The story this summer

August is a particularly important month in the application cycle because it represents such a large share of all applications lodged throughout the year – at least a quarter of the total. More broadly, the summer months plus September comprise about 70% of all applications. This year, applications fell by -17% in August and by -18% across June, July, and August.

These declines are even worse than last summer, when the Dependants Ban deterred many “main” (i.e., student) applicants because they could no longer bring their families. About 99,500 main applicants applied in August 2026 – 20,800 fewer than in August 2025, and the lowest count since tracking began in 2022. The following chart, created by Spencer Withrington for a recent article in his market intelligence newsletter, , shows that the downward trend has characterised all months of 2026 so far.

The Dependants Ban continues its work

The Dependants Ban means that the Home Office will only process applications from a family member of a student if that student is in a research master’s or PhD programme. This has resulted in a cumulative drop of -88% in dependant applications between December 2023 (the last month before the rule took effect) and August 2026. Dependants can only apply when their submission is attached to that of the student they hope to accompany, which means that the fall in dependants’ applications is also a factor in lower applications from students themselves.

Visa refusals will further influence enrolments

Looking for a moment at spring 2026 trends, 31,222 sponsored study visas were granted in Q2 2026, a -43% drop in issuances compared with Q2 2025. While fewer applications were most of that story, a high visa refusal rate of about 8% in that quarter was also influential. Visa rejection rates are variable through the year, and the rate in the second half may prove to be lower than the first half. Still, Q2 trends alone remind us that of the low number of applications received the summer months of 2026 (181,500), several thousand will likely be refused.

Q2 2026 visa data show that refusal rates were especially high for key sending markets including India, Nigeria, Bangladesh, and Ghana, and that visa grants were very low for India, Nepal, Nigeria (down by least -50% compared with Q2 2025) and especially Pakistan (-90%).

Contributing factors

In 2025, it was primarily the Dependants Ban that depressed sponsored study visa applications. This factor is still in play, but it is now joined by a host of other ones.

One of these is the UK’s Basic Compliance Assessment (BCA) framework and its accompanying Red-Amber-Green (RAG) banding system. As of 1 June 2026, the RAG system obliges UK institutions to maintain a visa refusal rate of less than 5%. Universities whose refusal rates reach above that benchmark can be subject to sanctions or even to the suspension of their license to sponsor international students. This is causing many institutions to apply much greater scrutiny to student applicants. Some are taking it a step further and limiting or pausing recruitment in markets where visa rejections are high.

Pakistan is a good example of the combined effect of high visa refusal rates and the RAG system on applications. Pakistani students don’t want a rejection on their record, and they know they are increasingly likely to receive one if they apply. They are also seeing some UK universities lose confidence in recruiting in their country due to the RAG system. At the same time, Pakistani students are aware of a growing list of compelling alternative destinations.

The spike in withdrawals

Again, we can use Pakistan to illustrate another trend that will affect enrolments in UK universities in 2026 and 2027. As a sending market, Pakistan held up remarkably well after the Dependants Ban, with +13% more Pakistani main applications in 2024 despite an -85% drop in Pakistani dependant applications. But now that Pakistan is more affected by the RAG, visa decision delays, and high rejection rates than many other sending markets, the patience of the market is being tested. In late-2025, only a few hundred Pakistani students withdrew their sponsored study visa applications. In Q1 2026, nearly 3,000 did.

Pakistan is the most striking example of a rising withdrawal rate, but it is not the only one. In Q4 2025, the total number of withdrawals (from all sending markets) was under 2,000. In Q1 2026, withdrawals more than tripled to about 7,000.

Things to think about

In the conclusion to Admit’s Issue 021 newsletter, Mr Withrington leaves university leaders with a few questions they might ask themselves about two key markets as a result of low applications and more visa rejections in the first three quarters of 2026:

• “Do you know your own refusal count for Nigeria for the September 2026 intake? Enroly’s rate is 12% and the Home Office’s for April to June was 25%. If yours is anywhere near either, ask whether one market is enough on its own to carry you over the 5% line.

