Student Visas - Home Affairs Committee Contents

Written evidence submitted by Navitas (UK) (SV36)

1.  Executive Summary

1.1  Navitas understands the Government's parallel objectives of eradicating abuse of the migration system, including any element of abuse via the student visa route, whilst ensuring that the UK's education system continues to attract the brightest and the best students from across the globe. It is very much in the interests of the sustainability of not only the UK's education exports services industry but also Navitas' UK College network that the UK remains a top priority destination for legitimate non-EU students; however it is imperative that policy be based on empirically sound data derived from comprehensive consultation and analysis as opposed to driving policy from less than robust data sources.

1.2   The education export services industry in the UK is complex and dynamic comprised of public and private providers. Regulation is welcomed by all bona fide providers; however any regulatory regime must be equitable across both the public and private sectors in order that Government applies the same standards of transparency and accountability across all providers regardless of their funding base.

1.3  Ireland, New Zealand and the USA have recently come out strongly in support of the economic and cultural importance of the education exports services industry. The Australian Government for example has recently recognised the negative impact on GDP of recent visa tightening measures.[45]

1.4  International students contribute to their local economies, providing a very significant income stream for the UK economy. The 2009 Universities UK report on the impact of universities on the UK economy indicated that in 2007-08 off-campus expenditure by international students was c £2.3 billion.

1.5  The UK is sending mixed messages to the world. Government words are signalling that the UK is keen to enhance its global engagement and welcomes international students as part of that engagement; however, Government action through the current proposals is signalling to the world that the UK does not want international students.

1.6  International student mobility is a very successful activity for the UK and contributes to the success of HE sector, the UK economy and international positioning. It should be considered as an export success and not as an immigration problem.

1.7  Government is focusing on net migration when setting targets; it should be focusing on settlement and, making it more difficult to transfer from temporary (ie students) to permanent migrant routes.

1.8  International students are "educational tourists" not immigrants; they may indeed be in the UK for longer than 12 months but this is because of the nature of their education programmes; they are not in the UK for economic reasons; their time in the UK on a student visa does not earn points towards applications for settlement and they have no recourse to public funds. Further, if students wish to progress onto further study or take up employment, they must apply to the Home Office for another visa; this is an inbuilt and existing control mechanism.

1.9  The potential to inflict profound, long-term damage on the HE and English language sectors for no discernible gain looms large if the proposals currently on the table are taken forward. The UK will not recover from this damage as trust and market-share once lost are impossible to regain.

1.10  "Whole-of-course" visas will enhance the UK's competitiveness as well as retention, progression and completion rates. Forcing students to apply overseas for a new visa between components of study pathway/programmes will have a negative impact on retention rates and student progression as well as create practical difficulties in terms of costs and accommodation.

1.11  International students/graduates play a key role as diplomatic/trade/cultural assets for the UK—"soft power" as it is known.

1.12  The Government endorsed and encouraged private/public interface between education providers in the UK could be undermined by these proposals thus in turn undermining the Government's need for private enterprise to take a more dominant role in the provision of employment opportunities and education costs as part of the rebalancing of the UK economy.

1.13  The sector should work with the Government to develop equitable and transparent accreditation and licensing procedures for providers and this will enhance credibility and establish acceptable standardised benchmarks for quality provision within the HE sector.


2.1  Navitas Limited is a diversified global education provider that offers an extensive range of educational services for students and professionals including university programmes, language training, work-force education and student recruitment. Navitas Limited is a public listed company on the Australian Securities Exchange (ASX) and is known as a world leader in the development and provision of educational services and learning solutions. Navitas Limited had a market capitalisation of approximately AUD$ 1.4 billion as at June 2010. Navitas consists of four operating divisions: University Programmes (the largest Division with operations in Australia, the UK, the USA, Canada, Singapore, Sri Lanka, Kenya, and Indonesia); English; Work-force; and Recruitment, all of which report to the corporate headquarters located in Perth, Western Australia.

