International Education Strategy – the impact on independent schools

Kris Robbetts, partner at VWV, looks at the impact of the International Education Strategy on independent schools and their key stakeholders

The Department for Education (DfE) and Department for International Trade (DIT) have launched a new International Education Strategy (IES) outlining plans to increase student numbers and income generated from international education. Building on the broader Export Strategy published in August 2018, the IES aims to consolidate the strengths in the UK’s education offering whilst addressing the challenges believed to prevent it from reaching its full potential, including, of course, Brexit.

Across 23 action points, the IES sets out an ambitious vision impacting on the full spectrum of education sub-sectors from early years through to higher education and aiming to increase the annual value of education exports to £35bn by 2030 (in 2016, it was £20bn). At the same time, it is expected that new National Minimum Standards (NMS) for boarding will be issued in 2019, creating a regulatory requirement for schools to have adequate education guardianship arrangements in place and making them subject to regular inspection.

The IES places international education firmly back in the spotlight and suggests there is likely to be renewed interest and increased scrutiny on the arrangements made for international students in the UK. We look at the impact this is likely to have on key stakeholders and, in particular, on the interplay between independent schools registered as Tier 4 sponsors and guardianship organisations. 

What will this mean for schools?

Our schools, which are singled out in the IES for providing international benchmarks for safeguarding and choice, constitute an important aspect of the UK’s international education profile. 

ISC research reported that in 2017 international schools educated around 4.5 million students around the world, a figure projected to double within the next decade, with the popularity of UK curricula delivered in English remaining strong. In 2018, UK independent schools opened more overseas branches than during the previous 20 years and demand for UK schools abroad continues to grow. 

The IES seeks to support the ambition and growth of the sector through a variety of measures, including the DIT encouraging independent schools to access international opportunities through the use and provision of exports data, connecting providers with investors and working with key sector bodies to produce information guides for schools interested in developing an international presence. 

Perhaps even more significantly, IES Action 13 states that the DfE and DIT will coordinate efforts across government and key sector bodies to encourage independent schools to have a better understanding of guardianship arrangements and the role of accreditation bodies. 

Best learning will be gathered from schools who already do this well. Current thinking is that this will result in new NMS in 2019, which will place greater obligations on schools to be proactive in ensuring that guardianship arrangements are acceptable.

For those who have been lobbying for the regulation of educational guardianship, these developments represent the culmination of years of work and one of the most welcome changes in the sector for some time. 

It was concern about the lack of any formal regulation of educational guardianship and the consequent risks this creates for international students at school in the UK that led, back in 1994, a small group of guardianship organisations and independent schools to create the first accreditation body for guardianship – the Association for the Education and Guardianship of International Students (AEGIS).  

A registered charity, AEGIS now counts 44 guardianship organisations and 72 independent schools as members. Affiliated with the Boarding Schools’ Association since 2018, AEGIS continues to operate its own accreditation framework and accreditation process and to promote best practice in the sector through conferences and training courses. Despite this, the number of international students who received educational guardianship services from an AEGIS-accredited provider remains low. 

In 2018, there were just over 28,500 non-British students with parents residing overseas. Of those students, only around 5,000 (17.5%) of them had an AEGIS-accredited educational guardian. It is these statistics that help explain why the IES and new NMS are welcome news to anyone concerned by the potential vulnerability of international students and the legal and regulatory risks being taken by so many schools.

New NMS for boarding   

Whilst it is difficult to know exactly what the new NMS will look like, it is easy to identify issues that they will hopefully address.

One is the current lack of any requirement for international students to be provided with independent educational guardianship. 

This is already a condition of AEGIS accreditation and regarded as best practice in order to ensure that students have an educational guardian able to act as their unconflicted advocate, but it is not widespread. As a result, it is still common for schools to allow, or even encourage, members of their own staff to act as educational guardians (and also homestay provider) for students, blurring the important distinction between ‘home’ and ‘school’ and potentially making it impossible for them to feel supported or even able to complain. 

Another is clarity on the number of children who are permitted to reside in a homestay at any given time. If experiencing authentic family life within the UK is among the key purposes of a successful homestay arrangement, it makes sense that the number of international students within any one setting be limited. 

Historically, that limit has been set informally at three, probably because the Children Act 1989 imposes a cap on how many children may be privately fostered in one household (known as the ‘usual fostering limit’) at that number such that hosting more may require registration as a children’s home. Despite this, there is a reported tendency for unaccredited educational guardians to place as many students as possible in each homestay and for some schools to be disinterested in, or even entirely unaware of, whether or not this is the case.

UK international schools currently educate around 4.5 million students around the world, a figure projected to double within the next decade

From a general welfare perspective this sort of practice is troubling, but it may also be a compliance breach where the school in question is a Tier 4 sponsor and therefore subject to specific Home Office obligations. It is a Tier 4 requirement that any student living in a homestay as part of a private fostering arrangement (i.e. one for 28 consecutive days or more) is not residing in accommodation ‘being operated as a commercial enterprise like a hotel or youth hostel’. 

Even if it is accepted as unlikely that any sponsored student would do that in practice, it should not be forgotten that sponsoring schools’ welfare responsibilities continue throughout the time students remain in the UK, whether or not it is term-time and the students are actually in their care.

With this in mind, now may be the opportune moment for guardianship organisations and schools alike to consider reviewing their practices. Guardianship organisations might investigate accreditation with AEGIS and schools may wish to do the same and/or consider validation by QegUK. Founded in 2016, QegUK differs from, and arguably complements, AEGIS by focusing on improving the practices of education providers (school, colleges, universities). 

It offers a kite mark to member organisations covering the regulatory aspects of good international student provision but also covers pastoral issues such as how well students are enabled to integrate into their learning community.  

At a time when Brexit is creating exceptional uncertainty, it is critical that the UK education system and its international offering is as prepared as it can be for life beyond EU membership. The IES provides clear reasons for optimism without forgetting to acknowledge the need to improve the way that international students are supported during their studies here. 

Hopefully, our regulatory system will now address deficiencies regarding educational guardianship long recognised by self-created accreditation and validation organisations. Ideally it will do so without undermining what makes the UK such an attractive place to live and learn.

Kris Robbetts is a partner at leading education firm VWV. Kris can be contacted by calling 0117 314 5427 or emailing

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