• What happens to your recruitment plan if Chinese demand falls by a fifth, the fall the Home Office table shows for the summer as a whole? On Day 28 China supplied more than all of the sector’s growth in undergraduate international acceptances.”

In June 2026, Professor Malcolm Press, president of Universities UK, was quoted in a government release announcing the RAG system. Mr Press said the sector committed to partnering with the government on integrity concerns, but he warned:

“What universities need from government is policy stability, transparent visa decision-making, and real-time data to act on emerging concerns. The sector relies on international student income, and recent sharp declines have led to substantial cost-cutting and job losses. It is essential that we build a fair, stable, and transparent system that works in the national interest …. International students bring significant economic and soft power benefits, contributing £37 billion in export earnings.”

For additional background, please see:

• “UK: Visa application withdrawals surpass refusals in Q1 2026”
• “UK: Sponsored study visa issuances down, rejection rates up, and more”
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment”

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The research found that the government’s investment in foreign students – e.g., supporting them through health services, social security, and financial grants – is less than what students who remain in the country after graduating contribute to the economy.

About 20% of graduates from the European Economic Area (aka the EEA, which is the EU plus Norway, Iceland, and Liechtenstein) stay for at least some time in the Netherlands. This rises to around 40% of non-EEA students. The overall stay rate is approximately 25% more than 10 years ago.

Non-European students contribute more revenue

The benefits of EEA versus non-EEA students are different. EEA students pay the same tuition as Dutch students – €2,694 in 2026 – and can apply for student finance under certain conditions. Therefore, the costs of hosting them during their studies is higher than for non-EEA students. By contrast, non-EEA students pay full fare and cannot access financing, which means they contribute more revenue to universities while they study.

Even after graduating, non-EEA students who remain to work are more than twice as valuable to the Dutch economy than students from Europe. Over their lifetime in the Netherlands, non-EEA students contribute €243,000 compared with €82,500 for European students.

But what about housing?

CBP found that: “More international students do add to housing pressure in the short term. But over time, the effect is limited, because the market adjusts – and how far it does depends on housing policy, not student numbers.”

The housing situation for students in the Netherlands is so dire that some domestic students give up and either resign themselves to hours-long commutes from their family home or abandon applying to their preferred university because it is too far. As reported in the , “some universities, including the University of Amsterdam and Utrecht University, now officially advise incoming international students to reject their academic admission offers and stay home if they have not secured a verified housing contract prior to the start of the semester.”

A recent survey completed by social policy thinktank of 700 international students found that almost one-third reported searching for more than three months before securing accommodation. That research, and significant media coverage, finds that some students never secure suitable housing, leaving them vulnerable to homelessness and thievery.

Hanna Smit, a housing consultant at Dutch tenant rights firm Stichting WOON, advocates for significant investment in student housing on campuses, explaining that “because student campus projects are specifically zoned, they do not compete for land or resources with regular, high-priority residential housing developments.” This recommendation should be broadly interesting to governments in other major study abroad destinations, where public concern about housing often leads to negative perceptions of immigration levels and/or international students.

Despite the housing crisis, over 80% of international student respondents to the ResearchNed survey said they were satisfied or very satisfied with their experience in Dutch higher education.

A self-imposed cap

Just before the CPB released its research findings on the tangible benefits of international students, 13 Dutch universities signed an agreement on 15 July 2026 with the government to self-regulate their foreign enrolment volumes. The universities have committed to admitting fewer than 17,000 foreign students every year. This volume represents an 11% decrease over allowed enrolments in 2022 and 2023.

Dutch universities’ English-language programmes are a major draw for international students. According to the agreement, the 13 universities will not develop any more of these programmes in the short ter unless they are tied to labour shortages in sectors including STEM, healthcare, and technology. Also exempted are programmes developed within the European Universities framework, which is based on deep institutional cooperation across EU nations.

Some industry experts have criticised the deal, pointing to “random [international enrolment] targets” that fail to consider the sharp contraction of the Dutch working-age population and economic labour shortages. Max van Duijn, chair of the Young Academy of the Netherlands (De Jonge Akademie), told :

“Internationalisation should not be viewed as a problem to be tackled, given that it is a precondition for a well-functioning academic system and for an innovative country with an open economy.”

