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Complaining to the OIA

by GR Evans

The Office of the Independent Adjudicator (OIA) has stressed in its Annual Report that the system it operates is under strain. The expectation that universities would offer a route for students to make  complaints became a requirement at the turn of the century as  providers began to recognise the existence of a ‘student contract‘. That made the student a ‘consumer’ of the ‘higher education provider’. ‘Complaints procedures’ for students to use began to appear alongside ‘grievance procedures’ for employees. Scrutinising the performance of higher education providers in that task falls to the Office of the Independent Adjudicator (OIA).

The OIA was created as a company in 2003 and began work as a voluntary scheme. It was designated as operator of a student complaints scheme in 2005. Its current ‘members’ are various sector bodies including  Universities UK and GuildHE. Its Board, headed by the actual Adjudicator, and it includes student representatives.

It first needed to show itself to be independent. The OIA faced criticism early on when a petition with 43 signatures, called for its abolition, complaining that it was a ‘biased, unreasonable, and non-impartial organisation. The petition called for:

Full evidence-based investigation into student complaints, fully independent of the University’s internal processes, and in accordance with existing educational and non-educational law,

and ‘a public enquiry into all decisions made against student complaints, by the OIAHE since its inception’, withnew rules:

to provide full legal aid cover for all students whose employment prospects are, or may have been, damaged as a result of their adverse experience with a public educational institution, and who remain unemployed as a result.

This was not followed through in those express terms. The stated objective of the process now followed by the OIA is to ‘put the student back in the position they  would have been in if the problem hadn’t occurred’.

Meeting that demand presents difficulties in two respects. The relationships of students to their ‘higher education provider’ have changed. They are its ‘members’ in the case of Oxford and Cambridge but in other providers a governing body of between twelve and twenty-four constitute the ‘members’ under the Higher Education and Research Act 1992. Elsewhere  they are likely to be, in effect, paying customers ‘buying’ a course. There is a contract and if the providers does not fulfil its part, the student may complain and seek redress in the form of repayment of fees.

A sense of student entitlement may arise from the sheer cost to a student. In England, tuition fees for the academic year 2026-7 will rise to £9,790 for standard full-time courses, £11,750 for full-time accelerated courses and £7,335 for part-time courses, for providers with a Teaching Excellence Framework award and an Access and Participation Plan. That will increase for the year 2027-8 to £10,050 for standard full-time courses, £12,060 for full-time accelerated courses  and £7,530 for part-time courses.  Costs for ‘maintenance’ and accommodation are additional.

The procedures to be followed in making a complaint have needed repeated updating. Key terms have had to be defined. For example, the Annual Report of Oxford’s Sexual Harassment and Violence Support Service reports ‘an increasing complexity of cases, and those requiring a longer duration of support’. Where there is a complaint it recognises the need for clarity as to whether a dispute is a ‘University’ or a ‘college’ matter, noting ‘a marked increase in college-based, student-to-student reports of reported incidents’. The University is therefore improving its provision for training to ensure that those with responsibilities for students are clear about what constitutes ‘consent’.

Nationally, is the system now simply overloaded? The OIA published its Annual Report in April, recording the scale of the  rise in the number of complaints it receives. In 2008 the OIA received 900 complaints against an England and Wales enrolment denominator of 2,117,535 – a rate of 42.5 complaints per 100,000 students. In 2025 there were 4,234 complaints, an increase of 17 per cent from the previous year. The 4,234 complaints in 2025 ‘translate’, it says, ‘to roughly 165.8 per 100,000. in 2025’. In October 2025  alone there had been 516 complaints, recorded as the busiest single month in its history. In the face of this demand the OIA  resolved 3,950 cases within six months and brought the average case handling time down to 81 days.

Stress-points are evident. Its Report notes that the complaints the OIA receives ‘prematurely’ are brought by students who ‘have begun the process but feel that they have waited too long for a decision’:

most of the complaints raised with us prematurely are brought by students who have begun the process but feel that they have waited too long for a decision. Delays are a symptom of a system under strain and may be one impact of the financial challenges facing providers.

