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Office for Students (OfS) Access and participation data and consultation findings

The access and participation data release provides key findings in access, continuation, completion, degree outcomes and progression at a sector level, focusing on the gaps between full-time undergraduate UK-domiciled student groups. For the first time, it provides figures on completion rates by combinations of student characteristics. Alongside this data, the OfS has published its new Equality of Opportunity Risk Register (EORR) which attempts to provide a framework against which institutions can identify which risks might apply to them, which students are most at risk and take measure to mitigate these risks. It has also released details of the EORR consultation findings and the OfS responses to these, and a commentary by John Blake, the OfS Director for Fair Access and Participation.

Findings from the access and participation data dashboard can be found here

The commentary from John Blake can be found here

The Equality of Opportunity Risk Register can be found here

The OfS analysis and response to its consultation on a new approach to regulating equality of opportunity in English higher education can be found here


  • Students from disadvantaged backgrounds and those otherwise underrepresented in higher education are less likely to complete their course. 81.6 per cent of students from the most deprived backgrounds (IMD) completed their course, compared to 92.2 per cent from the most advantaged group. 80.7 per cent of black students completed their course, compared to 88.5 per cent of white students  (data dashboard p16)
  • Full-time degree outcome indicators showed a 17.8 percentage point gap between students from the most deprived areas gaining a 1st or a 2:1 compared to the least deprived areas. This gap reduced from 2016-17 to 2020-21 but increased in the most recent year, up from 15.4 percentage points in 2020-21. The ethnicity awarding gap follows a similar pattern. The gap for White and Black students stands at 20 percentage points (data dashboard p27, p28)
  • For entry into professional or managerial employment, further study, or other positive outcomes, full-time students who were eligible for free school meals had a progression indicator which was 6.7 percentage points lower than qualifiers who were not eligible. This gap has closed slightly since 2017-18, when it was 7.8 percentage points (data dashboard p29)
  • The new Equality of Opportunity Risk Register (EORR) presents a list of 12 potential risks to access, course success and progression. The OfS expects institutions to use the EORR to identify prospective or current students likely to be affected by the risks, which groups may be most at risk and how the provider can contribute to reducing the identified risks (EORR p9)
  • Risks to access include unequal access to knowledge and skills and guidance and information about HE, and not feeling able to apply to certain types of courses or institutions (p9)
  • “On course” risks include a lack of academic and personal support, mental health risks and cost of living risks (EORR p9)
  • The EORR identifies 18 groups of students, based on personal characteristics, who may be most affected by risks. It also provide school-based and area-based indicators that may interact with personal characteristics to create or exacerbate risks (EORR p5)
  • John Blake reiterates the “need for universities and colleges to work much more closely with schools to drive attainment raising work”. On continuation and progression, he says:  “The brutal reality is that – on a minority of courses – students enter higher education and receive no discernible benefit”(commentary)
  • In the consultation responses, institutions raised questions over whether HE was best placed and had the knowledge, expertise and capacity to raise school attainment.  They also asked for further clarification on the types of activities that would be suitable for raising attainment in schools and how these should be evaluated (consultation response p49)
  • The OfS has altered the wording on its expectation that providers work to raise attainment at pre-16 through partnerships with schools. It will revise the regulatory notice to clarify that providers should “support” the work of schools in raising attainment, rather than have a singular responsibility to raise attainment (consultation response p49)
  • Providers “where possible” are encouraged to set numerical targets to provide effective indicators on whether they are making positive progress in addressing risks to equality of opportunity (consultation response p32)
  • Providers will continue to report on overall access expenditure. They will also have to submit an estimate of costs for each intervention strategy to enable the OfS to assess the credibility of the proposed interventions (consultation response p44)

Implications for governance:

The first thing to note is that the timetable for implementation of the new approach outlined by John Blake and covered in the various OfS documents has been extended. The majority of institutions in England will now be expected to submit a new access and participation plan in spring 2024, although a “first wave” of universities and colleges will be encouraged to submit plans this summer. Universities that sign up to be “pioneers” will receive tailored support as they draw up their plans.

Whatever the time frame, new plans should be focused on ‘risks to equality of opportunity’ and have regard to the EORR when identifying these.

Governing bodies will therefore have more time to explore the implications of the EORR and what the access and participation data is showing. They will need to consider if the necessary measures are in place to ensure new APPs fulfil these regulatory requirements, as well as any cost, time and resource implications.

When outlining the various risks, the EORR makes the point that a providers’ location, entrance tariff and whether it recruits nationally or locally, will have a potential impact. This provides an opportunity for providers to examine their own data to establish how a risk might affect their current or potential student population.

While this is important contextual data to include in APPs, John Blake’s commentary makes clear that that context cannot be used to explain away student outcomes. He describes as “wrong-headed” the argument that “we should be cautious about implementing expectations for student outcomes because institutions with weaker outcomes often have high proportions of disadvantaged students”. Instead, he refers to courses “letting them [students] down”, making it clear that the new access and participation approach “needs to go in lock-step” with new measures on quality assurance, such as numerical thresholds for continuation, completion and graduate outcomes.

Many of the student characteristics that make some groups more at risk – as evidenced by the access and participation data dashboard - will be very familiar to widening participation and outreach teams. Many of the 12 potential risks are well known too, and universities may already have measures in place to try to address them, such as targeted academic support for certain groups and increased investment for student mental wellbeing. Others, such as “cost pressures”, might currently be less of a focus or less likely to be referred to explicitly in APPs.

Outreach and partnerships with schools also form a significant element in the widening participation efforts at the vast majority of registered providers. Indeed this fact is stated in the consultation response document and employed by the OfS as a counter against respondents who argue that providers might not have the capacity and capability to work with schools to raise attainment.

Respondents have asked for clarification about what these interventions should look like and how their effectiveness should be measured. Some also highlighted the increased burden of reporting financial investments in access and intervention plans.

In response to these concerns, the OfS will shortly publish “Regulatory advice 6”. This will provide further guidance and advice about how providers can meet the OfS expectations and make most effective use of the EORR in informing access and participation plans. It will cover, among other things, the range of appropriate attainment-raising interventions that provider might consider, the development of partnerships with schools, evaluations, reporting investments and expenditure and setting targets, including collaborative targets.

Regulatory advice 6 is referenced 50 times in the consultation response report and promises to provide vital detail on a range of queries, so this is clearly a document that governors will want to watch out for.

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