Horizon scanning: what to watch in 2026
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At a glance
- The white paper sets out a vision for a more collaborative, specialist sector, but leaves unresolved the incentives and regulatory structures that work against it.
LLE policy is about to meet reality. The LLE launches this year with limited clarity on eligible modules or quality accountability, and implementation will test how it works in practice.
Medr is moving from consultation to implementation of its new tertiary regulatory framework and HE provider register, with rollout beginning in 2026–27 and QAA supporting delivery.
Following new legislation, the Scottish Funding Council will take on expanded oversight of tertiary education and apprenticeships, with focus now on implementation.
QAA is in constructive discussions with the Department for the Economy on a new review method balancing assurance, enhancement and a sustainable programme of funded activity.
Both the Scottish and Welsh Governments have launched major reviews into the long-term sustainability and future shape of tertiary education, with QAA contributing evidence and expertise.
- With Scottish and Welsh elections due before review outcomes are published, QAA will undertake structured political engagement to inform future policy thinking.
This horizon scanning briefing looks beyond announcements to explore how UK HE policy developments may play out in practice over the next year, helping institutions prepare and inform decision-making.
So, what happens next? The year HE policy meets reality
2025 was the year of higher education policy announcements across the UK. In England, we finally got the long-trailed Post-16 Education and Skills white paper and the Office for Student’s integrated quality model.
In Wales, Medr began consulting on their approach to quality and the Minister announced a review on the future of tertiary education in Wales.
Scotland saw the Tertiary Education and Training Bill pass Stage 3 on its way to becoming an Act of Scottish Parliament, and in Northern Ireland we continued discussions with DfENI on developing new quality assurance and enhancement arrangements with the aim of resuming review activity in the nation.
And for my fellow European buffs, the government announced a long-awaited return to Erasmus and the revised European Standards and Guidelines for quality assurance were released for consultation.
What we were left wanting for was the detail of how all these announcements will translate into tangible change for the sector. All the uncertainty 2025 left us with makes me cautiously optimistic that 2026 is the year we see real action. I may be left eating my words when 2027 rolls around, but for now, here’s what I’m expecting (or hoping) to see come to fruition over the next twelve months.
Hi, is that HERA? It’s collaboration calling
The white paper laid out a laudable ambition for a more collaborative, integrated and specialist sector. What it didn’t do is reckon with underpinning systems, incentives and regulations that make it difficult for the sector to realise it on its own.
Instead, we saw the government introduce the often suggested and often derided idea of linking fees to quality (or more accurately, TEF ratings). Turning quality into a game of monopoly (where the good have the resources to get better, and the worse rated risk being locked into a cycle of decline) will have potentially existential impacts on providers, students and the sector at large.
The government insist they don’t want a competitive market in higher education, but this proposal intervenes quite substantially to try and make the sector act like one. Introducing differential fees and two tiers of provision is likely to intensify competition between providers and is unlikely to encourage the kind of cross-sector working other parts of the white paper extol so fervently.
These plans were reiterated in the OfS’s integrated quality model consultation, the outcome of which we should learn this summer. With the system currently in flux, we have the opportunity to adapt the proposals to drive the sector more towards the government’s more collaborative vision.
Embedding expectations around collaboration, removing proposals that will penalise improvement that isn’t yet borne out in the data and implementing clear action plans for providers who end up losing funding because of their rating would help to bring the government and regulator’s vision closer together.
We’ve got a planned project on the topic coming up this year – stay tuned and, if you’d like to be involved, get in touch.
No, not that kind of collaboration
The government is not, however, all in on collaboration in all its forms. One area we know we’ll see concrete change this year is franchising regulation. After much debate, coverage and deliberating from DfE, we’re expecting two key changes to come into place this year.
Firstly, all delivery providers with a headcount of more than 300 students will be required to register with the OfS. For those already at this number, an eligible application must be made by 30 June to avoid any penalties. Many in the sector will have been relieved with the late in the year announcement, after much speculation that the DfE were minded to go further. I'm sceptical about whether this will address the root cause of quality and standards concerns – OfS registered providers haven’t been left out of the coverage completely – but it will make this area of provision much more transparent.
