Study Route visa changes ahead for student sponsors and international students

2025 is already proving a year of significant visa rule changes for the international student sector – and we are only just through the first quarter. Student sponsors and international students must prepare for key immigration changes over the next few months, including planned Confirmation of Acceptance for Studies (CAS) and visa fee increases from 9 April 2025, new fields on the CAS about Recruitment Agents, and the removal of visa corrections from the Administrative Review process for in country applicants. Additionally, the Home Office is introducing a new Genuine Intention to Study rule into the Short Term Student Visa route, and we also saw the publication by the Home Office, in January, of its new Remote Delivery policy, which will expressly permit eligible sponsors to offer some online learning to their international sponsored students for the first time.

The recently published Statement of Changes to the Immigration Rules outlined significant new safeguarding changes to the Child Student Visa route, which will affect independent schools sponsoring Child Students. Due to come into effect on 29 May 2025, the measures are aimed at strengthening child safeguarding with new requirements relating to sponsored boarders and their care arrangements outside of school boarding. These new safeguarding rules are explored in a separate article.

Visa fee increases

In unwelcome news for student sponsors and international students, there will be significant increases in student visa and sponsorship fees with effect from 9 April 2025. When the visa fee increases were first announced in January, the Government confirmed the hikes in immigration fees were part of efforts to reduce the reliance of the UK’s immigration system on taxpayer funding.

Student and Child Visa Application fees for entry clearance and in country applications will increase to £524 (from £490). There will also be a significant 120% increase in the fee to assign a CAS, with the mandatory fee increasing by £30 to £55. Unlike with Certificates of Sponsorship for staff sponsorship, the Student Sponsor Guidance does not (yet) prohibit student sponsors from clawing back this fee from a prospective sponsored student. Many student sponsors already charge an administration fee to cover the cost of assigning a CAS. However, it will be important to watch out for any new restrictions in the student sponsor guidance on the ability to pass on this CAS fee to students.

With effect from the 9 April 2025, there will be other Student Sponsorship fee increases to watch out for:

• Student sponsor licence application fee: £574 (from £536)
• Student sponsor Basic Compliance Assessment fee: £574 (from £536)
• Sponsor Action Plan fee: £1,579 (from £1,476)

Short-term Students – New ‘genuine intention to study’ rule

The Short-term Student Visa route is for individuals who wish to study an English language course in the UK which is longer than six months but not more than 11 months. Applications made under the Short term Student (English Language) route, from 9 April 2025, will be subject to a new 'genuine intention to study' rule. This will enable Home Office caseworkers to refuse applications where they are not satisfied the applicant has a genuine intention to study the course listed on their application and leave the UK at the end of their course.

With effect from 9 April 2025, a Short Term Student applicant must satisfy the decision-maker that they are a genuine student, which means they:

• Are genuinely seeking entry to the UK to study the course that they have been accepted on to and will not study any other course in the UK;
• Will not study at an academy or state funded school;
• Will leave the UK within 30 days of the end of their English language course, or at the end of 11 months, whichever is sooner;
• Will not make the UK their main home;
• Will not work in the UK (nor engage in business or professional activities in the UK);
• Have relied on funds that are genuinely available to them for the purposes of undertaking the course of study they have been accepted on to.

Changes to Administrative Review for visa corrections and validity rules

Where an applicant believes a case working error has been made by the Home Office in refusing their Student or Child Student visa application, it is possible to challenge the visa refusal by making an Administrative Review application for a fee of £80. Administrative review is also the mechanism currently in place for applications made in the UK which result in Home Office visa errors (whereas visa errors made following an out of country application are dealt with by the Home Office's Error Correction team).

With effect from 9 April 2025, however, Administrative Review will no longer be the mechanism to challenge incorrect visa conditions and length of permission errors. In a welcome change, error correction grants will be removed from Administrative Review. The Home Office’s out of country Error Correction team will be expanded to cover in country cases where there is an error in conditions or length of UK immigration permission granted.

New validity rules also make clear that an applicant cannot make an Administrative Review application outside the UK when they are challenging the refusal of an application for permission to stay (i.e. applicants must remain in the UK to apply for an administrative review against their visa refusal). In addition, an application for Administrative Review will be invalidated if an immigration application is made while the administrative review application is pending. This change will ensure that a person is only considered for one grant of UK immigration permission at a time, avoiding conflicts should both applications be granted.

Trinidad and Tobago

Nationals of Trinidad and Tobago were added to the 'Visa national’ list on 12 March 2025 by the latest Statement of Changes. This means that such nationals will now be required to obtain entry clearance (a visitor visa) before travelling to the UK. Prior to 12 March 2025, such nationals could seek permission to enter the UK upon arrival. Trinidad and Tobago has also therefore been removed from the list of countries whose nationals are eligible to apply for Electronic Travel Authorisation.

Recruitment agents

With an increasing spotlight on the link between recruitment agents and sponsor compliance, the Home Office has separately confirmed that a new Agent field will be introduced on CAS by this summer. It will initially be optional for student sponsors to insert on the CAS the details of any agent used to recruit an international student. However, this CAS field is likely to become mandatory in future.