For additional background, please see:

• “Netherlands reports first-ever decrease in foreign enrolment for 2025/26“
• “Dutch government walks back controversial measures to constrain English-taught degrees“

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They are Bridge Mills Galway Language Centre, Emerald Cultural Institute, International House Dublin, Liffey College, and Patrick’s English Academy.

Those five schools now join that have to date also been awarded the mark.

The announcement of the first language school awards, said Dr Lynn Ramsey, CEO of QQI, “marks a new era of quality oversight and regulation for the English-language education sector in Ireland, with the establishment of formal, statutory engagement with QQI. Under the scheme, QQI has a statutory monitoring responsibility to ensure providers adhere to the agreed code of practice, ultimately ensuring that the rights of learners are protected during their time studying in Ireland.”

An accompanying statement from QQI provides important background: “To obtain TrustEd Ireland authorisation, [ELT] providers must undergo a thorough due diligence assessment, which examines areas such as financial and legal structures and business plans to establish the capacity and capability of private education providers to deliver quality assured education programmes.

“Under the scheme, providers must also have quality assurance procedures that are approved by QQI and demonstrate compliance with an associated Code of Practice.” (Note that there are distinct Codes of Practice for and for .)

Replacing the ILEP

The continued expansion of the TrustEd Ireland scheme has additional significance beyond its role as an official quality mark. First, the provisions for the mark are enshrined in Irish legislation. QQI’s powers to assess and monitor providers and to enforce the requirements of the scheme also arise from that legislation.

Second, the TrustEd Ireland mark will shortly become the basis for determining whether or not an Irish institution or school is eligible to recruit non-EU students. In other words, it functions as a licence to operate in the international student market, at least in terms of recruitment of non-EU/EEA students that require a visa to study in Ireland.

The current mechanism for this is the Interim List of Eligible Programmes (ILEP), which is maintained by the Department of Justice’s Immigration Service Delivery. The ILEP, however, will shortly be superseded by the TrustEd Ireland scheme.

First announced in 2024, an initial window for applications for the TrustEd Ireland mark opened from 14 October 2024 to 28 March 2025. A second window was opened from 13 October 2025 to 27 March 2026, the decisions from which are expected by the end of this year.

After that point, the ILEP will be replaced by a new TrustEd Ireland Authorised Providers: List of Eligible Programmes. QQI explains: “The new TrustEd Ireland list will identify those programmes that comply with immigration requirements to enable Immigration Service Delivery (ISD) in the Department of Justice, Home Affairs & Migration to determine applications for study visas and immigration permissions for study purposes.”

“All education providers intending to recruit non-EU/EEA/Swiss students that require study visas or immigration residence permissions for the purpose of study (where such residence exceeds 90 days) must ultimately secure authorisation from QQI to use the TrustEd Ireland mark.”

For additional background, please see:

• “Ireland to open applications for new quality assurance mark in September 2024“
• “Ireland’s ELT sector reports modest growth in student numbers but weeks are down amid ‘real and consequential’ challenges“
• “Irish higher education reports a fourth straight year of foreign enrolment growth“

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This is the most serious sanction that can be levelled against a licensed sponsor. Revocation of the sponsor licence means that Bloomsbury, formerly the London School of Business and Management, immediately loses the ability to sponsor international students under the UK’s Student Route.

This means that it can no longer issue Confirmation of Acceptance for Studies (CAS). Any CAS already issued also now becomes invalid, and any pending visa applications based on a Bloomsbury CAS will be refused. The Institute will also be removed from the Register of Student Sponsors.

The revocation of the Bloomsbury Institute’s sponsor licence on 5 August 2026 follows the suspension of its licence on 9 June 2026, from which point it was forced to also suspend recruitment of international students.

