Whitehall Discovers The Cash Machine
Chapter 7
Sources supporting this chapter, with the manuscript section they relate to and a note explaining how each item contributes.
Showing all 22 references
Evidence used
Material used to support factual claims and explanations in this chapter.
Source
UK Parliament, 2017
Supports the chapter's framing of the post-HERA settlement, including the creation of the Office for Students, the register of English higher education providers, registration conditions and the statutory basis for student protection plans.
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Office for Students, published 3 February 2022
Used for the account of initial, general ongoing and specific ongoing conditions, and for the point that registration is the permission structure through which providers enter and stay within the regulated system.
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Office for Students, last updated 24 November 2022
Used for the description of student outcomes as a condition of registration, including continuation, completion, progression, numerical thresholds, split indicators, contextual evidence and potential regulatory consequences.
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Office for Students, published 15 December 2020
Used for the chapter's explanation of risk-based regulation, including the OfS's focus on providers at greatest risk of breaching conditions of registration, assessment of likelihood and impact, and monitoring as new information is received.
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Universities UK, 5 September 2023
Used for UUK's definition of regulatory burden, the link between OfS registration and university operating conditions, the summary of Moorhouse findings, and UUK's account of gold plating and disproportionate burden.
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Moorhouse Consulting, 2023
Used for the source, scope and limitations of the UUK-commissioned regulatory burden research, including 54 institutional survey responses and 62 members engaged across the research, the 17.6 FTE estimate, governing-body time, variation by university size, and comments on smaller and specialist providers.
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Office for Students, last updated 24 November 2022
Used for the detailed account of condition C3, including the requirement to have an approved and published student protection plan, implement it where relevant events occur, inform the OfS of triggering events, assess risks to continuation of study, and keep measures credible, deliverable and fair.
Source
Office for Students, last updated 24 November 2022
Used for the account of student protection directions, market exit risk, market exit plans, teach-out, transfer, records, complaints, refunds, compensation, and the requirement that a provider may be directed to consult an insolvency practitioner on feasibility.
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Office for Students, 2025
Used for the explanation that OfS-registered providers must have approved student protection plans covering risks such as course, campus or institutional closure, with measures for completion, transfer or compensation.
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Office for Students, 24 June 2025
Used for the operational detail on course closure: early communication, teach-out or transfer options, review of contractual commitments, refund and compensation policies, contact with applicants, engagement with professional, statutory or regulatory bodies where relevant, and the distinction between formal remedies and practical educational continuity.
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Competition and Markets Authority, 12 March 2015; updated 31 May 2023
Supports the chapter's account of consumer-law obligations in higher education, including accurate pre-contract information, fair terms, complaint handling, changes to course information, express agreement to changed pre-contract information and limits on broad variation clauses.
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Office for Students, 30 July 2024
Used for the link between OfS registration conditions and consumer protection expectations, including accurate information for applicants and students, fair and transparent contracts, complaints processes, student protection plans and the OfS's reliance on CMA guidance.
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Office for Students, 2025
Used for the account of the Annual Financial Return, including who must submit it, the five-month sign-off deadline, the workbook and commentary requirements, current-year and four-year forecast data, governing-body consideration, and the OfS's use of the information to assess financial viability and sustainability.
Source
Office for Students, updated 24 September 2025
Used for the detail that the workbook includes historic and forecast financial information, student-number information, validation checks, provider responsibility for accuracy, and submission through the OfS portal.
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Office for Students, last updated 24 November 2022
Used for the chapter's explanation of OfS financial viability and sustainability monitoring, including annual audited statements, annual financial forecasts for most providers, possible variation by size or risk, F3 reporting of material changes, and additional monitoring where concerns arise.
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Office for Students
Used for the description of OfS expectations for providers under financial pressure, including annual financial returns, additional information requests, low-cash reporting, updated financial and student-number forecasts, commentary on changes and mitigating actions.
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Office for Students
Used for examples of reportable events relevant to institutional distress, including withdrawal of financial support, likely financial covenant breach, likely liquidity below 30 days' average expenditure, termination of partnership agreements and material changes in financial position or forecasts.
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Office for Students, 2025
Used for the chapter's account of provider closure planning, early engagement, multi-agency coordination, course mapping, teach-out, transfer, student records, communications, validating and subcontractual partnerships, and the practical difficulty of planning while an institution is in crisis.
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Department for Education, 16 July 2020; withdrawn 6 October 2021
Used to support the point that the government created a temporary COVID-era restructuring scheme for providers facing financial difficulty, and that this was not a standing post-pandemic restructuring settlement.
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Nursing and Midwifery Council, original publication 17 May 2018; newly published 25 April 2023
Used to support the nursing-course example, including NMC-approved programmes, practice learning, practice learning partners, supervision and assessment requirements, practice learning hours and professional approval.
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UK Visas and Immigration, Version 04/2026, used from 7 April 2026
Used to support the point that international students' position can be affected by sponsor duties, course timing, CAS arrangements and withdrawal of sponsorship.
Go deeper
Selected contextual material that extends or complements the chapter.
Further reading
Office for Students, 16 April 2026; last updated 13 July 2026
Useful current context on the proposed treating-students-fairly condition and proposal to remove the specific requirements relating to student protection plans. The consultation closed on 9 July 2026; the final regulatory outcome should be checked before publication.
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