Fourteen years ago, when I moved from specialist immigration law into higher education, it was clear that the majority of universities neither understood nor valued the role that UKVI compliance plays in institutional health. In 2013, compliance teams were often no more than two people strong, and too often populated by those who had ‘fallen into’ the role rather than being intentionally recruited for it.
I learned early on that risk cannot be mitigated by policies alone, as many institutions barely had codified processes and policies, the lifeblood of my military and legal training. The only effective way to manage risk is to ensure that everyone understands it and how it affects students, staff, reputation, and institutional viability.
Over time, I deliberately moved the physical location of UKVI compliance within my institution through governance, registry, and international functions, integrating admissions, CAS issuance, and international student support into a single, coherent structure. In effect, I built immigration law firm capabilities within a university, without the fees, but with the same rigour.
The outcome speaks for itself, with 680% growth over a decade and no UKVI breaches, and not because we were risk averse. We understood our operational limits, aligned strategy with capability, and embedded compliance where recruitment decisions were actually being made. I forced connections and opened up the context of why compliance sits in the hub of the student journey. I built my team from amazing individuals who had superb soft skills; listeners with applied empathy and emotional intelligence as well as business acumen.
Failure to align recruitment and compliance is where the sector has been failing. It is one way the government finds it all too easy to create negative immigration policies, which in turn see too many HEIs inadvertently damaging their own recruitment pipelines.
Too many institutions still do not understand the relationship between strategy and operational reality. Growth targets are set without a genuine understanding of capacity, agent quality, admissions robustness, or compliance workload. When those targets are missed, the response is rarely reflection, it is blame, direct or tacit.
Growth targets are set without a genuine understanding of capacity, agent quality, admissions robustness, or compliance workload. When those targets are missed, the response is rarely reflection, it is blame, direct or tacit
Too many institutions still behave as though BCA compliance is owned by a small technical team rather than by the sponsor itself. Accountability for BCA metrics is routinely displaced downward, while strategic decisions that directly shape those outcomes, recruitment targets, agent appointments, market expansion, and admissions tolerances, are made elsewhere.
All too often, lip service is paid to the tension between growing recruitment and higher standards of compliance, effectively the message is, do both. When metrics fail, universities blame execution rather than governance. When Basic Compliance Assessment (BCA) thresholds are breached, UKVI does not sanction departments, it sanctions institutions. That distinction is critical and often conveniently ignored. This is not a compliance failure; it is a leadership failure.
We are now seeing the consequences across the sector, with 40% of institutions in financial deficit: financial instability, restructures, redundancies, and toxic working environments. Recruitment teams are witch-hunted for failing to hit unrealistic targets, too often increased mid-cycle, while simultaneously being constrained by risk-averse compliance functions that have been pushed into siloed, defensive positions.
This dynamic is corrosive. Recruitment becomes subservient to compliance. Compliance becomes detached from strategy and leadership sits uncomfortably in the middle, reacting rather than governing. What makes this particularly damaging is that compliance is often blamed for slowing growth, when in reality the failure lies in the absence of joined-up strategic thinking. Compliance teams retreat into risk registers and audit preparation not because they want to, but because they are excluded from early-stage planning, agent strategy, and pipeline management.
Equally problematic, is the persistent resistance to compliance-led engagement with agent networks. There can be institutional resistance to compliance experts engaging directly with agents, yet if undertaken appropriately there should be real upsides from this, in terms of influencing the quality of what enters the top end of the funnel, in turn minimising the pains of downstream compliance
Today, more than ever, compliance and recruitment must function as a single ecosystem. Risk should not be avoided; it should be understood, contextualised, and managed. Compliance teams must be fully integrated across the student journey – from market strategy and agent training to admissions, enrolment, and progression.
What I am increasingly seeing instead, is paranoia replacing professionalism. Risk registers are becoming instruments of fear rather than tools for informed decision-making. Institutions are becoming risk-averse rather than risk-intelligent and it now seems that the latest international education strategy provides a hypothetical route for many sponsors to cease international student movement inbound to the UK.
The continued primacy of recruitment, regardless of Home Office preference, will continue to place agent relationships front and centre. Too often they are mere transactional partners, creating significant cultural chasms within vital relationships. BCA outcomes are not compliance metrics, they are the lagging indicators of strategic decisions made months or years earlier.
BCA outcomes are not compliance metrics, they are the lagging indicators of strategic decisions made months or years earlier
The sector must confront a hard truth: if universities do not understand their own strategies and operational limits, they will continue to fail in this space and they will continue to sacrifice staff, culture, and long-term stability in the process. With 65% of student recruitment being supported by the agent network, and much higher figures for many, we must invest more collaborative energy and effort in to supporting our well trained and ethical agent businesses, as they are too valuable to lose.
I have witnessed some exemplary cases of collaboration, connection and success over the years, but with an exodus of experience we need to reform. The Agents and Educators Global Alliance (AEGA) I am championing will help bridge the gap between agent and sponsor, bringing them together with a collaborative point of support, representation and excellence.
Compliance is not the problem. That lies with misaligned strategy, poor operational insight and leadership unwilling to own risk. Until we accept that what and how we recruit into our institutions, shapes everything that follows, we will continue to repeat the same mistakes — only now, with far higher stakes, including course closures, huge declines in income and forced exiting from specific countries.
The consequences of not acting are legion, from the parochial but important institutional financial sustainability, to the philosophical principle that fewer young people studying overseas will make the world a poorer place.
Pete Yetton is the founder of the Remarkable (Law) Consultancy and the Agents and Educators Global Alliance (AEGA). He will be speaking about the new BCA metrics, admissions and compliance operations and agent regulation at The PIE Live Europe 2026, 24-25 March, London. See agenda and ticket details here.
