Office for Students, 2025-2030 Strategy Consultation 

Question 1: Do you have any comments to make on the OfS’s proposed strategy for 2025 to 2030 or the priorities set out within it? 

GBS UK fully supports the OfS’s proposed strategic priorities - Quality, Wider Student Interest, Financial Sustainability, and Protecting Public Money - as they are vital in addressing challenges within the higher education sector. These priorities closely align with GBS’s mission to deliver high-quality, accessible education that caters to diverse student needs. 

To ensure these priorities can be delivered, GBS would like to see OfS improve engagement across the range of education providers, including alternative institutions like GBS. In order to find solutions for the challenges faced by the sector, the regulator will need to be willing to look at different approaches, and learn from alternative providers, other countries and other sectors. Such forums would enable dialogue and facilitate the sharing of best practice and insights into emerging solutions to the challenges in higher education. 

For instance, widening participation is at the core of GBS mission. 71% of GBS students come from IMD quantiles 1 and 2, representing areas with historically low higher education participation. Furthermore, 6% of our students are unpaid carers, and the average student age is 37. These figures reflect GBS’s commitment to ensuring that students from under-represented backgrounds can access high-quality education. Our Foundation Year plays a key role in this, particularly in supporting mature learners and those returning to education after a long break, equipping them with the skills needed for academic success. 

Beyond widening access, GBS strongly supports the focus on quality as a central element of the new strategy. Access to education alone is not enough - students need a learning environment that enables positive outcomes. This is why we welcome the introduction of a Quality Risk Register, alongside the Equality of Opportunity Risk Register, to help mitigate risks to academic standards.  However, we also believe that there are lessons to improving quality from other sectors and industries and that the sector needs to be willing to learn from those and move away from the traditional highly bespoke form of delivery. The OfS should be aiming to play a pivotal role in transforming this approach. 

Student satisfaction is key and the OfS strategy needs to understand that not all students have the same needs. GBS students recognise and appreciate our efforts. In the National Student Survey, GBS achieved a 90% satisfaction rate, significantly exceeding the sector average of 74%. Additionally, 89% of students expressed satisfaction with our mental wellbeing services, 10% above the sector average. 

GBS also agrees with the commitment to measuring continuation and completion as indicators of success. GBS is committed to achieving retention and achievement rates above 80%, meeting benchmarks for alternative providers and reinforcing our commitment to student success. However, we would like a more open discussion as to the appropriate level of benchmark. It is our view that the current approach mitigates against equality of opportunity. Different types of students have different needs and different reasons for withdrawing. The median age of a GBS student is 37. As a result, many of our students who withdraw do so because of life events such as illnesses that their children are suffering from or a change/loss of jobs. In addition, they have not come directly from secondary education and there should be allowance for this transition and for foundation years.  The measurement needs to reflect these complex challenges.  

With the higher education sector experiencing growing financial pressures in recent years, the renewed focus on financial sustainability in the OfS Strategy is welcome. Strong financial management is essential not only for the resilience of the sector but also for minimising disruption to learning and maintaining education quality. At GBS, we ensure that tuition fees provide outstanding value for money. We have developed a high quality approach to teaching which are able to deliver within the funding provided by student loans without the need to additional financial support in the way of grants. We believe that the sector can still make significant improvements in the way teaching is delivered to simultaneously improve quality and reduce cost.   We would particularly welcome a discussion about funding and delivery of foundation years which are essential for widening participation. 

We ​​support the emphasis on financial sustainability and have built GBS on a focussed model of delivery. Our approach is designed to meet student needs while maintaining a high-quality learning experience at a lower cost. By structuring our infrastructure and support efficiently, we reduce non-teaching resources, both staff and estates, ensuring that we operate successfully within the available funding. This enables us to offer an accessible, high-value education without compromising on excellence or student support. 

Question 2: Do you have any comments about any unintended consequences of the proposed strategy or the priorities set out within it, for example for particular types of providers, particular groups of students, or for individuals on the basis of their protected characteristics? 

While GBS supports the OfS’s priorities, the OfS strategy could be enhanced by recognising the importance of innovative delivery methods that cater to the diverse needs of students. Learning models that prioritise flexibility, such as block scheduling, allow students to balance work, family, and academic commitments effectively. This is common practice, for example in the Australian HE sector. The OfS should actively learn from such evidence-based innovations to shape a strategy that supports diverse, non-traditional pathways to ​​success. 

GBS is a sector leader in supporting mature students living in areas of deprivation and our student-centred approach is a core reason for that. At present, 56% of our students are in employment, and 15% run their own businesses alongside their studies. To accommodate their unique circumstances, GBS provides structured timetables that include evening and weekend classes. This approach enables students to continue working while making academic progress, contributing to high satisfaction rates. Beyond benefiting individual students, this model has wider positive implications for the UK economy - supporting workforce upskilling and business growth and allowing individuals to take on better paid and higher productivity careers, and providing employees with access to a skilled workforce. 