Jim Dickinson’s blog for WonkHE on 26 April 2026 pointed to further evidence arguing that the fact that 42% of complainants now disclose a disability could mean a sector which is still structurally unable to accommodate them. So even if the growth in complaints may reflect an increasing sense of entitlement among students, the OIA suggests that the Adjudicator makes recommendations – or requires compensation to be made – that is ‘an indication that a student has not received the service they expect at a time when fees and cost of living pressures are increasing’.

The continuing multiplication of ‘alternative providers’ seems likely to lead to more complaining. They may admit unqualified students and be imperfectly regulated. The OIA publishes a list of ‘case summaries’ on providers where problems have emerged. The ‘worked example’ given in the OIA’s Report is that of Brit College, on which the OIA had already published concerns as of ‘public interest’ in November 2025.

The OIA had made Recommendations and had reported the College’s refusal to comply with its Recommendations to its Board in September 2025 and shared information about the complaint with the Office for Students (OfS), Department for Education (DfE) and Ofqual.  None of this led to reform. Companies House reports that Brit College Ltd is subject to Receiver Action, with its accounts and confirmation statement overdue and apparently heading for liquidation.

There seems, then, to be a question as to the effectiveness of the OIA not in terms of its work but in terms of its powers, where a provider of higher education falls beyond the reach of a complaints procedure.

SRHE member GR Evans is Emeritus Professor of Medieval Theology and Intellectual History in the University of Cambridge.


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Students in quality assurance – representatives, partners, or even experts?

by Jens Jungblut & Bjørn Stensaker

Throughout Europe, students are often regular members of external quality assurance mandated to perform evaluations and accreditations in higher education. While this role has been secured through the Standards and Guidelines for Quality Assurance in the European Higher Education Area (ESG), we have little knowledge about how students participate in such panels and which roles they take up. In a paper presented at the SRHE conference in Nottingham in December 2025, we addressed this issue – both conceptually and empirically.

One could imagine that there are several roles that students could play as part in an external quality assurance panel. Students are most often seen as representatives of their fellow students. This has implications as to how students are appointed to such panels, as various student interest organizations usually have the power to nominate specific students to the task. More recently, the idea of students being partners has also gained interest, where a key assumption is that students should be involved and participate in all aspect and processes related to their own education – including quality assurance. The initiative “student partnerships in quality Scotland (sparqs)” is a well-known example of this inclusive approach (Varwell, 2021). However, one could argue that students may even take on an expertise-based role in quality assurance. This type of role is not based on experience per se but rather the ability to reflect upon the knowledge possessed and the ability to engage in systematic efforts to learn more – based on these reflections (Ericsson, 2017).

In our paper presented at the SRHE conference we argue that the role of students participating in quality assurance panels (or any other related processes in higher education) may not be static, restricting students to merely one role at a time (see also Stensaker & Matear, 2024). We rather argue – in line with Holen et al (2021) – that the roles students may take on are highly dynamic. A consequence of this would be that students may shift rapidly from one role to another, depending on, for example, the evaluation context, committee setting, or the issue that is being discussed.

To test our assumptions, we conducted a survey targeting students taking part in European quality assurance processes; to be more specific, we targeted the `Quality Assurance Student Experts Pool` within the European Students’ Union. This group was established in 2009 with the aim to improve the contribution of students in quality assurance in Europe. When included in the pool, students undergo training sessions providing them with relevant background knowledge about quality assurance processes and the ESG. The members of the pool are then called upon by quality assurance agencies throughout Europe to act as student representatives on their quality assurance panels at program, institutional, or national level, performing evaluations, accreditations and other forms of assessments. The `Quality Assurance Student Experts Pool` therefore represents a unique entity in Europe, as it is the only European structure that collects and trains students for these roles. 35 students (of a total of 90) responded to our survey.

The students responding have on average been involved in quality assurance for more than four years, and over 60 percent have participated in four or more evaluation or accreditation processes. In line with our expectations, the students indeed report that they are taking on several roles during the evaluation processes, they are representatives of students, they feel they are equal partners within the evaluation panel they are part of, and they also see themselves as experts. In our data, we could not identify a clear hierarchy between the different roles. However, our data suggest that students are often perceived as a partner, while less often as experts. A possible interpretation here is that temporality and experience matter: students may be initially viewed as a representative and as a partner when starting their work within the panel, and through the process of participating in multiple panels over time they might demonstrate expertise which is in turn recognized by their peers in the panels. An interesting feature coming out of the data is also that the students in the `Quality Assurance Student Experts Pool` regularly share knowledge among the members of the pool, and in that way contribute to continuously build the expertise of all members. Expertise is in this way not taken for granted or expected as a prerequisite for being a member, but rather nurtured, systematised and made available to newer and future members.

