Admissions figures obtained by Times Higher Education show that there has been a much slower response rate to offers this year than in 2010, particularly among applicants who are not awaiting examination results.
Critics say this is further proof that the change in the funding system that will come into force in 2012-13 has been poorly communicated to the public.
They also warn that the figures are evidence that students applying next year will be put off by universities setting fees at £9,000, the maximum permissible level.
Applicants who received all their offers from institutions by the end of March have until 5 May to decide which one to accept as their "firm" choice.
Those whose offers are conditional on exam results can also make an "insurance" choice.
Statistics issued to institutions by the Universities and Colleges Admissions Service, which have been seen by THE, show that by 15 April - just three weeks before the deadline - the number of unconditional offers accepted was down by 12 per cent on last year.
The number making firm acceptances of conditional offers was also down by as much as 20 per cent when a snapshot of the situation was taken last month, although the gap has since narrowed.
The statistics appear strange when compared with the previous official Ucas application figures, released in March, which show a rise in the number of people seeking university places compared with a year ago.
One senior university manager, who did not want to be named, said there was anecdotal evidence from admissions officers, parents and students of confusion among English applicants over when the maximum cap of £9,000 will come into force.
This had led many students to delay decisions on whether to start university this autumn because they were not sure whether they would be subject to fees of £9,000 in their second year, he suggested.
In fact, the current system of lower fees will apply to the 2011-12 intake throughout their courses. Only students applying this year who defer their studies until 2012-13 will face the higher cap.
Aaron Porter, president of the National Union of Students, said: "If it is true that students are being deterred even next year because they have misunderstood the reforms and when they are being implemented, this is further proof of a poor policy, horrifically communicated by the coalition, falling further into chaos.
"It is also a hugely worrying sign that students will be deterred from going to university altogether. We could see drops by as much as 20 or 30 per cent from 2012."
Les Ebdon, chair of the Million+ group of new universities, said: "There is a lot more explaining to be done about £9,000 fees or we face a huge drop in numbers."
A spokeswoman for the Department for Business, Innovation and Skills stressed that the new regime would apply only to those "starting their studies in 2012 onwards".
She added: "No one will be asked to pay for their studies upfront and you will only pay back loans once you are in a well-paid job."