The Institute’s licence was in the balance this year because Bloomsbury had not maintained compliance with the Basic Compliance Assessment (BCA) requirements. As the Home Office explains: “The Basic Compliance Assessment is an annual check that all sponsors must pass, measuring visa refusal rates, course enrolment and completion.”

Those BCA thresholds tightened this year, but Bloomsbury was assessed against the earlier benchmarks, which required that all sponsors maintain a visa refusal rate of less than 10%, an enrolment rate of at least 90%, and a course completion rate of at least 85%.

“Student sponsors must meet the standards required to retain their licence,” said the Home Office. “Failure to meet these standards represents a serious breach of its duties as an international student sponsor, and as a result, [Bloomsbury’s] licence was revoked.”

Effective 1 June 2026, the BCA thresholds were further strengthened such that visa refusal rates must be maintained below 5%; the course enrolment rate must be at least 95%; and the course completion rate must be at least 85%. Perhaps unnecessarily, the Home Office notes as well that, “The Bloomsbury Institute would also have failed to meet the new, stricter standards.”

A largely international student body

For 2024/25, the most recent available reporting year, HESA data indicates that the Bloomsbury Institute enrolled a total of 1,035 students. More than 800 of those, or nearly 80%, were international students, with the lion’s share (93%) coming from Pakistan.

The revocation of the sponsor license necessarily places the study programmes of those students, and even the future of the institution, in question. The Home Office says that its priority now is to “minimise disruption for international students already enrolled” at Bloomsbury.

To that end, the Institute “will be permitted to continue teaching its current sponsored students for a short period,” the term of which is not specified. Students who cannot complete their studies within that window will be supported to transfer to another institution.

Needless to say, those provisions are an important feature of the Home Office announcement. The headline is that a UK institution has had its sponsor licence revoked. But of course, behind that headline, are the many affected staff and students who now must deal with the uncertainty that accompanies this sanction against their institution.

For additional background, please see:

• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“
• “UK universities bracing for a further decline in international enrolments“
• “England: Government ‘remains of the view’ that the International Student Levy should go ahead; implementation planned for August 2028“
• “UK: Sponsored study visa issuances down, rejection rates up, and more“

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• The 685,565 foreign students in UK higher education in 2024/25 accounted for nearly a quarter of the total system enrolment that year;
• The total net economic impact of the 2024/25 cohort alone was estimated at £40.4 billion across the duration of their studies;
• The net economic impact estimates equate to £100,000 per international student, or £1 million in net economic benefit for the UK economy for every ten students over the duration of their studies;
• Student commencements have declined by -12% from a peak in 2022/23, at a cost to the UK economy of £2.9 billion;
• The net economic impact from the 2024/25 cohort equates to an average of £580 per UK resident per year.

Those key findings come from a recently released report from London Economics. Published in July 2026, was commissioned by the Higher Education Policy Institute (HEPI), and Kaplan International Pathways.

This type of impact analysis is not new, but it is an important part of the evidence for international education’s impact on institutions and national economies. At a time when there is rising public concern around immigration levels in many key study destinations, this type of analysis is crucial to the discussion.

“Immigration is a top concern for voters in Britain, and it is important that the debate around immigration policy is informed by evidence,” says HEPI Director of Policy and Strategy Rose Stephenson. “This report shows that international students generate very substantial benefits for the UK economy and underpin the financial sustainability of many universities. If ministers decide to further reduce international student numbers, they should be clear that there will be economic costs as well as potential political benefits. At a time when the UK is seeking stronger economic growth, those trade-offs deserve an honest and open discussion.”

There is a growing awareness across the sector, however, that those national impact figures may not affect public opinion in a meaningful way. The benefits arising from international enrolments can be unevenly distributed from community to community, and the linkages between international students, the financial health of institutions, and broader issues of innovation and productivity in the economy are not often well understood.

Writing about a recent roundtable of higher education leaders, IDP Director of Partnerships Rachel MacSween and Woke Editor Debbie McVitty , “Attendees agreed that the abstract economic returns argument has hit a ceiling, and simply doesn’t resonate with the key groups of voters that regional policymakers need to keep onside. Others – particularly those from parties intrinsically hostile to immigration in general – may see the numbers but simply care more about other political pressures and perceived risks.”