2.2  Navitas University Programmes Division UK's Colleges are located on university campuses in Aberdeen (Robert Gordon University opening in October 2011), Cambridge (Anglia Ruskin University), Edinburgh (Edinburgh Napier University opening in June 2011), Hertfordshire (University of Hertfordshire), Plymouth (University of Plymouth), Portsmouth (University of Portsmouth), Swansea (Swansea University) and West London (Brunel University), locations which enable students to experience the UK city, climate, culture and lifestyle of their choice. Navitas' partner universities are internationally renowned for their teaching and research.

2.3  Navitas understands that students coming from all over the world have different English language, academic and career levels and aspirations, so Navitas Colleges in collaboration with their respective Host Universities provide a range of degree pathways inclusive of flexible programme intake start dates to suit students' pedagogical and personal needs. By studying with Navitas, students join supportive, educationally focused communities that help them to integrate into the UK culture, develop personally, maintain balanced lifestyles and achieve their academic and career potential before returning home armed with strong emotional, linguistic and economic ties to the UK.


3.1  The Navitas Colleges in the UK, under their legally enforceable Recognition and Articulation Agreements, provide significant third stream revenue to their respective Host Universities via the direct royalty paid per head each semester (three semesters in one calendar year) as well as "pipeline" income as students move through the articulation process and pay the full University fees directly to the Host University for the remainder (usually a minimum of two academic years) of their degree programme. In the period from September 2000 to December 2010 Navitas UK:

  • has paid direct royalties to six Host Universities totalling GBP £13,241,295.00;
  • facilitated access to university education for c 16,400 students who would otherwise have been denied access to a UK University degree and a UK cultural experience; and
  • facilitated Host Universities' access to c GBP £220 million in pipeline income ie that income derived from students progressing through the articulation agreement from a Navitas College to their respective Host University in order to complete their degree studies.

Indeed in the current financial year (2010-11) alone our Host Universities will receive over GBP£6 million in royalties and c GBP £27 million in pipeline revenue.

3.2  Any reduction in international students as a result of visa constraints would have a severe financial impact on a HE sector already under threat from funding cuts.[46]

3.3  Non-EU students from degree-preparation courses are a significantly critical source of students for UK universities. Universities UK (UUK) has estimated that 46% of all non-EU students admitted to UK universities come via preparatory programmes inclusive of those entering via formal, on-campus articulation and recognition agreements. 37% of Navitas UK's annual revenue is derived from its degree preparation route, a loss of this revenue would jeopardise some 300 positions across the UK and would impact significantly on both the direct royalty payments and pipeline income for our Host Universities.

3.4  The regulatory regime should also be consistent and equitable across both public and private providers; prohibiting institutions from offering NQF Level 3 may well raise legal issues such as restraint of trade.

3.5  Non-EU students make a significant contribution to UK universities to the tune of between 10-30% of total income,[47] the substantial contribution via full fees i.e. cost recovery, ensures the enviable breadth of courses available in the UK is protected.

3.6  Non-EU (International Students) have been incorrectly categorised as an immigration risk, when in fact they are "Education Tourists" who make an extremely important economic contribution to the UK. These students main domicile is outside of the UK and they return home on a regular basis for holiday periods, so Government's intention to restrict an invaluable export earning industry in this way does not match the need to rebuild the economy and engage private industry to a greater extent. The Government's own data illustrates that of the 186,500 students granted visas in 2004, only 5,568 later gained settlement rights—ie only 3%.[48] Overall international students have a minimal effect on net migration as there are approximately the same numbers of students leaving the UK each year as there are entering it. It is also arguable that the UK should be welcoming of UK-educated, highly skilled workers who will make an above-average contribution to the UK's economic future and also make excellent ambassadors for this country. The Government should be targeting reductions in settlement rather than using the student cum Education Tourist route to reduce net migration, given that the Government's own data illustrates that this is the group contributing the least to the net migration problem.

3.7  A 2007 British Council Report stated that in 2003-04, the Education and Training export sector was worth £27.7 billion.[49] In 2010, the sector estimates this to be closer to £40 billion and thus the UK's second biggest contributor to our net balance of payments, after financial services.

