In keeping with its commitment to ‘Restoring Control Over the Immigration System’, the Government recently published updated student sponsor compliance guidance which confirms that these tougher compliance standards to remain a licensed student sponsor are now in effect since 1 June 2026. Student sponsors must brace themselves for the new publicly available Red-Amber-Green rating system to track a student sponsor’s compliance – with corresponding new UKVI enforcement tools where student sponsors do not meet the required compliance standards in respect of the international students they recruit and sponsor on the UK’s Child Student and Student visa routes.
Basic Compliance Assessment
Student sponsor licence holders must apply for a Basic Compliance Assessment (BCA) every 12 months paying an annual fee of £574. The BCA measures a sponsor’s compliance against certain key metrics in order to determine whether a student sponsor can retain its student sponsor status and therefore maintain its ability to recruit and enrol international students.
Student Sponsor Guidance on New Student Sponsor Compliance Standards
We examine below the key compliance changes published in the Student Sponsor Guidance on 1 June 2026 (UKVI Guidance). It is imperative that student sponsors are aware of these significant changes so that international student recruitment and compliance processes can be adapted accordingly.
New Basic Compliance Assessment Thresholds
The UKVI Guidance confirms that stricter BCA metrics applies to BCA Applications submitted on or after 1 June 2026 as follows:
- Visa Refusal Rate of less than 5%
- Enrolment Rate of at least 95%
- Course Completion Rate of at least 85%
For all BCA applications applied for on or after 1 June 2027, a student sponsor must meet the following metrics:
- Visa Refusal Rate of less than 5%
- Enrolment Rate of at least 95%
- Course Completion Rate of at least 90%
BCA Outcomes and new Red/Amber/Green Banding System
The UKVI Guidance confirms the introduction of a new Red-Amber-Green (RAG) rating system to track student sponsor compliance against the three BCA metrics. When a student sponsor receives their ‘BCA Outcome Notice’, it will confirm the sponsor’s RAG rating and any associated compliance action as a result. Subject to the Transitional Arrangements outlined below, the RAG rating will also be published on the publicly available register of student sponsors, which will serve to heighten reputational risk for education institutions.
The UKVI Guidance confirms the new RAG system is not an aggregate and the RAG rating “shall be determined by their lowest rated metric which will take precedence over any other metric’s score.” This means that a sponsor can receive a Red rating as a result of their Visa Refusal rate, even if they fall into the Green category for their Enrolment and Course Completion rates.
RED RATING
A sponsor will receive a Red rating if they do not meet one of the BCA core metrics. According to the UKVI Guidance, the consequences of a Red rating will be:
- Red rating will remain on the public register of sponsors until the outcome of their next BCA.
- The sponsor will be placed on a UKVI Action Plan with a minimum duration of 12 months.
- UK Visas and Immigration (UKVI) will reduce the sponsor’s next CAS allocation when compared to their previous year’s CAS usage. There is no upper limit on the CAS allocation reduction but the minimum reduction will be no less than 10% of their previous CAS usage.
- The UKVI may apply restrictions on privileges associated with status of Higher Education Providers with a Track Record of Compliance. This could include restricting a sponsor’s ability to self-assess English Language where there is evidence that students with poor English were being recruited and sponsored or restricting the ability to provide remote delivery if course completion rate is low and courses contain significant remote delivery elements.
- Sponsors will be issued a ‘Final Warning’ in their BCA Outcome Notice. This warning will remain active for the next five BCA’s in which the sponsor must not be rated Red again. If another Red rating is received in any of the sponsor’s next five BCAs, this will be considered a serious breach and licence revocation action will be initiated by the UKVI.
Where licence revocation action is initiated, this has potentially serious consequences for an education institution and its international students including:
- Sponsor may be removed from the public register of student sponsors
- Sponsor will be suspended from assigning new CAS.
- UKVI decision making will be paused on outstanding visa applications for CAS issued by that sponsor
- Licence revocation which results in:
- All sponsored students having their visas curtailed to 60 days during which time they have to leave the UK or find a new student sponsor
- Education institution is banned from the register of student sponsors for up to 2 years.
A sponsor has 20 working days in which to make written representations challenging the UKVI’s intention to revoke notice.