Trying something different

This brings us to the most interesting aspect of the London Economics report this year. As the authors explain: “For the first time, the analysis uses newly available detailed data on students’ term-time addresses, providing a more accurate picture of the local economic contribution made by international students across the UK. The findings show that these benefits are spread across all nations and regions of the UK.”

The analysis moves beyond the national-level figures we summarised above to provide a more detailed view of how that impact is distributed throughout the UK, region by region and parliamentary constituency by constituency.

An accompanying allows users to examine the impacts for each parliamentary constituency in the UK, such as we see in the example below.

The report finds that the impact of foreign enrolments is distributed throughout the UK economy, with “constituencies from nine regions featuring in the top 20 in terms of total UK impact, and constituencies from all regions featuring in the top 40.”

Even as illustrated in the table of top ten constituencies above, the impact varies widely by community, with the net national average benefit, per resident, estimated at £580.

There is something powerful in this model, as it brings that national impact down to the level of the individual community and even individual resident. The report is transparent about how those benefits are distributed. But it also makes clear that there is an impact in every part of the economy arising from international students, and that that impact can be quantified for each household.

Stepping back from this particular example in the UK, there are important lessons in this for every study destination in terms of how that more granular analysis could be employed to demonstrate the concrete, local impacts of international students. The London Economics report feels like an important evolution in the evidence base we have, and one that could make a meaningful contribution to building the social license for international education at the community level and therefore meaningfully affecting policy-making as well.

For additional background, please see:

• “Australia poised to further restrict immigration in bid to drive down net migration figures“
• “The power of data and narrative in building public support for international students“
• “Under pressure: How global migration and economic trends are impacting international education“

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The programme will draw €420 million from the European Structural and Investment Funds (ESIF), which support cohesion and equality across member states, and it will be administered by the Ministry of Education. Students will see their travel, living costs, food, and accommodation covered under the terms of the scholarship.

Minister for Education and Merit Giuseppe Valditara and Prime Minister Giorgia Meloni announced the initiative together at a conference called “.” Details about timing will be released in the coming months.

Most scholarship students will go for two-week periods for language studies or immersion in a foreign high school environment, but in some cases, longer durations will be possible. While away, students may participate in a range of academic and social activities, including visits to companies and other workplaces.

Speaking at the conference, Prime Minister Meloni urged the audience to consider the new initiative as more than an opportunity to learn another language:

“Living and studying in another country, even if only for a few weeks or months, means learning to deal with new situations, becoming more independent, and engaging with people who have different customs, ideas and cultures from your own. It therefore means expanding your minds and your ability to understand others. It means building self-confidence, learning to cope and broadening your horizons. Furthermore, for us it means enriching our community, because when the young people participating in this project come back, they will bring back much more than just better knowledge of and fluency in a foreign language. They will bring back new ideas, new friendships, greater self-confidence and a broader view of the world, all of which certainly represents an asset for them, but it will also be valuable for their friends, their families, their classmates and the whole of Italy.”

The scholarships will be awarded based on merit but also using the ISEE (equivalent economic situation indicator) to ensure that students from all backgrounds can participate regardless of income. Prime Minister Meloni spoke to the importance of language learning for removing barriers across class:

“Today, we live in an increasingly interconnected world. Universities, employers, research institutions, and companies are looking more and more for people who are able to navigate international contexts, and speaking another language, particularly having a good knowledge of English, is very important. However, it is even more important to be able to use that language in real life, and you can’t do that by simply learning a language from textbooks; you can only do that by managing to experience that language, immersed in the context in which it is spoken.

This is why we decided to invest in this initiative, above all because we believe our talented young people deserve the same opportunities as all their peers in Europe, for example. We believe that, in this day and age, young people’s talent cannot and must not be limited by a language barrier.”

The significance of this new mobility programme arises in part from the fact that Italy is already a major EU sending market for language studies, and it is, for example, a top market for English-language training providers in the UK, Ireland, and Malta.