Student sponsors already have a duty to provide the Home Office with details of the recruitment agents they use. Inserting agent details on a CAS, however, underlines how important it is for student sponsors to carefully vet and monitor the agents they use to recruit their international sponsored students. All student sponsors and agents should work within the new British Council UK Agent Quality Framework ,which provides best practice in this area.

Remote delivery

It has been long-standing international student visa policy that any study in the UK must take place at the teaching site of the student sponsor. As a result of Covid 19, the Home Office provided concessions for student sponsors to use online teaching methods to deliver courses to international students on the Student Visa route. Since the Covid 19 Concessions were formally withdrawn on 30 June 2022, the Home Office has been consulting with student sponsors to allow the delivery of course elements remotely whilst setting boundaries to ensure UK immigration control is not compromised.

Further to extensive consultation with stakeholders, the Home Office published its final Remote Delivery Policy on 14 January 2025. The provisions of the new Remote Delivery Policy were included in the latest version of the Student Sponsor Guidance published on 19 March 2025. These provisions provide new definitions for what constitutes remote delivery and, most significantly, when student sponsors are able to offer courses remotely to their international students.

Defining Remote Delivery

Remote Delivery is now defined in the Student Sponsor Guidance as "timetabled delivery of learning where there is no need for the student to attend the premises of the student sponsor or partner institution which would otherwise take place live in-person at the sponsor or partner institution site”.

Face to face delivery is now defined in the Student Sponsor Guidance as "timetabled learning that takes place in-person and on the premises of the student sponsor or a partner institution”.

When Remote Delivery will be permitted

Under the new Remote Delivery policy, face to face delivery must remain the predominant method of delivery with remote delivery permitted as follows:

• Higher Education Providers with a Track Record of Compliance may deliver up to 20% of the taught elements of any degree course level and above course remotely; or
• Higher Education Providers with a Track Record of Compliance may deliver between 21% and 40% of the taught elements of the overall course at degree level or above remotely where the sponsor has obtained prior approval for the course delivery from the Student Sponsor Compliance Team to offer the course to sponsored students; or
• The course is at any academic level at a student sponsor and usage of remote delivery is required for a specific student to prevent discrimination on the basis of their protected characteristics under the Equality Act 2010; or
• The course is at any academic level at a student sponsor and remote delivery is required for the general student body where continuity of education provision would otherwise be interrupted by unforeseen circumstances (such as industrial action, extreme weather, or periods of travel restriction).

A Higher Education Provider establishes a ‘Track Record of Compliance’ by passing their annual Basic Compliance Assessment for four consecutive years and maintaining their Educational Oversight (i.e. from Office for Students for English providers) consistently for four years. For Higher Education Providers holding a Track Record of Compliance, this status will be confirmed in the public register of student sponsors with ‘Student Sponsor - Track Record’.

The Student Sponsor Guidance has added remote delivery provisions to the Academic Engagement requirement for Higher Education Providers. Remote delivery has been added as an example of academic engagement with a new requirement that any academic engagement monitoring systems must be able to identify whether learning is taking place face to face or remotely.

There is also a new sponsor duty to report to the UKVI and withdraw sponsorship if a sponsor becomes aware that the student has exceeded the permitted level of remote delivery for their course.

Remote delivery restrictions

Accordingly, unless there are exceptional circumstances or a need to prevent discrimination, student sponsors offering courses below degree level are prohibited from offering courses remotely to their sponsored students. The Home Office rationale for the differing approach between degree level and below degree level study is that below degree level courses are shorter, cheaper and with lower English language ability and are therefore "more vulnerable to abuse from non-genuine students".

Student sponsors offering courses to international students below degree level (or sponsors delivering courses at degree level or above without a Track Record of Compliance) must therefore ensure that their teaching continues to take place at the teaching site. Student sponsors offering courses at below degree level must also continue to ensure their sponsored courses include a minimum of 15 hours per week 'classroom based' study. Interpreting the ‘classroom based’ study requirement as being consistent with the new definition of 'face to face delivery" in the Home Office’s Remote Delivery Policy also appears sensible.

Remote Delivery uncertainty

There is significant concern amongst student sponsors that the remote delivery provisions have already been included in the Student Sponsor Guidance without an implementation date nor a transitional period for implementing the Home Office’s Remote Delivery policy.

For instance, those Higher Education Providers with a Track Record of Compliance who are able to offer remote delivery for their international sponsored students have not had sufficient time to calculate the percentage of remote delivery for courses starting this September 2025. Details must be provided via the annual CAS allocation process where remote delivery is between 21%-40%.

This situation is therefore creating a lack of clarity for student sponsors with uncertainty how the Home Office would apply the remote delivery provisions in the Student Sponsor Guidance when conducting audits. It is hoped that the Home Office will provide urgent clarity in the Student Sponsor Guidance about the timeline for implementation.

Contact us

If you have any queries about how the new Study Visa Route changes affect your education institution and international students, please contact Anna Blackden or submit an enquiry form, below.