Concerns that lead providers had managed to get off quite lightly with the government’s measures are, however, mitigated somewhat by the OfS’s proposals for condition E10. My hope is that it drives targeted intervention in a high-risk area and prompts lead partners to look again at their oversight of partnership provision. But it also feels like we're getting a new condition to reiterate responsibilities providers already have. I’m no fan of regulatory overreach, but this seems to me like one area the regulator could afford to reach a little further on.
LLE policy is about to meet reality
2026 will also be the year when students can start applying for modules under the Lifelong Learning Entitlement (LLE). The doors open as soon as September, but we don’t yet know which modules have been deemed eligible, or how providers will be held accountable for the quality of those that are. Instead, we’ll kick off with relatively little to go on and, consequently, very few providers actively engaged.
But after years of policy development, commitment from successive governments and trials that were at best inconclusive, and at worst undermined the whole premise, the LLE will finally see the light of day. And I expect the launch will throw some of the very real challenges and potentially misjudged assumptions (from all sides) into fresh relief. Nothing pokes holes in a policy like the behaviour of those it's designed to impact, and this year we’ll start to see how students actually respond.
I expect the reality of the LLE may make the sector, the government and hey, even us, realise that we weren’t right about everything. I’m excited to see how it all ends up coming together and what we can learn to make more flexible, lifelong learning a reality that makes sense for students, the sector and skills.
Medr regulatory reform: now comes the hard bit
In 2025, Medr consulted on the development of their new regulatory framework for tertiary education in Wales. Such was the extent of the proposals that Medr had to carry out two separate consultations over the course of the year. Combined with the Welsh Government’s consultation on the development of a new register for higher education providers, there was plenty to get our teeth sunk into in Wales.
The focus for Medr now almost immediately pivots from consultation to implementation as they begin to accept applications for the new register for higher education providers in April with a view to it going live over the summer as the new regulatory framework begins its rollout for the 26-27 academic year. This is an ambitious timetable, reflecting the scale of change underway across the Welsh tertiary system. QAA will continue to work closely with both Medr and the sector as the new framework is implemented in the months ahead.
Scotland reform: from legislation to implementation
The passage of the snappily titled Tertiary Education and Training (Governance and Funding) (Scotland) Bill marks a significant step towards greater coherence across Scotland’s post-16 education and training landscape. The legislation expands the powers and responsibilities of the Scottish Funding Council, including a more holistic role in the oversight of all apprenticeships.
QAA will continue close dialogue with both the Scottish Funding Council and the Scottish Government as the Bill becomes and Act and attention turns to detailed implementation.
Northern Ireland: progress, but let’s not jinx it
QAA continued to have positive discussions with DfENI on QAA’s proposals for a new review method in Northern Ireland. We are hopeful for a positive conclusion, with the aim of agreeing an approach that supports both robust external review and sector enhancement, and that enables QAA to deliver a sustainable programme of funded activity in Northern Ireland.
Sustainability reviews are having a moment
Fellow politicos among us will be aware of recent political announcements concerning further and higher education in both Scotland and Wales in recent weeks.
Just before Christmas, the Minister for Further and Higher Education in Scotland announced a review, in partnership with Universities Scotland, aimed at securing the long-term financial viability and sustainability of Scotland’s university sector. QAA will continue to engage with Scottish Government officials and will share our perspectives on this vital issue.
Just last week, the Welsh Government opened a call for evidence into their own review on the Future of Tertiary Education in Wales, focused on both the sustainability of the tertiary sector, as well as increasing participation in post-16 education in Wales. QAA will be submitting our response to this call for evidence for consideration and will continue engaging with Welsh Government as this work progresses.
The small matter of elections
It should be noted that outputs from both reviews are not expected until autumn 2026 at the earliest, by which time national elections will have taken place in both Scotland and Wales.
While QAA is not a campaigning organisation and will not be producing manifestos or making public asks of prospective parliamentary candidates, we will undertake a programme of engagement in the run-in to both elections. This will enable us to engage constructively with political stakeholders across the devolved landscape and ensure QAA’s expertise can inform policy thinking ahead of the next parliamentary term and beyond.
From monitoring to (QAA) membership
All this leaves us plenty to sink our teeth into over the next year. We’ll be tackling all this and more across our networking communities (including our first ever Executive Leader Retreat!), new resources and our engagement with policymakers across the UK. And if there’s a particular policy area that’s piqued your interest, do reach out to the team at publicaffairs@qaa.ac.uk.