We want to thank all the students that bothered to respond to our small questionnaire. While our study is exploratory, we do think it provides new insights regarding student involvement and influence in a setting characterized by a high level of expertise and professionalism, and we hope that the findings can help future research to further unpack the dynamic nature of students’ roles in quality assurance panels.

Jens Jungblut is a Professor at the Department of Political Science at the University of Oslo. His main research interests include party politics, policy-making, and public governance in the knowledge policy domain (education & research), organizational change in higher education, agenda-setting research, and the role of (academic) expertise in policy advice.

Bjørn Stensaker is a Professor at the Department of Education at the University of Oslo. He has a special research interest in governance, leadership, and organizational change in higher education – including quality assurance. He has published widely on these topics in a range of journals and book series.


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What does it mean to be political for today’s students?

by Rille Raaper

When we think about student politics, it is inevitable that the images of student protest and rebellion come to mind. These views of what counts as student politics have been shaped by rather romantic ideals of what it meant to be a student and do politics in 1960s, or perhaps even in 2010-2011 when we witnessed the last large scale student rebellion in England, but also more globally. When we stretch our imagination, perhaps we can also see students engaging with electoral politics, and them being stereotypically more left leaning compared to the general population – or ‘woke’ as portrayed by many right-wing media outlets today. In cases where students do not meet these expectations of political activity, they are often derogatively called ‘snowflakes’: a fragile generation of apolitical students. While there may be some truth in students becoming less politically active, it is important to question why this might be the case, but also to consider the extent to which our own understandings of student politics are perhaps outdated and need changing.

The cost of student protest

In contexts where higher education is marketed as an investment into one’s future, the student-as-consumer positioning becomes unavoidable. Consumerism in our universities may be brutally explicit as in the UK where students are protected by the Consumer Rights Act 2015, or more subtle in systems where laws and regulations do not treat students as consumers, but the transactional idea of higher education and human capital development still imply similar understandings. As students are constantly reminded to prioritise ‘value for money’ and question their investment into successful graduate employment, deviating from such a mindset and standing out as a disruptive or disobedient student cannot be a preferred or safe option. This was evident with the recent pro-Palestinian encampments which on British campuses were rather short-lived, often adopted around the exam periods and ending with the closure of the academic year 2023/2024. The cost of non-compliance is very high for our students: how could a student who has accumulated an average of £45k student debt with already insecure graduate employment trajectory drop everything and revolt? My recent book Student Identity and Political Agency: Activism, Representation and Consumer Rights deals with these dilemmas and argues that the modes of student politics have had to change alongside the generational pressures that contemporary students face. In other words, the form that student politics takes is intertwined with what it means to be a student today.

Alternative forms of political agency

To counteract the view that students have become apolitical or snowflakes, we need to imagine student politics as more fluid and situational: something that gets embedded within the everyday practices of being a student.

First, this revisioning invites us to be more open-minded about what counts as student protest. For example, it is evident that when today’s students do protest, their actions tend to be more short-lived while triggered by identity-based issues that matter to them personally. We should also look at the new and alternative spaces that activism takes place within, eg digital platforms. The latter could of course relate to generational shifts and students being more digitally adept, but also to the fact that the university campuses have become heavily regulated by timetabling pressures and health and safety rules, making it difficult for students to socialise, let alone organise on campus.

Second, our universities have never emphasised student voice as much as they do today. In addition to students’ unions, there is a wide range of new representative roles on university committees and working groups. While there are questions about tokenism and the effectiveness of these roles – and perhaps fairly so – one cannot deny that there is an incredible infrastructure emerging for students to (peacefully) exercise their interest. This could also be politically motivated, and we should not underestimate the power that students as collectives hold through such representative roles.

