Student Visas - Home Affairs Committee Contents

Written evidence submitted by the University of Oxford (SV21)


Our response to the UK Border Agency proposals is outlined in the sections below. A summary of our main concerns is as follows:

1.  Closing the Post-study work route will deny us the talents of young researchers whom we have trained as students. It could seriously undermine our international competitiveness as post-study work experience is often a determining factor for applicants when choosing a country where they wish to study.

1.1  The proposal to only permit on-campus employment during the week is impractical to administer and negatively affects community integration.

1.2  Removing the right to work for all dependants and not allowing them to accompany students if the course is less than 12 months makes financial and pastoral support for couples and families very problematic. These students may go instead to our competitors abroad who offer more child/family-friendly visa policies.

1.3  The introduction of the new points based system has made the visa application process more complex and confusing for students. In the summer of 2010 nearly 100 students coming to Oxford were refused visas, mostly on minor technicalities, and had to reapply. Further proposals that make the process even more complex could deter applicants from applying to Oxford and UK HEIs in general eg additional English language tests, tighter requirements for academic progress, and not allowing students to extend a visa within the UK.

1.4  Seeking assurance that students will still be able to gain a visa for A-Level or Foundation courses is important as they act as a crucial feeder route for our intake of undergraduate students.


2.  The University of Oxford is a world-class university with a strong international reputation. A key element for our success lies in attracting the best students from schools and universities worldwide. A third of our students and staff come from outside the UK. The University has nearly 5,000 non-EU students (ie those who may require a student visa) on course at any one time, which represents 24% of our total student population, and our students come from over 120 countries (including EU and non-EU countries). When we focus on the graduate student population within these figures, the non-EU percentage of the population is much higher at 41%. Nearly 60% of our graduate applications each year are from outside the EU.

2.1  Our international student and staff profile generate an exceptional diversity in our academic and cultural life. We are concerned that the proposals outlined may deter students from choosing Oxford or the UK as a study destination. There is a potential impact on our research activity if we are not able to attract the best students to work and study in highly specialised areas of research for which we cannot often recruit suitably qualified UK/EU candidates. These students will go to the US instead. With the introduction of higher fees for UK/EU undergraduate students in the near future following Lord Browne's report, we may see a shortfall in applications and it will therefore be increasingly important that we can recruit competitively internationally, to garner the most talented undergraduate students suited to our highly academic courses.

2.2   The forecast income for Oxford University for 2010-11 for non-EU students' fees is £72.5 million compared to the income from Home and EU students' fees of £54 million which is then supplemented with £68.8 million from HEFCE income. Whilst we do not seek to recruit overseas students to profit from the higher tuition fees it does demonstrate what a large undertaking of teaching the University provides. The fee income and corresponding daily expenditure by overseas students represents a significant injection of capital into the local economy from the overseas student body.

2.3     The University of Oxford is classed as a Highly Trusted Sponsor of students by the UKBA. The University should be classified as a very low risk institution because of our stringent admission procedures, very high English language requirements, a very low drop-out rate, and our systematic and accurate student data management system which readily identifies any absence or academic progress issues. However, when applying for a visa our students face the same bureaucratic obstacles and delays that students going to higher risk institutions also encounter.

2.4  The points-based system, while welcomed for its greater transparency and less subjectivity, has introduced more complexities into the visa application process for our students and generated considerable confusion and frustration. The requirements for documents have become much more specific and must be presented in the exact correct format. Over the summer of 2010 we had a large number of visa refusals, often on minor technicalities, which caused some students to arrive late or to even consider withdrawing from their course at Oxford.


Our response to the proposals is divided into five sections as outlined in the UK Border Agency consultation document.

Raising the level of courses students can study

3.  Oxford only offers a few below-degree level courses so the proposal to restrict courses to degree level, or below degree level for Highly Trusted Sponsors would not be a detrimental change for Oxford. We are concerned that many of our international undergraduate students come to us via A-Level Colleges or Foundation courses in the UK. However, most reputable A-Level colleges and institutions offering foundation courses are already Highly Trusted Sponsors so the direct impact may be small, providing those institutions retain that status.

3.1  Data from our 2010 intake of non-EEA undergraduate students shows that many of them apply from within the UK to commence at Oxford. We received 2,905 applications of which 666 were already studying in the UK, i.e. 23% compared to a sector wide average of 33%. From these applications we made 388 offers and 102 of these students were already studying in the UK, i.e. 26%. This shows a high level of co-dependency with the FE sector. Any measures or policy statements that send a negative signal to potential applicants about the possibility to gain a visa for A-Level, Foundation courses or other below degree level courses could lead these students to avoid studying in the UK, and in turn, they may not apply to UK HEIs.

Introducing tougher entry criteria for students

4.  At the moment universities are free to make their own assessment of a candidate's English language competency and it is not part of the visa application process. Our English language requirements are set very high at IELTS 7.0 for undergraduate study and IELTS 7.0 or 7.5 for postgraduate study compared to the proposed UKBA minimum B2 level which is equivalent to IELTS 5.5. Students are required to submit a test result by an approved examining body which already meets the UKBA list of approved examiners. The proposal to require English language test results as part of the visa process would therefore put an additional burden on our students and duplicate an academic condition which had already been ascertained by the university. This takes away the trust in universities to make their own capable academic decisions as Highly Trusted Sponsors.

Ensuring students return overseas after their course

5.  The first proposal in this section states that students wishing to remain in the UK after their first course to start a new course would have to show evidence of academic progression to a higher level. This does not allow flexibility for students to take a second Master's if they had a change of career direction, or if they were seeking to pursue a doctoral degree at a later date and we were to recommend a second Master's as a basis/revision for the later doctoral study.

