1. Reduction in permitted refusal rate
From June 2026, the Home Office will apply new compliance thresholds to Independent Schools requiring:
- A visa refusal rate of less than 5%
- At least 95% of students enrolling on the course
- At least 85% of students successfully completing their course (rising to 90% from June 2027)
Where a school sponsors a small number of students there is scope for discretion if one of these criteria is not met, but it is clear that even a small number of refusals can present compliance issues, including where the refusal is for a reason unrelated to the school.
For example, we have seen applications refused because of unclear financial documents provided by a student's parents, proposed care arrangements which do not align with the Immigration Rules and missing medical evidence. It is increasingly important that schools take steps to make sure the requirements of the Rules will be met by a pupil before issuing a Confirmation of Acceptance for Studies (CAS).
2. Greater scrutiny of agents
The Home Office is placing greater scrutiny of agents used to recruit international students, and schools must disclose any agents used when issuing a CAS.
Schools should take steps to review the agents they currently use and make sure they are carrying out checks to ensure any students recruited this way are genuine students who are likely to complete their course.
3. Emphasis on safeguarding rules
The Home Office will take any breaches of the safeguarding rules seriously and it will usually result in the loss of a sponsor licence. This includes situations where pupils are staying in private foster arrangements which have not been reported to the local authority, or situations where there is no UK guardian on file for the pupil.
Schools should review their policies and check they are compliant with the Home Office rules as a matter of urgency.
4. Increased focus on non-sponsored students
A common issue we have encountered is a situation where a non-sponsored student has been permitted to study without holding a valid visa, this is particularly the case where the student is a visitor to the UK and restrictions apply to their right to study.
Independent Schools with sponsor licences should check a potential student has a relevant visa to allow them to study in the UK before enrolment and retain evidence of this. They should also record and monitor visa expiry dates so follow-up checks can be carried out. As a licensed sponsor, an Independent School is expected to play a role in tackling illegal immigration and we are increasingly seeing the Home Office ask for evidence of this during compliance visits.
We regularly assist Independent Schools with compliance audits and training to help prepare them for Home Office visits. If you would like to discuss this, or other support packages we offer, please get in touch.