Finally and perhaps most importantly, I invite us to consider the power that the student-as-consumer holds. In the age of marketised universities, we need to ask some uncomfortable questions related to the extent to which student-as-consumer positioning itself empowers students with new types of political agency. We know that an increasing number of students are exercising their right to complain, and they often do this to call out universities for their wrongdoings. These wrongdoings may relate to consumer rights and personal grievances, but often they also reflect wider structural inequalities. It could therefore be argued that consumer rights have granted students new tools to exercise their interest. There is a tendency for the sector to view student complaints as something negative and unreasonable, and none of us would want to be the subject of one. However, it is likely that if students are increasingly treated as consumers, it is also this consumer positioning that offers new opportunities for political agency to be exercised. In today’s highly pressurised university environments, consumer complaints might be a more effective way to make oneself heard: making complaints is a legal right for our students, and the potential reputational damage to universities makes complaints high stakes.

In summary, I argue that the market forces and consumerist discourses that brutally shape students are also what trigger, enable and disable certain new and altered forms of political agency. Such understanding invites us to shift away from the prevailing assumption that contemporary students are becoming apolitical and instead to rethink our normative understanding of what counts as political agency.

For more details, please see my book published as part of the SRHE and Routledge book series Research into Higher Education:

Raaper, R (2024). Student Identity and Political Agency. Activism, Representation and Consumer Rights Oxon: Routledge

Rille Raaper is Associate Professor at Durham University. Rille’s research interests lie in the sociology of higher education with a particular focus on student identity, experience and political agency in a variety of higher education settings. Her research is primarily concerned with how universities organise their work in competitive higher education markets, and the implications market forces have on current and future students. The two particular strands of Rille’s research relate to: a) student identity and experience in consumerist higher education; b) student agency, citizenship and political activism.


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Customer Services

by Phil Pilkington

“…problems arise when language goes on holiday. And here we may indeed fancy naming to be some remarkable act of mind, as it were a baptism of an object.”

Ludwig Wittgenstein, Philosophical Investigations, para 38 (original emphasis)

The paradigm shift of students to customers at the heart of higher education has changed strategies, psychological self-images, business models and much else. But are the claims for and against students as customers (SAC) and the related research as useful, insightful and angst ridden as we may at first think?  There are alarms about changing student behaviours and approaches to learning and the relationship towards academic staff but does the naming ‘customers’ reveal what were already underlying, long standing problems? Does the concentrated focus on SAC obscure rather than reveal?

One aspect of SAC is the observation that academic performance declines, and learning becomes more surface and instrumental (Bunce, 2017). Another is that SAC inclines students to be narcissist and aggressive, with HEI management pandering to the demands of both students and their feedback on the NSS, with other strategies to create iconic campus buildings, to maintain or improve league table position (Nixon, 2018).

This raises some methodological questions on (a) the research on academic performance and the degree of narcissism/aggression prior to SAC (ie around 1997 with the Dearing Report); (b) the scope and range of the research given the scale of student numbers, participation rates, the variety of student motivations, the nature of disciplines and their own learning strategies, and the hierarchy of institutions; and (c) the combination of (a) and (b) in the further question whether SAC changed the outlook of students to their education – or is it that we are paying more attention and making different interpretations?

Some argue that the mass system created in some way marketisation of HE and the SAC with all its attendant problems of changing the pedagogic relationship and cognitive approaches. Given Martin Trow’s definitions of elite, mass and universal systems of HE*, the UK achieved a mass system by the late 1980s to early 1990s with the rapid expansion of the polytechnics; universities were slower to expand student numbers. This expansion was before the introduction of the £1,000 top up fees of the Major government and the £3,000 introduced by David Blunkett (Secretary of State for Education in the new Blair government) immediately after the Dearing Report. It was after the 1997 election that the aspiration was for a universal HE system with a 50% participation rate.

If a mass system of HE came about (in a ‘fit of forgetfulness’ ) by 1991 when did marketisation begin? Marketisation may be a name we give to a practice or context which had existed previously but was tacit and culturally and historically deeper, hidden from view. The unnamed hierarchy of institutions of Oxbridge, Russell, polytechnics, HE colleges, FE colleges had powerful cultural and socio-political foundations and was a market of sorts (high to low value goods, access limited by social/cultural capital and price, etc). That hierarchy was not, however, necessarily top-down: the impact of social benefit of the ‘lower orders’ in that hierarchy would be significant in widening participation. The ‘higher order’ existed (and exists) in an ossified form. And as entry was restricted, the competition within the sector did not exist or did not present existential threats. Such is the longue durée when trying to analyse marketisation and the SAC.

