Sir Alan Langlands, chief executive of the Higher Education Funding Council for England, said the cancellation of a proposed higher education bill earlier this year had been a "game-changing moment".
Speaking at GuildHE's annual conference, held at the Leeds College of Art on 12-13 November, Sir Alan said: "We're facing a strange situation, where we will be pursuing [policy] for five years without the parliamentary implementations in place."
He said that regulation was needed to bring private providers under student number controls, adding that the expanded student loan book also posed a problem.
"Vast sums of money will flow through the Student Loans Company and there is no effective control on that," he said.
Once the National Audit Office began examining the public money underwriting student loans, stricter controls were likely to be introduced, he predicted.
Arguing against deregulation, Sir Alan said that formal legislation relating to higher education would "uphold high standards and contribute to international reputation, stimulate student demand by providing assurance [about quality]...encourage third-party investment and underpin bank lending".
The sector's rejection of plans to reduce Quality Assurance Agency checks on some universities showed that it did not want to be an "international outlier" in regulatory terms, Sir Alan argued.
"I think you should be careful what you wish for when it comes to ditching all regulation," he said.
His leadership of a taskforce set up to help foreign students affected by the London Metropolitan University visa crisis had convinced him that students required more rights under the new system, he added.
Sir Alan also said that talk of a 50,000 shortfall in undergraduate numbers was overplayed, as this year's figures should be compared with recruitment in 2010-11.
"We are about 20,000 short of where we want to be," he said.