AMBER RATING
A sponsor will receive an Amber rating where they are close to not meeting the core metrics in one or more metrics as follows:
- Refusal rate: ≥4% – < 5%
- Enrolment rate: ≥95% – < 96%
- Completion rate: ≥90% – < 92%
According to the UKVI Guidance, the consequences of an Amber rating are:
- Amber rated sponsors will be required to attend formal engagement meetings as required with the UKVI to review their BCA results and discuss any mitigation action required. Such engagement meetings must be attended by the acting Chief Executive of the institution (e.g. Headteacher/Principal, Vice Chancellor) alongside the Key Contact and Authorising Officer named on the licence, plus heads of international student admissions/visa compliance where these posts are held by additional members of staff. Such a meeting will normally be arranged by the UKVI within 30 calendar days of the BCA Outcome Notice.
- If significant recruitment deficiencies are identified, UKVI may also impose an Action Plan of less than 12 months in duration.
- The UKVI will also not grant more CAS than the sponsor’s previous usage until they are rated Green again.
GREEN RATING
Green rated sponsors meet the requirements across all 3 metrics and do not fall into the Amber category (as set out above). A Green rating is treated as an indication of strong BCA performance and no compliance action will be taken. However, a Green rating does not preclude the same sponsor being found in breach of their general sponsorship duties and facing other UKVI compliance action (e.g. UKVI Compliance Visit)
Challenging a Red or Amber Rating
According to the UKVI Guidance, the BCA Outcome Notice will provide a list of cases that have been considered as counting towards the metric(s) that caused the sponsor’s Red or Amber rating. A student sponsor must submit any challenge to the BCA outcome calculation within 20 working days of receiving the BCA Outcome Notice.
In challenging their Amber or Red rating, the sponsor must be able to demonstrate that the UKVI data relied upon in the BCA Outcome Notice was “materially flawed based on the facts at the time the decision was made”. A sponsor would need to demonstrate that the BCA data has been incorrectly calculated. In practice, this will mean showing that the UKVI’s calculation erroneously included sponsored students in a metric that should have been discounted.
Such a rating challenge may, for instance, highlight:
- A Student’s CAS was successfully withdrawn on the Sponsor Management System (SMS) by the sponsor before a visa refusal decision so should not have been included in the Visa Refusal metric;
- A delayed enrolment SMS report was made and as such, the student should have been positively included in the Enrolment rate metric;
- Students were erroneously included in the Course Completion metric that have left their course and left the UK/ changed UK visa category or temporarily deferred their studies and left the UK.
Administrative Reviews and Visa Refusal Calculations
There appears to be a significant change introduced in the UKVI Guidance regarding how Administrative Reviews affect Visa Refusal rate calculations for BCA purposes with the following paragraph added at 2.17: Students with a live reconsideration of their application, as a result of a successful Administrative Review against the decision to refuse their Student or Child Student application will not be included in the calculation.
The previous version of the Student Sponsor Guidance stated “Students with live administrative reviews against a decision to refuse their Student or Child Student application will not be included.”
The UKVI Guidance explains the policy rationale for this change in how Administrative Reviews affect the Visa Refusal calculation which is to “align the guidance to the existing operational consideration and policy intent of how Administrative Review cases are considered for the purposes of calculating the refusal rate.”
Subject to any further clarification from the UKVI on this unexpected new provision, this change means that student sponsors could only challenge inclusion of a visa refusal in the Visa Refusal Rate metric where the student has (a) successfully applied for an Administrative Review and (b) the reconsideration of their Student Visa is ‘live’ as a result. Under previous versions of the Student Sponsor Guidance, a pending Administrative Review would have been sufficient to state that the visa refusal should not be included in the Visa Refusal calculation for BCA purposes.
Discretionary Assessments
According to the UKVI Guidance, Independent Schools and smaller student sponsors will also be able to rely on a Discretionary Assessment to avoid a Red or Amber rating.
The UKVI Guidance provides that sponsors may be eligible for Discretionary Assessments to pass the BCA where they are not rated Green. Student Sponsors will be eligible for Discretionary Assessments in the following circumstances:
- The sponsor is an independent school and has fallen into a Red or Amber category.