The focus on marketisation should help us realise that over the long term the unit of resource was drastically reduced; state funding was slowly and then rapidly withdrawn to the point where the level of student enrolment was critical to long term strategy. That meant not maintaining but increasing student numbers when the potential pool of students would fluctuate – with  the present demographic trough ending in 2021 or 2022. Marketisation can thus be separated to some extent from the cognitive dissonance or other anxieties of the SAC. HEIs (with exceptions in the long-established hierarchy) were driven by the external forces of the funding regime to develop marketing strategies, branding and gaming feedback systems in response to the competition for students and the creation of interest groups – Alliance, Modern, et al. The enrolled students were not the customers in the marketisation but the product or outcome of successful management. The students change to customers as the focus is then on results, employment and further study rates. Such is the split personality of institutional management here.

Research on SAC in STEM courses has a noted inclination to surface learning and the instrumentalism of ‘getting a good grade in order to get a good job’, but this prompts further questions. I am not sure that this is an increased inclination to surface learning, nor whether surface and deep are uncritical norms we can readily employ. The HEAC definition of deep learning has an element of ‘employability’ in the application of knowledge across differing contexts and disciplines (Howie and Bagnall, 2012). A student in 2019 may face the imperative to get a ‘degree level’ job in order to pay back student loans. This is rational related to the student loans regime and widening participation, meaning this imperative is not universally applied given the differing socio-economic backgrounds of all students.

(Note that the current loan system is highly regressive as a form of ‘graduate tax’.)

And were STEM students more inclined toward deep or surface learning before they became SAC?  Teaching and assessment in STEM may have been poorand may have encouraged surface level learning (eg through weekly phase tests which were tardily assessed).

What is deep learning in civil engineering when faced with stress testing concrete girders or in solving quarternion equations in mathematics: is much of STEM actually knowing and processing algorithms? How is such learnable content in STEM equivalent in some cognitive way to the deep learning in modern languages, history, psychology et al? This is not to suggest a hierarchy of disciplines but differences, deep differences, between rules-based disciplines and the humanities.

Learning is complex and individualised, and responsive to, without entirely determining, the curriculum and the forms of its delivery. In the research on SAC the assumptions are that teaching and assessment delivery is both relatively unproblematic and designed to encourage deep, non-instrumental learning. Expectations of the curriculum delivery and assessment will vary amongst students depending on personal background of schooling and parents, the discipline and personal motivations and the expectations will often be unrealistic. Consider why they are unrealistic – more than the narcissism of being a customer. (There is a very wide range of varieties of customer: as a customer of Network Rail I am more a supplicant than a narcissist.)

The alarm over the changes (?) to the students’ view of their learning as SAC in STEM should be put in the context of the previously high drop-out rate of STEM students (relatively higher than non-STEM) which could reach 30% of a cohort. The causes of drop out were thoroughly examined by Mantz Yorke(Yorke and Longden, 2004), but as regards the SAC issue here, STEM drop outs were explained by tutors as lack of the right mathematical preparation. There is comparatively little research on the motivations for students entering STEM courses before they became SAC; such research is not over the long term or longitudinal. However, research on the typology of students with differing motivations for learning (the academic, the social, the questioning student etc) ranged across all courses, does exist (a 20 year survey by Liz Beatty, 2005). Is it possible that after widening participation to the point of a universal system, motivations towards the instrumental or utilitarian will become more prominent? And is there an implication that an elite HE system pre-SAC was less instrumentalist, less surface learning? The creation of PPE (first Oxford in 1921 then spreading across the sector) was an attempt to produce a mandarin class, where career ambition was designed into the academic disciplines. That is, ‘to get a good job’ applies here too but it will be expressed in different, indirect and elevated ways of public service.**

There are some anachronisms in the research on SAC. The acceptance of SAC by management, by producing student charters and providing students places on boards, committees and senior management meetings is not a direct result of students or management considering students as customers. Indeed, it predates SAC by many years and has its origins in the 1960s and 70s.

