UK Student Visa Reforms: How the May 2025 Immigration White Paper Affects Education Providers

Key Points

• Stricter Compliance Demands: Sponsors face higher BCA thresholds (95% enrolment, 90% course completion, 5% visa refusal rate) and public Red-Amber-Green ratings, risking licence loss.
• Agent Quality Framework (AQF) Mandate: Sponsors using recruitment agents must join AQF, with tighter oversight to prevent visa abuse.
• Financial & Post-Study Pressures: A proposed 6% levy on international tuition fees and reduced Graduate Visa (18 months) may deter international students, straining university budgets.

The UK Government’s May 2025 Immigration White Paper proposes significant reforms to the UK’s study visa routes, aiming to cut net migration. The new measures would place UK education providers who sponsor international students under increased compliance and financial pressures. Although these measures do not represent current law or sponsor guidance, if enacted, the measures could also make the UK a less attractive destination for international students.

Immigration law expert Anna Blackden explains how this could impact sponsors and international students.

Key Proposals in the 2025 Immigration White Paper

Tougher Compliance Standards for Student Sponsors

Currently, sponsors of international students must have a visa refusal rate of less than 10%; an enrolment rate of at least 90% and a course completion rate of at least 85% in order to successfully pass their annual Basic Compliance Assessment (BCA) and retain their student sponsor status.

Higher BCA Thresholds: 95% Enrolment, 90% Completion & 5% Visa Refusal Rates

The White Paper proposes to raise the minimum pass requirement of each metric by 5%. This means course enrolment rates of sponsored students must be at least 95% and course completion rates at least 90%. Although not specifically mentioned in the White Paper, it is assumed that the visa refusal rate will also be reduced to 5%. This means that of all the students sponsored in a 12 month period by a UK education provider, the total number of applications refused by the Home Office must be less than 5%.

Red-Amber-Green Ratings: Public Scrutiny & Licence Risks

The Home Office will introduce a publicly visible Red-Amber-Green rating system to track a student sponsor’s perform with their BCA metrics. Student sponsors which fall close to these metrics will be placed on action plans to improve their compliance with corresponding limits placed on the number of new international students they may recruit.

If implemented, such tougher BCA thresholds will require student sponsors to reassess their international student recruitment strategies in order to protect their BCA metrics. This could disproportionately affect applicants from certain regions where, for instance, there are higher numbers of students that claim asylum in the UK before their studies finish. Ultimately, changes to the BCA metrics will mean more student sponsors are placed at risk of losing their sponsor licence and their ability to recruit international students. At a time when finances are already under strain, losing the valuable income from international student fees would have a significant adverse impact.

Mandatory Agent Quality Framework (AQF) for International Student Recruitment

The UK Agent Quality Framework provides best practice standards in the management of international student recruitment agents. Student sponsors already have a duty to regularly provide the Home Office with details of the recruitment agents they use. However, the new requirement for sponsors to sign up the AQF is designed to ensure that student sponsors cannot outsource their responsibility to recruit international students who are genuinely coming to study in the UK.

With an increasing spotlight on the link between recruitment agents and sponsor compliance, the Home Office had already confirmed before the publication of the White Paper that an optional new Agent field will be introduced on CAS from 22 May 2025. Inserting the details of the agent used to recruit the international student on a CAS underlines how important it is for student sponsors to carefully vet and monitor the agents they use to recruit their international sponsored students. With the White Paper’s recognition of the role of recruitment agents in preventing student visa abuse, it is likely that the agent field on CAS will become mandatory in future.

Local Impact Consideration and International Student Recruitment

Under current sponsorship processes, student sponsors must submit an annual CAS request setting out how many students they wish to sponsor and justifying the numbers requested. Where student sponsors seek to increase the numbers of international students they wish to sponsor, further details are required to demonstrate the institution has the capacity, teaching facilities and infrastructure to support such growth. Under measures proposed in the White Paper, sponsors will also have an additional requirement to demonstrate they are considering local impacts when taking its decision on international recruitment.

6% Levy on International Student Fees

According to the White Paper, the Government will explore introducing a 6% levy on international student tuition fee income received by Higher Education Providers. This would be reinvested into the higher education and skills system and further details will be set out in the Autumn Budget. If implemented, it is anticipated that Higher Education Providers are likely to pass on the levy to international students with increases in tuition fees. This could, in turn, adversely affect the attractiveness of the UK as a study destination. Any decrease in international student numbers coming to the UK would place UK Higher Education Providers under further financial strain.

Short-Term Student Visa Review: Stricter Accreditation Checks

The Short-term Student Visa route is for individuals who wish to study an English language course in the UK between 6-11 months at an ‘accredited institution’. The White Paper confirms that a review of the Short Term Study accreditation bodies will be conducted in order to address concerns that this unsponsored visa route has a high rate of visa refusals due to ‘genuine student’ concerns. Accreditation bodies do not have any duty to report non-compliance in the form of failure to enrol or complete an English language course.

Applications made under the Short Term Student (English Language) route have already been subjected to a new 'genuine intention to study' rule since 9 April 2025. However, a review of accreditation bodies is intended to ensure that their processes are robust, consider what further checks need to be put in place to ensure the right level of scrutiny is being applied both before an organisation is accredited and when that accreditation is renewed.

Additional Impacts on International Students

Graduate Visa Cut to 18 Months

This proposal is designed to ensure that international students transition into graduate level jobs However, the reduced duration of the Graduate Route could make it less likely that graduates will achieve the graduate level employment for which the Graduate Visa route was created. Such changes to the Graduate visa route may also decrease the attractiveness of the UK as a study destination with international students choosing countries with more generous post study work visas.

New A1 English Requirement for Dependants

This is the first time adult dependant partners of students will be required to meet an English Language requirement (at A1 Basic User level). This change is aimed at increasing the ability of migrants to integrate in the UK, seek employment and contribute to society. However, the ability for international students to bring dependants to the UK has already been significantly reduced in recent years and such a proposal could disproportionately affect dependants who are not from English speaking countries.

Next Steps for Education Providers

Should the measures set out in the White Paper be enacted, it will be imperative that licensed student sponsors take steps to ensure their international student policies and processes are sufficiently robust to meet higher BCA metrics and withstand rigorous UKVI scrutiny.

Contact us

We can assist with strengthening your compliance processes or answer any queries about how the proposals in the White Paper may affect your education institution and international students. Please contact Anna Blackden in Doyle Clayton’s Immigration team.