5.1  The second proposal to require such students to return to their home country and apply for a new visa would not only be a major bureaucratic inconvenience to the majority of students, but a considerable expense which they may not have the   funds to meet. A large proportion of our student intake each year, an estimated 30%, are already in the UK taking another course of study and apply for a visa extension within the UK to start at Oxford. Returning home could be very problematic given the long processing times for visa applications in some countries, and the potential cost could be a factor in students deciding not to study at Oxford. Many students would find the timescale very difficult as with final papers and graduation ceremonies due over the summer or even until September, they may not have adequate time to return home and obtain a new visa.

5.2  Gaining Entry Clearance overseas offers no right of appeal if the application is rejected; this is in contrast to extending within the UK which does offer a right of appeal, so students are further disadvantaged by being required to return home. If the intention is to capture a small minority of students who might be seeking permanent settlement through long-term residency in the UK, or those not wishing to return home for other reasons, it seems disproportionate to penalise genuine students progressing through the UK education system. If this policy is implemented an exemption should be given to Highly Trusted Sponsors to allow students to extend within the UK.

5.3  The third proposal to close Post-study work is of very serious concern to us as with the closure of Tier 1 and a cap on Tier 2 there would be very limited opportunities for talented students to gain work experience in the UK. We are particularly concerned about opportunities for exceptionally talented students to stay on for highly specialised post-doctoral positions, for which most job-seekers in the UK would not be qualified to apply. If we cannot employ the graduate students we have so highly trained, we will deprive ourselves of a real asset to the research effort which sustains our leading international competitiveness.

5.4   Our internal findings through student surveys such as the Student Barometer[67] and research by our Careers Service show us that opportunities for work experience during and after study are seen as essential by prospective and current students. The UK currently performs badly in this area compared to our competitors overseas. Further restricting these possibilities to work will make it more difficult to attract the best students from overseas to study here.

5.5   We would strongly suggest that instead the Post-study work route should be refined. Possible options could include allowing students from a Highly Trusted Sponsor University to work for a Highly Trusted Sponsor Employer, a shorter length ie one year only, restricting it to specified subject areas, restriction by course level, or requiring a job offer at a certain salary level before Post-Study work is granted. We would suggest that such refinements should be the subject of future consultation with the sector.

Limiting the entitlements of students to work and sponsor dependants

6.  The first proposal in this section to only allow work on campus during the week and off campus at the weekend or vacation periods would be very impractical to administer, or to explain to students and employers. It also isolates students from the local community and undermines integration efforts, especially as many UK Universities are not campus based and are located within cities or towns. As a collegiate university we would need an exact definition of what constituted work on campus. This proposal could exclude students from valuable opportunities to work part-time in our large number of independent spin-off or partner companies and institutions conducting ground breaking research in scientific areas. We do not understand the exact rationale behind this proposal and fear that it may also push home students out of on-campus employment opportunities.

6.1  The second proposal to remove permission for all dependants to work is again of serious concern for us, as for longer courses this could be a very negative factor that deters students from applying to Oxford. Undergraduate and graduate research students would find it very hard to support dependants if they were self-funded. Those coming from poorer countries would face a particularly great burden. Scholarships are usually only funded for the cost of one person so this could deter well qualified applicants from taking up prestigious awards such as our Rhodes and Clarendon scholarships. It also raises a pastoral care issue for universities and the student visa holder in finding an activity for the dependant to be engaged in for several years, if no work is permitted.

6.2  The third proposal to restrict students on courses of less than 12 months from bringing dependants would be seen as a very negative factor in students deciding whether or not to study in the UK. This would rule out our nine-month Master's and 12 month Master's course students (short of 12 months by a few weeks) from bringing their dependants. We also have a large number of students who come from the US as visiting students each year for a period of less than one year. We would strongly suggest that the current position, which is that dependants may only accompany students if the course is longer than six months, be maintained. Again, the risk is that these students will choose to study in the US instead.

Simpler procedures for checking low-risk applications

7.  As a Highly Trusted Sponsor and an institution with robust admission requirements and stringent attendance and progress monitoring we would welcome this if it made the visa process easier for our students. However, we understand this could also be based on nationality which may make the visa process more complicated and confusing for students. Determining how low risk countries are to be identified and how it may vary over time seems controversial and it also removes the subjectivity that was a defining part of the new points based system. It could also be seen to be penalising exceptionally talented students from high-risk countries.

7.1  The second and third proposals in this section about stricter accreditation procedures do not apply to us directly as we already meet all the necessary requirements.

Recommendations for the Committee in its report

8  Recommend that alternative options be considered to closing the Post-study work route (as outlined above) and that exemptions should be offered for the current cohort of students if any changes are to be implemented in the near future.

8.1  Propose that students should still be allowed to bring dependants if the course is longer than six months, and that alternative options are considered to the proposal of restricting all dependants from working. Both of these proposals could seriously affect our ability to recruit the best students and postgraduate research students would be especially discouraged from coming to the UK.

8.2  Advocate dropping the proposal that students be restricted to campus employment during certain periods because of the complexity of trying to introduce such a requirement and the negative effect on community integration.

8.3  Recommend that (all) students, or at least those moving to a Highly Trusted Sponsor, be allowed to extend their visa within country when starting a new course.

8.4  Emphasise that the academic judgment of Highly Trusted Sponsors should be relied upon to assess a candidate's progress and English language ability. Further visa requirements will only contribute to a more bureaucratic and complex procedure and deter potential applicants.

January 2011

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