I am unlikely to get onto the board of Morrisons, but I could for the Co-op – a discussion point on partnerships, co-producers, membership of a community of learners. The struggle by students to get representation in management has taken fifty years from the Wilson government Blue Paper Student Protest (1970) to today. It may have been a concession, but student representation changed the nature of HEIs in the process, prior to SAC. Student Charters appear to be mostly a coherent, user-friendly reduction of lengthy academic and other regulations that no party can comprehend without extensive lawyerly study. A number of HEIs produced charters before the SAC era (late 1990s). And iconic university buildings have been significantly attractive in the architectural profession a long time before SAC – Birmingham’s aspiration to be an independent city state with its Venetian architecture recalling St Mark’s Square under the supervision of Joseph Chamberlain (1890s) or Jim Stirling’s post-modern Engineering faculty building at Leicester (1963) etc (Cannandine 2002).

Students have complex legal identities and are a complex and often fissiparous body. They are customers of catering, they are members of a guild or union, learners, activists and campaigners, clients, tenants, volunteers, sometimes disciplined as the accused, or the appellant, they adopt and create new identities psychologically, culturally and sexually. The language of students as customers creates a language game that excludes other concerns: the withdrawal of state funding, the creation of an academic precariat, the purpose of HE for learning and skills supply, an alienation from a community by the persuasive self-image as atomised customer, how deep learning is a creature of disciplines and the changing job market, that student-academic relations were problematic and now become formalised ‘complaints’. Students are not the ‘other’ and they are much more than customers.

Phil Pilkington is Chair of Middlesex University Students’ Union Board of Trustees, a former CEO of Coventry University Students’ Union, an Honorary Teaching Fellow of Coventry University and a contributor to WonkHE.

*Martin Trow defined an elite, mass and universal systems of HE by participation rates of 10-20%, 20-30% and 40-50% respectively.

** Trevor Pateman, The Poverty of PPE, Oxford, 1968; a pamphlet criticising the course by a graduate; it is acknowledged that the curriculum, ‘designed to run the Raj in 1936’, has changed little since that critique. This document is a fragment of another history of higher education worthy of recovery: of complaint and dissatisfaction with teaching and there were others who developed the ‘alternative prospectus’ movement in the 1970s and 80s.

References

Beatty L, Gibbs G, and Morgan A (2005) ‘Learning orientations and study contracts’, in Marton, F, Hounsell, D and Entwistle, N, (eds) (2005) The Experience of Learning: Implications for teaching and studying in higher education, 3rd (Internet) edition. Edinburgh: University of Edinburgh, Centre for Teaching, Learning and Assessment.

Bunce, Louise (2017) ‘The student-as-consumer approach in HE and its effects on academic performance’, Studies in Higher Education, 42(11): 1958-1978

Howie P and Bagnall R (2012) ‘A critique of the deep and surface learning model’, Teaching in Higher Education 18(4); they state the distinction of learning is “imprecise conceptualisation, ambiguous language, circularity and a lack of definition…”

Nixon, E, Scullion, R and Hearn, R (2018) ‘Her majesty the student: marketised higher education and the narcissistic (dis)satisfaction of the student consumer’, Studies in Higher Education  43(6): 927-943

Cannandine, David (2004), The ‘Chamberlain Tradition’, in In Churchill’s Shadow, Oxford: Oxford University Press; his biographical sketch of Joe Chamberlain shows his vision of Birmingham as an alternative power base to London.

Yorke M and Longden B (2004) Retention and student success in higher education, Maidenhead: SRHE/Open University Press

Paul Temple


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The student experience in England: changing for the better and the worse?

By Paul Temple

When the present English tuition fee regime was being planned, there were plenty of voices from inside universities warning that it would change the nature of the relationship between students and their universities for the worse. Students would, it was feared, become customers, rather than junior partners in an academic enterprise. Indeed, this was what the Government’s 2011 White Paper, Students at the Heart of the System, seemed to look forward to: “Better informed students will take their custom to the places offering good value for money” (para 2.24) – in other words, they would, it was hoped, act like normal consumers. Has this happened? Continue reading →