The message to the sector? Tread carefully. Review your markets. Know your data. Consider your methods of assessing credibility. Because one or two refusals could now put your whole international pipeline at risk — and once it’s gone, you might not get it back for years.

And then there’s the cut to the Graduate Route — 18 months instead of 2 years. A pointless and regressive move that takes one of the few well-designed migration routes and makes it worse. Why mess with it?

The new levy on sponsorship income lands at the worst possible time. This isn’t about funding enforcement — it’s a tax on a sector already under pressure. Students will end up footing the bill, when really we should be tackling overpayment to agents and inefficiencies.

As an aside – the assumptions related to reduction in migration are blunt, focussing on the institutions losing the ability to sponsor students, not considering the changes in behaviour these changes would create.

Home Office modelling shows 22 HEIs would fail under these proposed changes. The modelling shows that they anticipate that 5 institutions would be unable to resolve these and would be barred from sponsoring new students as above.

It gets worse: it’s not clear if institutions who are removed from the register will retain their track record of compliance when returned. If not, they’d need to rebuild it, meaning three years+ before getting the benefits of ‘track record’ status. This will restrict your recruitment significantly.

The image below, from the Home Office’s technical paper, spells it out: fail the new BCA, and you're off the Register of Student Sponsors for up to two years. This would have a massive impact on university finances and reputations and would set your institution back years.

Sponsors will also need to consider how they conduct their credibility/pre-CAS interviewing; to outsource or not to outsource, whether the use of AI is sensible, and whether to have tiers of interviewing based on student nationality.

A handful of visa refusals could now shut down your entire international programme for 1 - 2 years – any sensible sponsor will be avoiding exposure in perceived high-risk markets.

This isn’t about poor compliance. This is about institutional risk appetite. It forces HEIs to think further about which students they take the risk of sponsoring, and sadly some genuine students will not be able to gain sponsorship based on where they are from, not whether they are credible.

The biggest shift? A 5% tightening of each of the BCA metrics. The refusal rate in particular is going to cause serious problems, especially for smaller institutions or those recruiting from high-risk markets, and beware of being over-reliant on markets as any fluctuation can push you over the edge.

I am often critical of our sector, and think if enforced as written, some sponsors will be punished harshly, and often through misfortune rather than design.

Basing immigration policy on peaks and troughs in net migration data leads to knee-jerk decisions (like this) - the conversation needs to be based on whether those students who arrive in the UK on a student route visa eventually settle here.

For comedic value - William Shatner’s version of Little Drummer Boy is incredible.