Higher Education Today – Autumn 2025

Welcome to the autumn edition of Higher Education Today, looking at current topics and questions facing higher education institutions. 

In each edition we feature content from key members of our Higher Education legal and regulatory team. If you would like further details about these individuals or information about the wider Higher Education team please see our Higher Education brochure. 

We are delighted that in this edition, the presenters from our ‘HE Pensions autumn update webinar’ share their thoughts. This webinar was part of our recent Higher Education autumn webinar series.

We also have an update from the presenter of our ‘Introduction to inquests for the Higher Education sector’ which was part of our spring series.

We also have an update from our immigration team about changes to the Immigration rules which were announced on 14 October 2025.

You can view the rest of our autumn webinar series here:

• Fitness to practise in higher education — Managing complex risks and regulatory responsibilities
• Managing employers’ Liability Stress Claims in Higher Education: From Tribunal to Employer’s Liability Claims 

You can view our previous higher education webinars here. 

We hope you find the newsletter interesting and helpful. 

Ashley Norman

Head of Higher Education

Quick Links Significant Changes for Pensions in the Higher Education Sector Supporting Mental Health in the Higher Education Sector Changes to the Immigration rules – 14 October 2025

 

Significant Changes for Pensions in the Higher Education Sector

What the new Defined Benefit Funding Code means for your organisation

In what was marked as one of the most important changes for pensions schemes in the past decade, now a year on from its introduction, the Defined Benefit Funding Code has been put into practice with many schemes now having completed their first valuations under the new requirements. 

The new code is particularly important for universities who are currently navigating a turbulent environment within their unique pensions landscape, whilst other many other schemes are experiencing a period of surplus. 

This means that the new code presents unique challenges for the sector, particularly as employer covenant assessments have come into much sharper focus under the guidance, with trustees having to reflect on, and tighten their current approach. 

Consequently, universities can expect to see much more robust covenant assessments being undertaken, with self-assessment covenants (where covenant reviews are undertaken internally) becoming a thing of the past. The impetus for greater scrutiny and challenge is likely to present certain challenges for the sector, with the possibility that universities may end up having to pay higher contributions as a result of these more stringent assessments.

That being said, given the relative immaturity of many university schemes with substantial numbers remaining open to accrual, it is possible that any overall increases can be spread over a much longer period. Many of these schemes will not be considering their endgame strategy anytime in the near future, and this presents an opportunity for cooperation between universities and trustees. These schemes can manage their liabilities in a pragmatic manner, balancing the demands of immediate financial pressures and cash flow concerns, whilst also protecting the long-term interests of the scheme and its members. 

This will also be relevant for university accounting practices, as more stringent funding assessments will also have an impact on what appears in their financial reporting. That reporting is likely to be increasingly scrutinised by funding providers as part of any financing or refinancing due diligence process.

Surpluses in the Local Government Pension Scheme – what do I need to be aware of?

At the other end of the spectrum, we are also expecting significant surpluses to be announced in many funds of the Local Government Pension Scheme (LGPS) as part of the latest 2025 valuation. This will certainly not be the case for each and every LGPS fund, and whether or not a fund is in surplus (and the extent of any surplus) will depend on a number of factors, including the actuarial assumptions used and the fund’s overall funding and investment strategy. Universities will therefore need to review the position of their particular fund to understand whether there is likely to be a surplus, and the fund’s approach (if any) to potential surplus extraction.   

Importantly for the higher education sector, surplus extraction is also something that funding providers are becoming increasingly aware of, and many providers are beginning to raise this as a factor when looking at university’s ability to access cash. The likelihood of strong funding levels in the LGPS clearly gives rise to a different set of opportunities for universities, with the prospect of significant contribution rate reductions also being a factor. 

As with surplus extraction, the extent of any contribution rate reductions will be fund-specific. The legal changes being introduced by Local Government Reorganisation and the Pension Schemes Bill 2025 are further factors which LGPS funds and their actuaries will take into account when setting contribution rates. Consequently, we will likely see a varied approach being taken across funds. Universities should therefore be alive to the outcome of the valuation, as it may have a material impact on contribution rates and the prospect of any surplus extraction in the future.

You can watch our webinar OnDemand here.

For more information on this topic, please contact Joel Eytle, Nigel Bolton or Sadie Goodrum who will be happy to help.

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Supporting Mental Health in the Higher Education Sector

This article discusses suicide. If you or someone you know needs support, help is available. You can contact the Samaritans for free at any time on 116 123 or visit Samaritans.org for confidential support. Alternatively PAPYRUS (0800 06841 41) is a voluntary organisation supporting teenagers and young adults who are feeling suicidal.

Our HE spring webinar series earlier this year included an Introduction to inquests for the Higher Education sector which discussed sector guidance for HEIs following a student death, preparing for an inquest and recent issues arising in inquests relating to HEIs. 

Since then, the Department for Education’s National Confidential Inquiry into Suicide and Safety in Mental Health has published its National review of higher education student suicide deaths, the largest national study to conduct a detailed examination of individual factors related to suicide in HEIs.

More recently, the BSI announced that it will be publishing its first suicide awareness and the workplace standard in November 2025. 