Many GBS students come from migrant communities ​​and non-traditional educational backgrounds. Flexible and alternative learning pathways are a necessity in order to engage and improve their learning outcomes in addition to high-quality language support. We aim to ensure that all students - regardless of background - have access to resources and guidance that reflect their individual learning needs. By embedding this principle in the OfS strategy, the sector can promote inclusive education that values diversity in thought and experience. 

GBS has consistently achieved above-sector average student satisfaction scores in the National Student Survey. This includes high ratings in key areas such as assessment and feedback, teaching quality, organisation and management, and learning resources. A commitment to alternative, student-centred learning models will ensure that the sector continues to evolve in ways that benefit all learners while strengthening the UK’s skills base and economic resilience. GBS is concerned that the strategy will focus on traditional forms of delivery and fail to recognise the need to adapt regulatory approach to the needs of students from a widening participation background. Successful widening participation requires the sector to adapt to the needs of these students not to seek to push these students to adapt to the needs of the sector.   

Question 3: Are there aspects of the proposals you found unclear? If so, please specify which, and tell us why. 

We welcome the overarching vision set out in the OfS Strategy for 2025–2030 and fully support its commitment to improving quality, widening access, and fostering innovation in higher education. These priorities are crucial in ensuring that the sector continues to adapt to the evolving needs of both students and institutions. 

​​​A key area where greater clarity is needed is the identification of the diverse needs of students. There is a danger across the sector that the student we talk about is an 18 year-old attending traditional campus-based universities. However, as the OfS rightly acknowledges, this is often not the case. As a result we would like to see clearer identification of the needs of different types of students. While interventions such as embedding student experience into the curriculum may help mitigate loneliness and mental health challenges for younger students at campus Universities, these are not necessarily relevant interventions for mature learners balancing work, family, and study. A regulatory approach that starts by understanding the specific characteristics of the student body being regulated will ensure that policies and interventions are appropriately targeted. 

To maximise the Strategy’s impact, we would like to see the OfS provide greater clarity on how it will be implemented and how stakeholders will be engaged. For example, while the focus on improving graduate outcomes is positive, further detail on how this will be achieved - such as partnerships with employers or sector-wide initiatives - would help institutions align their own strategies and approaches with OfS’s priorities. Similarly, setting out indicative timelines for key initiatives would support effective planning across the sector.  

The emphasis on continuous improvement is particularly important, and we recognise the value of strong evaluation metrics. To enhance transparency and accountability, the OfS could outline the specific indicators it will use to measure progress. For instance, if student well-being is a priority, will this be assessed through retention rates, National Student Survey (NSS) results, or other benchmarks? Clearly defined success measures will help institutions shape their own evaluation processes accordingly. 

We also welcome the OfS’s focus on collaboration with students, educators, and providers. To ensure meaningful engagement, the strategy could specify how stakeholders will be involved in shaping policies and implementation. Regular forums, advisory panels, or dedicated feedback channels would encourage a more dynamic and inclusive dialogue.  We would encourage the OfS to develop methods to engage with students from backgrounds which form part of the widening participation agenda who are often not represented through traditional student representative bodies or traditional alternative providers. 

We are fully committed to working alongside the OfS to support the successful implementation of the Strategy. By providing greater clarity in these areas and engaging positively with all of the sector, the OfS can empower institutions to play an active role in achieving its long-term vision for higher education. 

Question 4: Our previous strategies have covered periods of three years. For this strategy, we are proposing an extended strategy period of five years. Do you have comments on this proposal? 

It is GBS view that the sector remains slow to change and must become more agile.  In addition, many of the sector challenges, including affordability, financial sustainability and widening participation require urgent response.  GBS is of the view that three years better reflects this need for urgency. 

Question 5 

5a) Do you think that our proposed ‘I statements’ appropriately and clearly describe the impact that delivery of our strategic objectives should have on our key stakeholders? 

GBS does believe that the proposed ‘I statements’ appropriately and clearly describe the impact that delivery of the OfS strategic objectives should have on key stakeholders, across students, academic institutions, the OfS, and the public. 

The ‘I statements’ are an effective measure that crystallise the ambition and final outcomes of the OfS strategy, demonstrating what the desired effect of the priorities and objectives should mean for the various different stakeholders. 

5b) Do you think that the strategic objectives distilled in our proposed ‘I statements’ are the right ones? Do you propose any additional ‘I statements’? 

At GBS we serve many students who are otherwise unable to access Higher Education, and as a result, our approach centres around supporting the specific needs of these students, often unique to the HE sector as a whole. 

We would welcome a more distinct ‘I statement’ that takes account of this and ensures that a focus remains on the mission that, regardless of background, age, or nationality, students can access HE in order to further their learning and enhance their outcomes in life. 

A potential statement that encapsulates this aspect could be: 

‘I am confident that my background and my current circumstances do not hold me back on my educational journey, and I have access to a learning environment that caters for my specific ​​needs’. 

This addition would help to ensure that the framework explicitly acknowledges the importance of accessibility, and tailored support for students facing barriers to higher education. Embedding this perspective within the strategic objectives would reinforce the commitment to inclusivity and student success, aligning the review’s ambitions with the diverse realities of the HE sector.