How can UK universities avoid UKVI ‘action plans’?

London: Recent news of the University of Glasgow and the education provider Study Group being placed on UKVI ‘action plans’ has reignited concerns about visa fraud at UK institutions and called into question how universities can enhance compliance efforts.

As per Home Office guidelines, “an action plan gives a sponsor who has committed a breach, short of a serious breach, an opportunity to improve its processes”.

The plan, which typically lasts three to six months, is intended to “ensure that it does not become necessary for UKVI to revoke [the institution’s] licence” required to enrol international students.

The reasons behind Glasgow and Study Group’s action plans have not been disclosed, though the Home Office requires sponsors to have a visa refusal rate of less than 10%, a course completion rate of at least 85% and an enrolment rate of 90%.

The primary reasons universities face action plans are not typically visa refusals but rather students’ non-arrival, absconding, or failure to complete their studies, Enroly’s compliance experts told The PIE News.

“These concerns often stem from misrepresented English language proficiency, academic backgrounds or financial instability,” they explained.

Study Group and the University of Glasgow are not the first sponsors to be subject to action plans this academic year. They join the University of Central Lancashire (UCLan), De Monfort University and Nottingham Trent University, which are currently subject to action plans.

“Sponsorship is a privilege, and it is right that education providers sponsoring international students to come to the United Kingdom must help to ensure the integrity of the system,” a Home Office spokesperson told The PIE, adding that they would take appropriate action against sponsors misusing this privilege.

Following a surge in international student recruitment in recent years, UKVI has recommenced university audits and heightened regulations, “exposing institutions that still rely on manual compliance processes like spreadsheets and email chains,” said Enroly.

During the pandemic, UK institutions experienced an “unprecedented” surge in applications from traditionally high-risk markets including India, Pakistan, Bangladesh and Nigeria, Syed Nooh, UEA’s head of global insights and market development told The PIE.

As Nooh explained, this was largely due to the UK’s open border policy, but it also led to a rise in fraudulent applications across the sector.

“As a result, we are now seeing significantly more UK universities requiring deposits from international students – including Russell Group institutions – with some institutions increasing the deposit amounts, and increased scrutiny on the legitimacy of applications,” he said.

While compliance pressures are intensifying, there is no definitive evidence that the sector is in permanent decline

As UK institutions grapple with a sector-wide financial crisis, tight funding and outdated systems have led to reduced staff training capacities resulting in compliance breaches as universities struggle to meet increasingly ambitious financial targets.

Furthermore, economic instability in key markets such as Nigeria has left many students unable to pay tuition fees, further compounding enrolment challenges.

“However, from a longer-term perspective, the challenges are not unprecedented,” said Enroly.

“Economic and political conditions have always influenced international student mobility, and while compliance pressures are intensifying, there is no definitive evidence that the sector is in permanent decline,” they maintained.

In the complex process of international student recruitment, there are certain compliance gaps identified by Enroly that can trigger the issuance of a UKVI action plan.

These include a lack of due diligence on financial documents which is particularly important for students coming from high-risk regions flagged by UKVI.

Additionally, while many institutions hold pre-CAS credibility interviews to help identify students likely to struggle with visa or academic requirements, these are not uniformly applied across the sector.

Post-arrival monitoring of enrolment rates, attendance, and visa compliance on matters such as working hours, as well as academic achievement tracking to identify students at risk of failing or withdrawing, are also vital, explained Enroly.

Implementing Enroly’s CAS Shield, which helps admissions, compliance and recruitment teams work together to meet UKVI regulations and mitigate risk, can be instrumental in helping institutions meet enrolment targets, according to recruitment teams.

Universities use the shield to enhance transparency by bringing students, agents and staff together on one central platform. It also automates administrative tasks, freeing staff from manual processes of spreadsheet tracking and email-based approvals.

For Nooh, compliance starts with recruitment teams: “Ensuring [they] are well-trained and have up-to-date knowledge of UKVI regulations is crucial.

“With appropriate training, they can effectively pass on this knowledge to agents and identify fraudulent applications before they are submitted,” he said.

Nottingham Trent University, while unable to comment on the plan as it is ongoing, clarified that it remained licensed to sponsor students under the Student Sponsor Route.

De Montfort University, which also remains lisenced to sponsor international students and has a new London Campus opening later this year, said that it took its responsibilities “very seriously” and had agreed “to take a few actions” to evidence its compliance.

The PIE did not hear back from its requests for comment from the University of Glasgow, Study Group and UCLan. It is unclear whether the institutions remain licensed to issue CAS’s while subject to the plans.