Both publications include further recommendations and guidance to reduce the risk of suicide amongst students and staff.

The Review primarily examined serious incident reports of suspected suicide deaths and incidents of non-fatal self-harm submitted by HE providers for the academic year 2023 to 2024 as well as testimony from bereaved families. The Review was informed of 107 suspected suicide deaths and 62 incidents of non-fatal self-harm. Serious incident reports were submitted for 104 of these incidents 

The main aim was to promote learning from these incidents to help prevent future deaths and the Review urges universities to make changes to prevent student suicides in a series of 19 recommendations. 

However, it has also faced criticism, primarily from bereaved families, who have highlighted the limited time-frame considered, the fact that the source material consisted largely of internal reports produced by the organisations themselves and suggest that if fails to tackle underlying issues of accountability. Many bereaved families continue to call for a statutory duty of care in higher education, but this is not one of the recommendations introduced.  

Key findings included:

• Almost half of reports identified mental health difficulties as a potential factor prior to the incident
• Almost a third of reports described a diagnosis, or suspected diagnosis, of neurodiversity
• A third of reports identified evidence of non-attendance
• Academic problems were referred to in over a third of the reports
• 13% of students were reported to have been victims of violence whilst many others experienced adverse life events prior to the incident including social isolation, relationship problems, problems with housing and finance.
• 40% of reports relating to suspected suicide included evidence of postvention support following the death for other students close to the deceased. However there was less evidence of postvention support for staff impacted by the death or for the student’s family.

Learning identified within serious incident reports:

Most serious incident reports identified points of learning to reduce the risk of further incidents, these centred around:

• Access to support, including improving awareness of staff and students, signposting to support and proactively following up students who have missed appointments or not accessed support offered
• Information sharing and communication, both internally and with external agencies. Inadequate methods of communication, such as automated e-mails, were frequently cited
• Risk recognition and management
• Improving systems, including the monitoring of attendance and engagement, record keeping and identifying vulnerable students
• Pastoral support
• Training and guidance for staff
• Confidentiality and access to information about students.

Extent to which serious incident reports followed sector guidance:

The review found that most serious incident reports were broadly in line with the underlying principles of the sector wide guidance for investigation serious incidents, thought not with all parts. The most frequent omission was the involvement of families in the review – in three quarters of the reports reviewed the family were not involved in any aspect of the investigation process. This was echoed by moving accounts from families of feeling excluded from the process of finding out what happened to their loved ones, whilst some had a perception that the university was evasive and avoided difficult questions.

We have previously noted that the target timescales for carrying out a serious incident investigation in the sector wide guidance can act as a barrier to involving families in a meaningful way as they may not be in a position to engage with the process so soon after the death of their loved one. 

Recommendations 

The report makes 19 recommendations centred around safety concerns, suicide prevention within university systems, amendments to the sector wide guidance for investigating serious incidents and safety messages for the wider system.  

Key recommendations include:

• Mental health awareness and suicide prevention training should be available for all staff in student-facing roles, and consideration given to mandatory training for all student-facing staff on identifying, raising and escalating concerns about a student.
• Students who are struggling academically should be recognised at potentially at risk
• Awareness of support at key points in the academic calendar should be increased
• Access to mental health and other support should be reviewed, particularly for those at additional risk
• Input from bereaved families should be a key part of the serious incident investigation process and their questions should be included I the scope and answered as far as possible
• Recommendations around the appropriate level of independence of the investigator, and granting the review process sufficient status within the organisation
• A duty of candour should be introduced to the HE sector, setting out organisation responsibilities to be open and transparent with families after a suspected suicide.

It will be important for HEIs to consider how to embed the full series of recommendations into institutional culture effectively and efficiently. 

BS 30480 Suicide and the workplace – Intervention, prevention and support for people affected by suicide - Guide

BS 30480 is the UK’s first standard dedicated to suicide awareness and education. It will provide a guidance standard to help organisations address suicide prevention, intervention, and postvention in the workplace. Though designed for a wide range of sectors, its principles are highly relevant to universities, which face growing concerns around staff and student mental health. The standard emphasises a proactive, compassionate, and structured approach to reducing suicide risk in institutional settings.

At its core, BS 30480 encourages organisations to embed suicide prevention into their culture through clear policies, leadership commitment, training, and open conversations. Prevention efforts focus on raising awareness, tackling stigma, and equipping staff to recognise and respond to warning signs. Universities are urged to integrate suicide prevention across academic departments, student services, HR, and residential life, ensuring that both staff and students can access appropriate support.

The standard also outlines how institutions should intervene when someone may be at risk—emphasising safe, non-judgemental communication and clear referral pathways. In the aftermath of a suicide or attempt, BS 30480 highlights the importance of sensitive postvention strategies, including grief support, effective communication, and policy review. Universities, as complex and high-pressure environments, must ensure that these processes are consistent, well-resourced, and inclusive of all community members.

Ultimately, BS 30480 provides a framework for universities to evaluate their current practices, strengthen mental health and wellbeing structures, and foster environments where suicide can be more openly discussed and more effectively prevented. You can register your interest here. 

