Student Visas - Home Affairs Committee Contents

Written evidence submitted by the University of Huddersfield (SV5)


1.  While it is recognised that robust control of the UK immigration system is a key aim of the coalition Government, there are concerns that the student route has been incorrectly identified as a major channel of immigration abuse. The restrictions that are being proposed could have a negative impact on the positioning of UK higher education in the international market and create significant damage for this important UK export sector.

2.  Universities and other Higher Education Institutions (HEIs) were invited to contribute to the last review of Tier 4, which was initiated in 2009 under the previous Government and was largely inconclusive. Many of the current proposals were posited by and responded to in the earlier review, and we would question why the new consultation is not taking these responses into account.

3.  Revenue from international student recruitment is needed to provide essential income diversification for public sector universities following significant reductions in public funding for teaching and research. It appears more than likely that the proposed changes will restrict planned growth and the essential development of alternative income streams, with a consequent risk to the viability of some departments or institutions.

4.  UK Universities are rigorously inspected and have many years of experience in dealing with international students in a trustworthy manner.

  • (i)  We operate our own sub-degree programmes, in the form of English language programmes and foundation years, for our own students progressing to our own degree courses. This gives us a good chance of articulating with the many different education systems across the world and gives us control over entry standards to our degrees. Removal of the right would be catastrophic for us.
  • (ii)  Working and dependents rights for international students are essential to us if we are to maintain parity with our major recruitment competitors in the United States and Australia. There is little evidence that work rights are abused by University students and students with dependents would have no problem funding the costs of medical care and schooling for their dependents.


The proposals which give greatest cause for concern are listed below.

  • Changes to work opportunities: Work rights and the Post-Study Work Programme are important marketing tools for HEIs and give us an even playing field with many of our closest competitors. UK education is promoted for its quality, and is appreciated as such worldwide, but it is also recognised that it can be expensive in relation to the US and Australia. It is particularly important in price-sensitive markets (the majority of the countries from which we recruit) that we can offset or challenge this view by conferring limited work rights. There is no evidence that PSW participants displace UK nationals in graduate employment.
  • If the provision of sub-degree programmes is restricted to HTS institutions this could undermine progression arrangements developed between HEIs and other education providers which are not HTS-rated. In most cases where these arrangements exist they are subject to stringent quality assurance procedures or the programmes involved are badged by professional education providers eg ACCA, NCC, ABE etc. However, we would strongly support an enhanced accreditation regime which integrates academic quality assessment with immigration compliance needs, approving only the largest and most professional providers.
  • The proposal to require international students to return home before progressing to a new course of study would be disruptive and a strong deterrent to individuals planning to continue their taught studies or undertaking postgraduate research in the UK.
  • The proposal to restrict permission to bring dependants into the UK causes concern over the disadvantages this would create for many students for both cultural and family reasons. The majority of students with dependants at the University of Huddersfield are from countries with which the UK is working to achieve political détente or co-operation and a move to restrict family transfers to the UK, in addition to affecting individuals and families adversely, may jeopardise high-level channels of co-operation.
  • The proposed requirement for all non-EU students coming to the UK to have undertaken an approved secure English language test will jeopardise progression arrangements between many UK HEIs and overseas partners, which normally incorporate independent language testing activities. In addition, many countries are English speaking and students are brought up speaking English and taught in English. This proposal effectively removes the academic freedom and autonomy of universities to determine and operate independent entry requirements. Students coming to study English language in a University, prior to an academic course, should not need a secure test as we can assess them ourselves and subsequently ensure that they reach the correct level to begin academic study.


1.  Several proposals in the consultation are welcome. These include the plan to reinforce accreditation procedures for private providers. The proposal to offer a fast track service to "low risk" applicants is cautiously welcomed; however, we do have reservations about the application of differential risk profiles and the possible introduction of subjectivity into what was always intended to be an objective system.

2.  The proposals as a whole fail to acknowledge the economic importance of education exports from the UK as well as ignoring the international dimension in which universities and other educational organisations must work to maintain competitiveness in both teaching and research. At present, the higher education sector is facing an uncertain future and the expansion of international activities constitutes one of the few areas available for further development; if migration policy changes radically this will seriously undermine this potential channel for growth.

3.  We believe that within an international context, the UK will lose the competitive advantage it has gained over the last few years owing in part to a liberalised student immigration regime and the overhaul of the visa application system. Of the UK's major competitors in the international education market, Australia felt the effects of a student immigration review that led some of its universities to predict a fall of up to 25% in its education export sector,[1] and a 1.4% decline in enrolments in the current year has now prompted another review of student visas.[2] The USA has a similar system to that of the UK, although it could be argued that the UK Tier 4 visa process is slightly more accessible and straightforward.


1.  Appropriate transitional arrangements must be put in place for any changes made to the immigration system.

2.  We would like to see HTS reserved for Universities only, or a special HTS* category created, so that it becomes easier to distinguish the rights that public funded and QAA inspected institutions can hold.

3.  Post-Study Work to remain but to be limited to graduates of HTS institutions.

4.  Dependants' rights to remain unchanged with HTS, but charges made for medical care and schooling.

5.  No requirement for University applicants to English Language Programmes to undertake a Secure English Language Test.

6.  The higher education sector should be closely consulted on issues such as differential risk assessment and to advise on the academic aspects of accreditation of private providers.

7.  It is suggested that a more rigorous sponsor accreditation procedure is accompanied by greater benefits for HTS institutions and their students.

January 2011

1   The Australian, 6 November 2010. Back

2   The Age, 17 December 2010. Back

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Prepared 25 March 2011