To be more specific: Italy was the second-largest sending market for Irish ELT schools in 2025, accounting for 14% of student weeks delivered that year. It was the leading source market for UK ELT in 2025 as well, where Italian students booked just over 14% of all English-language learning weeks. And in Malta, Italy was again the second-largest sending market for 2025 with 12% of student weeks for the year.

For its part, English UK was quick to recognise the importance of the new €420-million scholarship programme and signalled to its members that it is already “working with the Department for Business & Trade and the British Embassy Rome to present a unified UK offer.”

For additional background, please see:

• “Italy rises as a study destination but struggles to retain foreign graduates”
• “Malta: Non-EU students keeping ELT weeks stable in the face of falling enrolment from Europe”
• “UK’s ELT sector reports declining enrolments through first quarter of 2026”
• “Ireland’s ELT sector reports modest growth in student numbers but weeks are down amid ‘real and consequential’ challenges”

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The scrutiny is coming from more than one direction. Admissions offices are tightening their own checks on the authenticity and consistency of English-language evidence, in response to well-documented fraud vulnerabilities and inconsistent evidence standards across the sector.

At the same time, UK Visas and Immigration (UKVI) now runs an annual Basic Compliance Assessment (BCA) for every institution holding a student sponsor licence, scoring them on visa refusal rates, enrolment rates, and course completion rates. Falling short on any one of those metrics can strip an institution of the right to self-assess a student’s English ability altogether, forcing a shift to mandatory secure testing across the board. Further, a new Agent Quality Framework is being extended so institutions can no longer treat agent-sourced evidence as somebody else’s responsibility. In short: the English-language evidence an agent helps assemble now feeds directly into a compliance metric that determines whether an institution can keep recruiting internationally at all.

That’s the backdrop and it’s also the opportunity. Agents who understand this chain of evidence, and can speak to it confidently, become more valuable partners to the institutions they work with, and better advisers to the students who trust them.

Academic readiness is the cornerstone of student success

Academic readiness is the strongest predictor of first-year performance, progression, retention, and completion. When students arrive without sufficient English proficiency, the impact is immediate: difficulty engaging in seminars and group work, falling behind in reading-intensive modules, rising stress, and a higher likelihood of assessment failure or withdrawal.

Meeting a minimum entry requirement isn’t the same as being ready to perform at it. A student who scrapes the headline overall score with a weak reading or writing subscore is often the one who struggles most in postgraduate, research-intensive programmes, where extended reading and academic writing carry most of the assessment weight.

In practice, that means: looking with the student beyond the single overall band to the subscore breakdown; recommending a margin above the minimum particularly in speaking and writing wherever a programme is writing- or seminar-heavy; and encouraging an early retake where subscores are borderline, rather than waiting until an offer is at risk. Agents who steer students toward the cheapest or fastest route to a passing score to obtain a visa rather than genuine readiness, aren’t doing anyone any favours: those are the students most likely to need extra support, delay progression, or withdraw outcomes now visible to institutions through the BCA’s own completion-rate metric.

The growing scrutiny of MOI

Medium of Instruction (MOI) evidence is under sustained scrutiny, and institutions increasingly treat it as a case-by-case judgement rather than a standard alternative to testing. Practice varies widely: some institutions require MOI letters to be corroborated by transcripts, curriculum details, or interview; others have withdrawn MOI acceptance for certain markets or programmes altogether, following BCA findings that linked MOI-based admissions to weaker completion or higher visa refusal rates.

For agents, that means treating an MOI recommendation as a considered call each time, not a default and being able to talk a student through the reasoning.

Three questions are worth working through together: First, does the receiving institution’s current policy actually support MOI for this student’s country, subject, and level of study? Policies here shift often, so this is worth checking fresh for each application rather than assumed from a previous case. Second, was the student’s prior study substantively delivered and assessed in English not just described as such on paper in a way that plausibly matches the demands of postgraduate or research-intensive study in the UK? Third, is an MOI-based application more likely to trigger additional verification, delay an offer, or be queried at visa stage for this particular market?