3.8  International students' contribution in tuition fees and living costs to the UK economy each year qualifies them as "wealth generators" for the UK economy. In addition to the full cost recovery course fees paid to a Navitas College for example, our students (all of whom are non-EU), and staff (we focus on employing from the local community) bring significant income to the local as well as the national economy through their spend on accommodation, food, transport (rail, bus, taxis, air and the purchase of motor vehicles), communication, clothing, leisure and social activities. This translates to a conservative estimate of economic impact for the 2009-10 student cohort's academic year of c GBP £27 million from students in the Navitas UK College network. Given the diversity of locations of our Colleges this is an important regional economic impact. Students are also visited regularly by family and friends further adding to the economic value add element.

3.9  There will be major job losses in the public and private sector as a result of a cap on international students. These job losses may well be concentrated in areas where there are large numbers of private and public educational establishments which are the key employers in those regions.

3.10  The negative material impact on GDP of unnecessarily tightened visa restrictions for non-EU students at a time when the UK needs thriving export industries and harbours an expectation that the private sector will pick up the shortfall in government spending, will be considerable. The Australian government for instance has just acknowledged the negative material impact on GDP that its recent tightening of visa restrictions for international students has had. Job losses in the sector are expected to be in the thousands, including university staff.[50]

3.11  The global education sector is the largest industry sector in the world after healthcare, and an industry in which the UK has a pre-eminent advantage with "our" language and the gold standard quality of our education system.

3.12  International students can legitimately stay in the UK to study for up to eight years, as many enter the UK to study GCSEs followed by A-levels, in order to win places at UK universities and therefore it needs to be noted that students who are still in the UK after five years are more likely to be engaged in longer term study pathways than staying illegally.

3.13  The reason many international students have to undertake preparation programmes prior to entry to a UK university is because many countries have a 12-year secondary system (in contrast to the UK's 13 years), and often both English language and study skills need to be improved. Pedagogically this is sound practice as our academic outcomes and success of our students when they transfer to the host university attest.

3.14  Unlike EU students, who study at UK universities under subsidy from the taxpayer, non-EU students provide valuable full fee income, which subsidises domestic students' places, builds numbers in declining programmes of study and helps to sustain the quality of research and teaching in our world-class university sector.

3.15  International students not only enrich the learning environment for domestic students and provide substantial economic support to universities, but also act as valuable ambassadors for future commercial, diplomatic and cultural ties that benefit the UK. We note here the Prime Minister's recent trips to India and China in which he emphasised, " much we [the UK] want to welcome international students to Britain". Proposed changes to the student visa regime do not support this statement.

3.16  In addition to the in-country economic value add of non-EU students to the UK, the UK also benefits from the global networks and links the education services export industry has established, particularly in key source countries such as India and China, which are also foreign policy priorities. Given the particularly high levels of satisfaction experienced in the UK by non-EU students during their study programme, it is sensible that the UK should capitalise on this potential for life-long advocacy for the UK.

3.17  English language competency does not equate to academic ability or capacity. The course accreditation process should determine what English language level is required to ensure success in an academic programme. Further, restricting the evidence base to a limited number of tests of English language will have significant implications for all institutions as this will dictate what English language tests can be used by institutions to assess students. It appears to entirely exclude the assessment and expertise offered not only by universities but also by the many bona-fide English language centres in the UK. Proposals related to English language may be viewed as intruding into institutional autonomy through setting particular requirements that have to be met before students can be admitted and so interfering in admissions decisions related to academic capability. It also appears at odds with the approach taken in the United States, where institutions are able to specify their own language requirements. The focus should be on encouraging non-English language speakers to learn the language in the UK in appropriately monitored and regulated English Language Centres thus ensuring the integrity of the language as well as earning important export income for the UK.

3.18  Recent increases (2008-09) in student visa applications are not a reliable and objective indicator of a concomitant increase in abuse. The declining value of the pound against many other currencies alone has made the UK a much more affordable study destination.

3.19  Non-EU students pay the full cost of their education in the UK; have to prove that they can cover the cost of their maintenance whilst in the UK; have very limited work rights and cannot fill a permanent vacancy; have no recourse to public funds and cannot claim any benefits related to housing or living costs; have no right to stay beyond the period set in their visa conditions. Given this, it is difficult to determine what benefits a reduction in their numbers will have for the UK.


