Does the TEF’s latest iteration deserve a gold rating?

Universities will be punished for the students they admit

No one in higher education should defend poor teaching. If a course is failing its students, the regulator should act quickly. But the Office for Students’ revised Teaching Excellence Framework, which its co-chief executives say will have “real regulatory bite”, is a blunt instrument pointed at a precise problem. I fear it will damage the institutions that do most to widen opportunity.

Start with what the framework measures. The TEF is meant to reward good teaching but much of it rests on student outcomes, such as progression into graduate employment. Those outcomes depend heavily on things teaching can’t control. Students from more privileged backgrounds often have networks and confidence, and a university that admits students without those advantages and still gets them into good jobs is doing excellent work. The new TEF will only look at the destination, not the journey to get there.

Then there’s the problem the OfS says it’s trying to solve. The English regulator speaks of pockets of poor provision, particularly in franchised courses. I don’t dispute that these exist but we already have tools for finding them. The B3 registration conditions on student outcomes and National Student Survey monitoring identify weak courses and trigger action. Building a high-stakes, sector-wide rating system to catch a minority of providers is like closing a motorway to deal with a pothole.

The TEF is an institutional judgement. Yet students do not enrol at institutions in the abstract – they enrol on courses. Even a gold-rated university will have bronze provision in some courses, while a bronze-rated one will have outstanding courses. What does a single rating tell an applicant choosing between two degrees? What does it tell the OfS about where quality is actually lacking? A label that is simultaneously too broad to guide students and too crude to guide regulators is not a quality system.

All this is a missed opportunity. Our most stubborn quality problem is the gap in life chances between students who arrive with socio-economic advantage and those who do not. A genuine quality framework would put that gap at its centre and reward institutions that close it. These proposals risk treating the gap as a mark against the universities working hardest to narrow it.

We’ve been here before. Ofsted’s framework has been criticised for penalising schools that take on the most complex and highest-need pupils. Heads in difficult circumstances ask whether it is rational to take young people who will count against them. Universities will ask the same question. If the stakes of a poor rating are high enough, even the most mission-driven institution will feel pressure to recruit fewer students from disadvantaged backgrounds, because their outcomes are statistically riskier. 

I have one other observation to make. Research has found that the people who actually teach in universities often feel uninvolved in – and unaffected by – the TEF. Their expertise, commitment and craft are not examined. A Teaching Excellence Framework that does not engage with teachers is a curious thing. If we want better teaching, we should be investing in the people who teach, rather than simply publishing a medal table.

I am not arguing for less accountability. London Metropolitan University welcomes scrutiny because our students and staff deserve nothing less. I am arguing for accountability that is accurate, fair and aimed at the right target. The OfS should use the tools it already has to tackle poor provision and build a framework that recognises the distance students travel, rather than only where they started. And it should involve teaching staff in shaping it.

The consultation is open. I hope the sector, including those who expect to be rated gold, will use it to join me in arguing that a quality system that penalises opportunity is not worth having.

Julie Hall is vice-chancellor of London Metropolitan University.

If the TEF has teeth, when should it bite?  

Review and reinvention have been recurring features of the TEF since it was unveiled in 2015. Both how the exercise works and what its ratings are intended to achieve have been regularly recalibrated, in line with political tides.

This mercurial quality – losing, gaining and sometimes regaining features along the way – has helped the TEF endure but has also obscured understanding of its methods and purpose.

Those who have been following the TEF from the start will recognise that we have now travelled almost full circle. The scheme was originally intended to inform undergraduate home fee increases, but this was never implemented. Instead, the TEF had only indirect effects, such as informing student choice about where to study and raising the status of teaching within universities.

Following a review and the shelving of the subject-level TEF in 2021, the emphasis shifted towards incentivising excellence. Informing student choice became a secondary objective.

Now, the second phase of the OfS’s consultation on assessing and rating quality in England points towards another iteration from 2027-28. This time, the TEF really will have “real teeth”, as part of a single, integrated quality system.

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Each year, the OfS would select a cohort of providers to assess whether they continue to meet minimum quality requirements covering both student experience and student outcomes. In addition, providers could choose to enter the TEF, receiving one of the familiar gold, silver, bronze or “requires improvement” ratings.

In practice, providers will be financially compelled to enter. Under the proposals, higher-rated providers could be rewarded with access to public teaching funding and permission to increase their fees. They would also be selected for reassessment less often, reducing the regulatory burden. But providers receiving a bronze rating could have their student numbers frozen, and those rated requires improvement could face a 10 per cent cut in recruitment.

So the framework will now have responsibility for policing, not just auditing, the sector. The argument is that simply unleashing the right incentives, encouraging good practice and hoping for the best is not sufficient for quality assurance. We must also assess how good something is and ensure there are consequences when it falls short. Even naming and shaming may not drive change; a regulator may need to intervene and stop things from happening.

