The UK government’s proposed international student levy is intended to be a simple mechanism: a flat £925 charge per international student per year, paid by English higher education providers and reinvested into the higher education and skills system. In principle, the policy objective is clear and defensible.
However, as the technical consultation currently stands, there is a significant unintended consequence that risks undermining international student exchange, outward mobility for UK students, and already fragile subjects such as modern languages. Unless this is addressed now, the levy could inadvertently make reciprocal exchange financially unsustainable for many universities.
Why exchange students matter and why they are different
Incoming exchange and study-abroad students are not the same as full-degree international students:
- they are typically fee-neutral, with tuition waived under reciprocal agreements
- they are credit-bearing but not registered for a UK award
- they are essential to maintaining balanced two-way mobility, which in turn enables UK students to study abroad
- they underpin disciplines such as languages and area studies, where a year or semester abroad is integral to the curriculum
In many cases, hosting an incoming exchange student already represents a net cost to the institution, absorbed in recognition of the wider academic and strategic benefits.
Where the levy design creates a problem
The technical consultation defines international students broadly and excludes only those on a short-term study visa, a route that is used almost exclusively for non-credit English language courses, whereas exchange and study-abroad students enter the UK on either a student visa (for full-year exchange), or a standard visitor visa or ETA (for one-semester study that is still credit-bearing).
The result is stark: a university could be required to pay £925 to host an incoming exchange student who pays no tuition fees
As drafted, this means that most incoming exchange students are likely to be counted for levy purposes, despite generating no additional tuition fee income. The result is stark: a university could be required to pay £925 to host an incoming exchange student who pays no tuition fees.
The knock-on effect on outward mobility and languages
Exchange is a two-way system. If hosting incoming students becomes a cash cost, universities will face difficult choices:
- capping or reducing inbound exchange numbers
- rebalancing or withdrawing from reciprocal partnerships
- limiting outward mobility opportunities for their own students
These pressures will be felt first, and hardest, in languages, where outward mobility is central to academic integrity and already under strain across the UK.
The risk is that a levy designed to support opportunity and access ends up shrinking access to study abroad, particularly for students in less well-resourced disciplines or from less advantaged backgrounds, which would run counter to wider government ambitions around global engagement, skills, and social mobility.
Almost certainly unintended and eminently fixable
There is no indication in the consultation documents or impact analysis that these consequences have been explicitly considered. The levy has been modelled as a headcount-based charge, optimised for fee-paying diploma mobility, not for fee-neutral credit mobility.
The good news is that this is eminently fixable without undermining the core policy objective. Options could include:
- excluding students registered for credit only and not a UK award
- excluding reciprocal exchange students where no additional UK tuition fee is charged
- excluding students studying less than a full academic year, unless enrolled on a full degree
Any of these would protect exchange and outward mobility while preserving the integrity of the levy.
A call to action for universities
The consultation on the international student levy is open until February 18 2026. This is the moment for universities to respond.
Institutions with: language provision, exchange-reliant programmes, and or strong commitments to outward mobility, should make their voices heard, clearly and constructively, highlighting this risk as an unintended consequence, not an argument against the levy itself.
If the sector does not raise this now, the danger is that a technically simple policy quietly erodes one of the most valuable, and vulnerable, parts of the UK’s international education ecosystem.
Respond to the UK government’s proposed international student levy here.
Vincenzo Raimo will be speaking about the potential impact of the international student levy at The PIE Live Europe in London on March 25. Book your ticket here.