It is suggested that the following recommendations be considered:

4.1  Require non-EU students to obtain private health insurance or purchase National Health credits as part of their visa acquisition process thus reducing the potential for abuse of the student route to obtain medical services via the NHS.[51]

4.2  Impose a reasonable and agreed (with the export services industry) per-head (of non-EU students) levy on each institution to provide the UKBA with additional funding to resource comprehensive compliance measures.

4.3  Implement a risk-based approach on a country-by-country basis to enable streamlined visa processing procedures for lower risk countries.

4.4  Charge one higher education (possibly a new one) accrediting body with the responsibility for:

  • accrediting private sector providers under new and enhanced accreditation requirements inclusive of a Quality Assurance Agency (QAA) audit; and
  • reducing the number of least compliant institutions and removal of same from the Register of Sponsors.

4.5  Require students to pay all fees in advance for courses of up to six months duration and at least two-thirds of the first year fee for courses longer than six months duration.

4.6  Implement a tuition assurance scheme/insurance scheme to protect pre-paid fees in the event of a closure (either forced or voluntary).

4.7  Redefine students as "education tourists" and therefore "temporary" visitors as opposed to "immigrants".

4.8  Move the focus of regulation and statistical analysis related to students from net migration to settlement.

4.9  Implement a "whole-of-course" visa approach for those institutions in legally enforceable, collaborative partnerships designed around the provision of an education continuum. It would effectively lock students into an agreed study pathway. It is a system that would facilitate better tracking of students; enhance progression and completion rates and prevent unnecessary movement of students. In addition, such an approach would encapsulate processes for inter-institutional transfer for those students who need to/must transfer because of the nature of their programme of study e.g. A Levels moving to HEI/FE; Foundation to HEI/FE; or English language moving to academic/vocational studies. It would also reduce the costs and inconvenience that students experience when moving from one institution to another, thus keeping the UK competitive and makes providers more accountable.

4.10  Make transfer from temporary e.g. the student route, to permanent migration routes much more difficult.

4.11  Classify all post-study work as "not leading to settlement" but maintain the current post-study work entitlements in order to ensure international competitiveness.

4.12  Restrict work rights for shorter courses ie those courses = 12 months in duration.

4.13  Remove the right to bring dependents if enrolling on shorter courses ie those courses = 12 months in duration.

4.14  Remove work rights for dependents of students on courses = 12 months in duration.

4.15  Continue to allow those visitors to the UK on business or tourist visas to undertake a short course of study/professional training at accredited and registered institutions.

4.16  Remain with the B1 level requirement for English language courses and allow institutions to determine the most appropriate method of determining English language levels and entry points to English language programmes.

4.17  Allow private institutions offering bona fide NQF Level 3 degree preparation programmes via legally enforceable articulation and recognition agreements with a nominated Host University to continue offering these validated programmes of study.

4.18  Agree with the sector, discrete definitions for sub-degree and pre-degree preparation programmes.

4.19  Adopt an agreed and generally accepted definition of "pre-sessional courses".

4.20  Complete the current review and then leave the visa system unchanged for at least one year after which changes should only be introduced on one of two set dates each year eg 1 January and 1 July.

4.21  Establish appropriate consultancy mechanisms whereby all registered and accredited providers can provide feedback and input to future decision making processes related to this vitally important education services export industry.

4.22  Undertake a comprehensive but separate review of HTS in order to determine its real value-add particularly as it was introduced in great haste and without consultation.

January 2011

45   See; New Zealand: New Zealand to make student immigration easier-Work; US: U.S. Voters Support International Education, Poll Finds-The Chronicle. Back

46 Back

47   International Students in the UK: facts, figure- and fiction: September 2010 UKCISA. Back

48   The Migrant Journey, Home Office, September 2010. Back

49   Global value: The value of UK education and training exports: an update, British Council, Pamela Lenton, Dr of Economics, University of Sheffield, September 2007. Back

50 Back

51   See the Australian Government's requirement of Overseas Student Health Cover (OSHC) at Back

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Prepared 25 March 2011