After all, higher education in England has changed considerably since 2015. The sector is now more diverse in terms of provider type, ownership, size, specialisation and student recruitment. Moreover, validated and subcontracted provision has grown significantly, raising concerns in parliamentary reports that the OfS, as the sector’s regulator, cannot ignore. The regular now needs a stronger tool to deal with an increasingly complex system.  

But if the TEF now has the teeth it was always meant to have, the question is when it should bite. When will doing so have meaningful, positive effects? It does not take much imagination to see that the exercise as envisaged could begin to reshape the size and structure of the sector in ways that are difficult to predict and potentially damaging.

One concern is that since the TEF is an institutional-level award, a provider might be penalised across the board for shortcomings in one area. Another is that frozen fee increases and removal of public funding would reduce the resources available for improvements. A third is that a “requires improvement” rating could result in courses being removed from locations where students have few alternative options.

On the other hand, you could argue that the TEF still won’t bite hard enough. A recruitment cut of 10 per cent for an institution rated “requires improvement” is all very well but the other 90 per cent are still being allowed to attend a provider that has been judged unsatisfactory. What is the purpose of a regulator whose responsibility is to act in students’ interests if it allows so many students to continue studying at a provider deemed not to be meeting minimum quality standards?

The assumption behind the recruitment cut is that it will incentivise rapid improvement. But what if it does not? To address this, the OfS proposes that two consecutive “requires Improvement” outcomes could result in suspension or removal from its register. However, the consultation also notes that any intervention would depend on the circumstances, including the seriousness and persistence of the concerns and their impact on students.

Retaining a level of regulatory discretion is wise. We might live in an age of data-driven quality but human judgement will still be needed. Still, exercising good judgment isn’t easy. The OfS’ ability to do so will determine not just the success of the TEF but also the regulator’s own credibility.

Andrew Gunn is lecturer in education at the Manchester Institute of Education, University of Manchester.

Is there any point to the TEF now?

The Teaching Excellence Framework has always intended to change the ways in which English higher education institutions operate. But the precise changes it aims to incentivise have repeatedly shifted over the decade that it has been part of the English higher education landscape.

When the TEF was introduced, the aim was to inform student choice, to recognise and reward excellent teaching, and – in ways that were never clear – to ensure higher education better met the needs of its stakeholders. It was thought that the award of a gold rating would inform student choice and lead to increases in student recruitment, prompting other institutions to up their game on teaching. But, as predicted by many, this never came to pass.

Following the publication of Shirley Pearce’s excellent independent review in 2021, the exercise’s primary purpose was recast as encouraging higher education institutions to take quality enhancement seriously, with a secondary purpose of informing student choice.

In the first phase of the OfS’ current consultation on the future of the quality system, which started back in September 2025, the aim has shifted again. Now the regulator is seeking to incentivise quality above its minimum standards. The important change is that rather than the TEF acting merely as a motivational signal to institutions, the level of TEF award will now directly determine whether they can maintain their levels of student recruitment (bronze) or increase it (silver or gold). Those rated “requires improvement”, meanwhile, will be obliged to reduce their recruitment by 10 per cent.

Although this proposal is eye-catching, the fact that it will not be introduced until 2030-31, when the demographic dip in 18-year-olds will take effect, suggests that it will have less impact than the other major change proposed by the current consultation: the ability of universities with silver and gold ratings to raise their fees to new maximum levels, set by the Department for Education. 

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The extent to which the TEF was ever really a framework for highlighting and celebrating teaching excellence is questionable. Most of that emphasis was rhetorical. But it is still notable how the aim to ensure parity of esteem between teaching and research – with the name of the TEF deliberately mirroring the established Research Excellence Framework – now feels as if it was of a different age. The current consultation mentions the words teaching only 14 times, and excellence only four times. Far more numerous are mentions of the terms student experience (148), student outcomes (149) and compliance (51).

So although the official name of the exercise has contracted back to Teaching Excellence Framework after a brief stint, around 2017, as the Teaching Excellence and Student Outcomes Framework, it would now be more accurately called the Student Experience and Outcomes Regulatory Compliance Instrument”. It is hard to see how such a system would inspire former universities minister Jo Johnson to wax lyrical about “inspiring academics who go the extra mile” and “change our children’s lives”, as he did when introducing the TEF back in 2015. 

Indeed, it is not unreasonable to ask whether students, institutions or even the OfS are well served by the pursuit of compliance through a partially independent review system, given the significant additional bureaucratic processes, time and resources it involves. If the TEF is merely about ensuring expected levels of performance on a number of measures of student experience and outcomes, why not simply have a system that examines whether universities meet these expectations without the need for institutional and student submissions or review panels of academics, students and OfS staff?