For more information on this topic and related issues, please contact Claire Leonard, who will be happy to help. 

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Changes to the Immigration rules – 14 October 2025

The Home Office laid a new Statement of changes to the immigration rules on 14 October 2025 that will impact higher education sponsors. Changes include raising the maintenance threshold for Students, shortening the permission granted under the Graduate visa route and tightening English language standards for economic migration routes.

Implementation of these changes is being staggered over the next 15 months, so the admissions, HR and career teams need to be prepared to adjust communications and internal processes. 

Summary of the key changes: 

1. Graduate route shortened to 18 months (PhD unchanged)

The period of permission granted under the Graduate route will be reduced from current two years to 18 months for applications made on or after 1 January 2027. PhD or doctoral graduates will however continue to receive three years permission.

This change is intended to encourage progression into graduate-level roles. Employers relying on the Graduate route as a bridge to Skilled Worker permission will need to adjust workforce planning and check that switching to sponsorship remains viable.  

2. Maintenance uplift to Student route and limited self-employment flexibility when switching to Innovator founder 

1. Maintenance (financial requirement): The financial requirement for the student immigration route will be increased from 11 November 2025 requiring students to show higher monthly living costs when submitting their applications.
   
   The monthly costs for ‘Students studying in London’ will increase from £1,483 to £1,529 per month and those ‘studying outside London’ will increase from £1,136 to £1,171 per month. The maximum amount that can be deducted for accommodation payments has also been increased to £1,529.
   
   Education Providers issuing CAS are urged to update internal guidance documents and policies to ensure that incoming students are briefed in advance about this new requirement to reduce risk of visa refusal.

2. Switching to innovator founder route: A specific change is being introduced to allow Students to be self-employed once an Innovator Founder application (with endorsement) is submitted during their student permission (and while it is pending). This flexibility takes effect on 25 November 2025.
   
   This is a narrow concession, and it does not permit self-employment before the Innovator founder application is submitted. All other student work restrictions continue to apply. These timelines are of particular significance to Higher Education providers supporting spinouts and incubators.

3. Other practical considerations for education providers 

1. English language threshold raised from B1 to B2 level for economic migration routes (for first-time grants)
   The English language requirement for the Skilled Worker and other economic migration routes such as Scale-up and High Potential Individual (HPI) routes will increase from the current CEFR B1 to B2 for initial applications submitted on or after 8 January 2026. 
   Transitional protection applies and where applicants are extending on the same route and who were granted permission subject to B1 level, will continue to be assessed at the same level. 
   Employers should factor this into the recruitment timeline and advise recruiters and/or new hires about the higher English language threshold in preparation for next year.
    
2. High Potential Individual (HPI) – expansion and cap
   Two significant changes have been announced to the HPI route. First, the Home Office will double the current list of eligible institutions (‘the Global Universities List’), with discretion to exclude institutions where appropriate (e.g. national security). Secondly, an annual cap of 8,000 applications will be introduced. 
   Most HPI changes take effect from 4 November 2025 with the B2 level English language change for HPI aligning with the 8 January 2026 implementation noted above.
    
3. Increase to Immigration Skills charge: 
   Although not included in the Statement of Changes, the government has indicated in a separate press release that the parliamentary process to increase the immigration skills charge (ISC) will begin this week. The ISC is payable by sponsoring employers for each year of a sponsored worker’s permission. The current rate, set at £1,000 per year since 2017, is set to rise by 32% to £1,320 per year (for small sponsors, its set to increase from £364 to £480). No commencement date has been announced but implementation is expected by end of this year.

The practical effects of the new set of changes for the Higher Education sector are primarily operational. It demonstrates the need for more robust pre-CAS checks on students’ ability to meet the higher maintenance threshold, updating internal guidance and processes, and effective communication of the changes to all relevant staff, agents and international students.

• Maintenance funds: Higher Education providers should update their guidance and communications to reflect the new maintenance thresholds to minimise risk of any visa refusal.
   
• Graduate route: Communicate the reduction in the length of Graduate route to prospective and current students, as it may influence their study decision and impact post-study plans. If your university has relied on the two-year Graduate period to assess graduates for sponsorship, you need to now plan for an 18-month period starting from 1 January 2027 and ensure that sponsorship remains viable for the affected cohort.
   
• English language for Skilled workers: It is recommended, Higher Education providers review their pre-screening requirements to ensure that any new hires/candidates can evidence B2 level across all four components (reading, writing, listening and speaking). Additionally, you must consider whether existing offers (issued on the assumption of B1 level) to candidates can submit their applications before the rule changes on 8 January 2026. 

For further information or assistance to navigate these upcoming changes to the Immigration Rules, please contact our Employment, Pensions & Immigration team

Say hello to us

Our Higher Education team is attending and speaking at a number of in-person and online events over the next few months, please follow the link for details. If you are also at these events, please come and say hello to us.

• UHR Wise Wednesdays – Condition E6 – 5 November (online)
• Independent Higher Education - Students Complaints and Appeals session – 13 Nov (online)
• Independent Higher Education Annual Conference – 26 November (London)