Our response recognises the importance of ensuring robust oversight and high-quality delivery of franchised provision. However, there are concerns that several elements of the proposed new Condition E8 and associated measures could introduce significant additional regulatory burden and duplication of existing processes.
Many of the proposed requirements, such as governance documentation, contingency planning and reporting, are already addressed through mechanisms including Student Protection Plans and the integrated quality framework. Creating parallel systems risks imposing unnecessary operational and financial costs on providers.
The response also highlights the need for clearer definitions, greater transparency around regulatory powers and thresholds, and more realistic implementation timelines. It emphasises that franchised provision plays an an important role in widening participation and that regulation should remain proportionate and evidence-based to avoid reducing opportunities for students.
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