Since these are mainly intended to contextualise the identified measures, it could be left to universities’ discretion whether to produce them, after an initial data-based judgment is announced. If an institution felt that this judgement did not match the quality of its provision, it could be given the chance to submit such contextual evidence.

Another alternative would be to deal with compliance entirely outside the TEF and go back to spirit of the recommendations of the Pearce review, designing a TEF focused on examining how higher education institutions systematically enhance the quality of their teaching across the whole organisation.

In a higher education system under increasing financial stress, either of these approaches would offer much more focused and effective ways of proceeding than dressing up a system of compliance as a system of quality enhancement.

Paul Ashwin is professor of higher education at Lancaster University. 

Excellence needs investment, not penalties

The scale of the financial crisis facing English universities was highlighted a year ago, when the Office for Students forecast that almost half of them would be in deficit in 2025-26. The OfS has also warned that certain universities’ long-term financial projections, typically based on expected student number increases, could be overly optimistic.

Against this backdrop, one might expect proposed regulatory reforms to avoid measures that could exacerbate existing challenges. Instead, the Office for Students’ revised set of proposals for the next iteration of the Teaching Excellence Framework include an intention to require institutions with an “unsatisfactory” outcome to reduce their recruitment by 10 per cent annually until reassessment. Furthermore, institutions awarded baseline quality outcomes (satisfactory or bronze across all aspects) could potentially be restricted from growth.

The freezing or loss of associated fee income could, of course, further undermine the very teaching and learning quality that the TEF seeks to protect and enhance. If a university were forced to shrink, it would be difficult to avoid cuts across pay and non-pay budgets. For existing students, this could lead to increased student-to-staff ratios and reductions in support services or learning resources.

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For future students, there could also be reduced choice. Faced with reduced income, institutions might elect to cut underperforming subjects or withdraw specific subject areas, potentially creating higher education cold spots within a region. Such changes would be particularly detrimental to learners from widening participation backgrounds, who are often less able to relocate to study.

Staff would also be negatively impacted. A sizeable reduction in fee income would almost certainly lead to job losses across both academic and professional services. Even if compulsory redundancies could be avoided, institutions would probably need to put in place recruitment freezes and restructuring programmes to reduce expenditure. Such actions would have significant implications for mental health, well-being and workload pressures, further undermining any attempts to enhance teaching excellence – not to mention sitting uneasily with OfS support for initiatives such as the University Mental Health Charter.

Given the financial implications of a reduction in student numbers, it is conceivable that some providers would seek to challenge their TEF outcome through regulatory and/or legal routes. Such cases have the potential to be costly for both the OfS and institutions, especially if they become complex and protracted. And the diversion of already limited institutional resources could undermine capacity to invest in activities that would support teaching excellence, student experience and student outcomes. 

Beyond these unintentional outcomes, the OfS’ proposals raise several significant questions related to evidential basis and implementation.

What is the evidence for the assumption that a reduction or cap on student numbers leads to enhanced learning and teaching? Why was a 10 per cent reduction determined to be appropriate – as opposed to, say, 3 or 5 per cent? What would happen if the student numbers of a university deemed unsatisfactory had already fallen substantially over several years – would any account be taken of that? And given that many TEF metrics are based on longitudinal data, how quickly would an institution be able to escape a sanction?

Another worry is that the existence of number cap sanctions – with their potential to cause serious institutional damage and provoke appeals and legal action – could negatively impact the recruitment of TEF reviewers.

These questions are not mere technical details. Given the potential financial consequences of a poor TEF rating, there must be a clear evidential basis that the OfS’ reform proposals are proportionate and will be effective.

An alternative approach to working with providers that do not meet teaching and learning expectations is suggested by the lessons identified by the regulator following the University of Sussex’s successful overturning of its fine for supposed free-speech breeches earlier this year. The OfS recognised the importance of respectful relationships with providers, including communication, transparency and alternative forms of intervention.

These principles would suggest that teaching quality is most likely to be enhanced by meaningful collaboration. This would need to include students as partners and could also incorporate targeted peer-to-peer support between institutions. Realistic improvement targets would be agreed between the OfS and providers, with recognition of local context. Where an institution has rapidly grown its student numbers, an agreed reduction could be an appropriate and proportionate action – but reductions would not be imposed as a blanket approach.

No one disputes that there must be accountability for student experience and outcomes. However, for meaningful sector buy-in, the next iteration of the TEF must be a process for driving improvement through investment, partnership and support – not a potential trigger for advancing institutional decline and even market exit.

Steve Briggs is director of learning, teaching and libraries at the University of Bedfordshire. He writes in a personal capacity.