Where any of these three is uncertain, recommending secure testing alongside or instead of MOI is the safer, more defensible choice for the student’s academic readiness, and for the agent’s credibility with the institutions they work with.

Secure testing as a strategic enabler

Secure English language testing is worth repositioning, in conversations with students, as more than an entry hurdle. It supports identity validation, demonstrates genuine academic readiness, reduces institutional exposure, and gives students greater confidence going into study. Viewing testing as an unnecessary cost is short-sighted: the real cost is poor preparation academic, financial, and emotional. Framing testing as an investment in a student’s own success, rather than a bureaucratic step, tends to land better with students and parents alike and it happens to be true.

BCA reviews are raising the bar

The Basic Compliance Assessment is an annual Home Office review of how well a sponsoring institution is managing its international student population against three metrics: visa refusal rates, enrolment rates, and course completion rates. Institutions rated amber or red face restrictions including, in some cases, losing the right to self-assess English-language ability, which pushes their entire cohort toward mandatory secure testing. As English-language evidence sits upstream of all three metrics a student who was never really ready for the course is more likely to be refused a visa, to under-enrol, or to withdraw, institutions are having to demonstrate, more rigorously than before, how that evidence was gathered, verified, and judged sufficient at the point of offer, both to their own compliance teams and to UKVI itself.

Agent-sourced evidence is now squarely inside that chain of justification. As regulatory attention on institutions increases, so does attention on the English-language guidance and evidence that agents provide upstream of the admissions decision. Weak guidance creates a vulnerability that traces all the way back to an agent’s file; strong guidance protects the student, the institution’s compliance record, and the agent’s own standing with institutional partners.

Defining practice that works for students and agents

A forward-looking standard is emerging, and it rewards informed, student-centred practice, which includes:

• Recommending the right test for the destination and programme, factoring in university acceptance, subject demands, security requirements, and timing
• Where subscores are borderline, especially speaking and writing for postgraduate, research-intensive courses, advising testing to a margin above the stated minimum, and supporting an early retake rather than a late one
• Treating MOI as a case-by-case judgement using the three questions above, not a standard substitute for testing
• Communicating secure testing to students as an investment in their own progression, not a hurdle to clear
• Keeping documentation authentic, consistent, and aligned with each institution’s current expectations, since these shift
• Engaging admissions teams early to confirm current requirements and reduce delays

These aren’t extra burdens layered on top of an agent’s advising role they’re the parts of that role now most visible to institutions, most consequential for students, and most likely to distinguish the agents that institutions want to keep working with.

The role of agents in a changing landscape

Agents are often a student’s first trusted adviser. Their guidance shapes not just admission outcomes but a student’s confidence, performance, and ultimately their success once they arrive. Getting the English-language piece right is one of the clearest, most immediate ways an agent can add value to that relationship and one of the clearest ways to build a track record that institutions notice.

How ELSAA supports the sector

ELSAA is the English Language Standard Advisory Authority [link to https://englishlsa.com]. Our mission is to strengthen standards, improve transparency, and support risk-aware decision-making across the English-language ecosystem. We work with agents and institutions to:

• Interpret emerging regulatory and compliance expectations
• Identify appropriate English-language pathways
• Reduce institutional and agent risk
• Improve student progression and retention
• Build trusted, future-ready recruitment practices

Agents who build this expertise put students at the centre of every decision and in doing so, strengthen their own standing with the institutions they work with. Strong English-language guidance isn’t an extra step; it’s the advantage.

The English Language Standard Advisory Authority (ELSAA) is an independent organisation dedicated to improving transparency, understanding, and informed decision-making in high-stakes English language testing. Through independent test reviews, comparative analysis, training, and advisory services, ELSAA supports universities, professional bodies, employers, and policymakers in evaluating and using English language assessments with confidence.

For additional background, please see:

• “Study highlights gaps between English standards set by test developers and those used by universities and professional bodies“
• “Narrowing bands of compliance: How the UK’s new RAG system will impact international student recruitment“

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Now, on 13 July 2026, the Department of Education (DfE) has released its response to the 91 submissions filed during a technical consultation that had been open from November 2025 through February 2026.

