries between UK Visas and Immigration (UKVI), a division of the Home Office, and universities.
The Home Office, UKVI and universities are working together, but progress is limited and the timeline very short. A phased transition from June would mitigate risk while maintaining momentum. The sector’s ask is measured: with better and shared data, clearer transition arrangements and a credible partnership, the reforms can deliver government aims and allow universities to continue recruiting highly motivated students.
What is changing?
The 2025 immigration White Paper described reforms to the Basic Compliance Assessment, the annual test determining whether universities retain student sponsor licences. At present, universities must meet certain thresholds for three metrics, set by the UK Government, in order to recruit international students. The three metrics are: the percentage of student visa applications refused by UKVI; the percentage of students who enrol after being granted a visa; and the percentage of enrolled students who complete their course.
This month, all three key metrics are getting much stricter. The visa refusal threshold – will halve from 10 per cent to 5 per cent. The enrolment requirement will rise from 90 per cent to 95 per cent, meaning 95 per cent of applicants awarded a visa must enrol at university. From 2027, the course completion threshold will increase from 85 per cent to 90 per cent.
Alongside this, a Red-Amber-Green (RAG) rating system will be introduced. Failing to meet even a single metric will result in a red rating. Even institutions within the thresholds can be labelled amber if they are within 20 per cent of a limit – for example, a refusal rate between 4 and 5 per cent.
These ratings carry significant consequences. A red rating could limit the number of international students that universities can recruit, and escalating sanctions can lead to the revocation of a universities’ licence to recruit internationally. Amber can also affect recruitment, access to international student finance, and lending conditions.
Why universities are concerned
The issue is not only the ambition of the metrics, but with the impact on operational realities. First, implementation is abrupt. Recruitment for September 2026 has been underway for months under the existing thresholds.
Halving the visa refusal threshold for the autumn intake forces institutions to reduce recruitment or withdraw offers, creating immediate financial loss and disappointment for applicants.
Second, the approach looks backward rather than forward. Checks on compliance are linked to licensing cycles, so reviews carried out after this month will still cover formal ‘Confirmation of Acceptance for Studies’ issued under the old system. Although the Home Office says it will show “discretion”, it has not explained how this will work in practice – leaving universities unsure where they stand.
Third, universities’ confidence in UKVI’s decision-making has been weakened. Scottish universities estimate that 2,300 students did not receive visa decisions in time in January, costing around £48 million in lost income. Visa refusal rates have also risen unexpectedly, often on grounds institutions report as inconsistent or factually questionable.
Finally, the three Basic Compliance Assessment metrics are interdependent. Visa delays reduce enrolment rates; delayed enrolment can affect progression and completion. This creates compounding compliance risks driven by factors institutions cannot control.
A matter of data
At the core of the issue is data. Universities are held accountable for outcomes they cannot fully monitor. UKVI does not provide timely refusal data, granular risk indicators or real-time visibility of its metrics to universities, through the sponsor management system.
Differences between university and Home Office datasets – sometimes involving only small numbers of students – can determine whether an institution passes or fails.
Universities also receive no data on asylum claims made by students they have sponsored, despite this being a key driver of the change in policy. Institutions are willing to help manage risk but require access to the relevant information.
What should change?
The sector’s proposals are pragmatic. Universities are calling for improved and timely data sharing, greater transparency, and a review of UKVI decision-making quality and training. Access to data on asylum claims is also essential to enable institutions to manage risk.
There is also a case for a more proportionate RAG system. Institutions meeting the compliance thresholds should be rated green. Amber should indicate genuine risk or concern, not proximity to a threshold. Red should be reserved for serious or systemic non-compliance.
Finally, if these issues cannot be resolved quickly, government agencies should focus on more gradual transition arrangements. Without such safeguards, compliant institutions risk being labelled as failing through no fault of their own – damaging finances, destabilising regions and weakening the UK’s competitive position in global higher education.
Robust compliance and a thriving international sector are not mutually exclusive. But without better data, clearer transition arrangements and a stronger partnership with the sector, the new visa regime risks achieving the opposite of what it intends.
Professor James A Miller FRSE is convener of Universities Scotland and principal and vice-chancellor of the University of the West of Scotland