- The sponsor falls into a Red or Amber category for their enrolment rate and fewer than 100 of the sponsor’s Students or Child Students were due to start their course during the 12 month period being assessed.
- The sponsor falls into a Red or Amber category for their Visa Refusal Rate and has used fewer than 100 CAS in the assessment period.
- The sponsor falls into a Red or Amber category for their completion rate and fewer than 100 of the sponsor’s Students or Child Students were due to complete their course during the 12 month period being assessed.
According to the UKVI Guidance, Discretionary Assessments will be conducted on a case by case basis taking into account the individual sponsor’s circumstances. The UKVI will consider any relevant factors, including (but not limited to):
- Reasons why visa applications were refused, students did not enrol or students did not complete their course
- Whether the sponsor is complying with general sponsor duties and their UKVI compliance history
- Whether the sponsor poses any threat to UK immigration control/remains suitable and eligible to hold a Student Sponsor Licence
- How many times a sponsor has failed to meet the core BCA requirements and previously relied on a Discretionary Assessment to retain its student sponsor status
Transitional Arrangements
In recognition of the significant change in sponsor compliance standards and the fact that student sponsors need time to prepare and adapt their sponsorship processes accordingly, the UKVI Guidance sets out important transitional arrangements.
Publication of RAG ratings
The RAG rating will be published on the publicly available register of student sponsors. Under Transitional Arrangements, however, individual RAG ratings will not be published on the sponsor register until every sponsor has received their first rating. At this point, the UKVI Guidance confirms that all sponsors will have their RAG rating results uploaded simultaneously.
Delayed Implementation of new Course Completion Metric
Changes to the course completion rate metric will only come into effect for BCAs made on or after 1 June 2027. This means that the stricter course completion rate metric of 90% will not form part of the sponsor’s RAG rating in their first BCA application made between 1 June 2026 and 31 May 2027. In such a BCA assessment, the legacy course completion rate of 85% will still apply and failure to meet this metric will result in UKVI compliance action as per the legacy BCA policy.
Operational Discretion
In the first BCA that a sponsor applies for after the metrics have been updated, the UKVI will consider whether to exercise ‘operational discretion’ in the event a sponsor falls into a Red or Amber category of a particular metric. According to the UKVI Guidance, factors that the UKVI will take into account when making an overall consideration of whether to apply such operational discretion in the transitional period include (non-exhaustive):
- Sponsor’s previous general immigration compliance history – including outcomes of UKVI Compliance Visits/audits, imposition and adherence to UKVI Action Plans
- The direction BCA results are trending in compared to recent previous assessment results
- Previous BCA performance including:
- Whether the sponsor has previously passed their BCA’s on a Discretionary Assessment and on how many occasions they relied on a Discretionary Assessment to pass
- Whether the sponsor has previously failed any BCA
- Improvements to recruitment practices that have recently been adopted but have yet to impact the data assessed by the BCA. New practices on their own will not automatically lead to discretion being exercised. The UKVI may consider when the practices were introduced and what these demonstrate re the sponsor’s wider recruitment approach
- Whether the metric(s) failed under the new thresholds relied on data from students recruited (i.e. assigned CAS) before the new metrics were announced on 12 May 2025 and that these students’ data was the predominant cause of the sponsor failing to meet one or more of their core requirements.
The UKVI Guidance makes clear, however, that consideration of operational discretion does not mean that the UKVI must give a sponsor discretion in this situation. As such, operational discretion does not preclude a sponsor from still receiving a Red or Amber rating overall in their first BCA assessment against the new metrics.
Action for Student Sponsors
It is imperative that licensed student sponsors now take urgent steps to ensure their international student policies and processes are sufficiently robust to meet these higher BCA metrics and withstand more rigorous UKVI scrutiny.
Student sponsors must assign their limited CAS allocation with caution and with thorough due diligence, introducing checks both before and after a CAS is assigned to protect their BCA metrics. This includes conducting rigorous intention and ability to study assessments on prospective sponsored students as well as carefully vetting and monitoring their Recruitment Agents (and associated commission arrangements) with reference to the higher BCA metrics
We can assist with strengthening your compliance processes or answer any queries about how the new BCA metrics/RAG ratings will affect your education institution and international students. Please contact Anna Blackden in Doyle Clayton’s Immigration team.