Despite considerable opposition from institutions, peak bodies, and other stakeholders, the government has affirmed that . It provides the following details:

• The levy will apply to all institutions registered in the Office for Students’ registry of English higher education providers;
• The levy will apply only to international students – that is, to students who do not qualify for home fee status;
• Each provider will receive an exemption for the first 220 students in a reporting year, for which no levy fees will be charged;
• Student counts will be based on an existing reporting mechanism: the Jisc Student Record for higher education institutions and, for further education providers of higher education courses, the Individualised Learner Record (ILR).

The Department of Education explains that the following student groups will be exempt from the levy:

• Students who withdraw within two weeks of a course start;
• Those enrolled in transnational education (TNE) programmes outside of the UK;
• Students enrolled only in non-credit courses;
• Post-doctoral students.

The Department indicates, however, that the levy will be charged for students who withdraw from their programme of studies after the initial two-week grace period.

The 13 July DfE response also sets out the timeline for implementation, indicating that the government will run two trial cycles during the 2026/27 and 2027/28 academic years. No fees will be charged during those trials, but the levy calculations will be reported back to providers each year. The levy will come into effect on 1 August 2028 and apply to international students from that point forward.

The government will next table legislation to formally establish the levy as part of the Finance Bill which will be introduced after the government brings in its next budget this fall.

Those opposed

As late as last week, sector leaders had urged the government to reconsider. Speaking at a Higher Education Policy Institute forum on 9 July, Durham University Vice-Chancellor Karen O’Brien said that the levy was “absolute insanity” and urged the government to take it “off the table”.

Earlier this month, Universities UK Chief Executive Vivienne Stern said that the levy “puts us in the bizarre situation of the government effectively putting a tariff on a UK export.”

Many of the submissions filed during the November–February consultation projected that the levy would undermine international student recruitment to the UK, and, by extension, the financial stability of the sector.

In its submission, for example, Universities UK says: “Recent data shows that international student recruitment has fallen materially and remains highly volatile. HESA student record data for 2024/25 shows total international enrolments down 6.1% year-on-year, driven primarily by a 12.5% decline in postgraduate taught enrolments, which have historically underpinned institutional financial sustainability. Home Office visa data indicates that while visa issuances have stabilised in aggregate, volumes remain 13.5% below 2023 levels and market composition continues to shift sharply. These data show that international recruitment is no longer a stable or steadily growing revenue base, but one characterised by sharp year-on-year swings, market concentration and policy sensitivity, increasing the risk that a per-student levy amplifies volatility rather than delivering predictable funding.”

Maike Halterbeck, a partner at London Economics, offered this comment on the release this month of a new Higher Education Policy Institute study on :

“This new report provides updated evidence on the substantial economic value that international students bring to the UK economy – value that is spread widely across the country. However, it also demonstrates what the economy stands to lose if and when this major export sector starts to decline. The number of international first-year students coming to the UK has already decreased by around 54,500 (12%) since 2022/23, and is expected to continue to decline as key new policy changes – including the new international student fee levy – come into force.”

Finally, Vanessa Wilson, CEO of University Alliance, said:

“We are very disappointed that the government has decided to press ahead with the International Student Levy despite the serious concerns raised by universities across the sector. As we have consistently argued, international students make an enormous contribution to our economy, communities and campuses, and this levy risks undermining the UK’s attractiveness at a time of intense global competition.

“It remains deeply counterintuitive to tax institutions that are already delivering opportunity, skills, and social mobility at scale, only to recycle that funding elsewhere in the system. We continue to believe international students are being undervalued in policymaking, and we urge the government to use the implementation period to reconsider the levy’s impact on institutional sustainability and the UK’s long-term international competitiveness.”

For additional background, please see:

• “UK confirms international fee levy of £925 per student starting August 2028“
• “UK confirms levy on international student fees as new analysis argues that government is ‘drastically underestimating’ the impact of the move“
• “UK sets out new immigration strategy, will reduce Graduate Route work term to 18 months“

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