Consultation on the Independent Schools Inspectorate’s Student Educational Oversight Framework for Private Further Education Providers (including English language schools)

1. Introduction

ISI is appointed by the Home Office as a designated educational oversight body for private further education ('PFE') providers, including language schools.

This consultation seeks views on ISI’s proposed Student Educational Oversight Inspection Framework ('the proposed inspection framework') and the inspection methodology applied to colleges that hold or are applying for a student sponsor licence. If implemented, the proposed inspection framework would be effective from September 2026.

Purpose of consultation

• To gather feedback on the scope, principles and process of inspection, and on reporting, quality assurance, and complaints arrangements.
• To test whether the proposed inspection framework provides fair, proportionate and reliable assurance of educational quality and safeguarding.

2. Background

• International students study in the UK under the UK Government's student sponsorship regime. Education providers who wish to offer places to international students must hold a student sponsor licence (Home Office/UKVI).
• Sponsorship rests on two principles:
  • Sponsorship is a privilege, not a right. Providers must help prevent abuse of the immigration system.
  • Students must be eligible and must study with a reputable provider who genuinely wishes to teach them.
• A sponsor must be a genuine, lawful education provider with acceptable educational quality standards, must be eligible and suitable to hold a licence, and must be capable of meeting sponsor duties.
• Educational oversight is required and maintained for all sites throughout the sponsor licence. ISI evaluates and reports to the Home Office whether all sites meet the requirements set out by the Home Office for education oversight.
• Providers applying to the Home Office for a student sponsor licence and seeking an ISI educational oversight inspection must have been continuously teaching UK students on courses that meet student requirements for two years prior to application.

3. Summary of the proposed inspection framework

3.1 Proposals relating to the scope of inspections and inspection evaluations

• ISI will inspect colleges that hold a student sponsor licence, or who intend to apply for one within six months of the planned inspection date.
• Inspections will evaluate:
  • Whether students receive a standard of education and care that meets Home Office requirements for educational oversight.
  • Whether safeguarding for students under 18 and/or vulnerable adults is in line with safeguarding guidance, including Keeping children safe in education and Working together to safeguard children.
• For each section of the inspection framework, inspectors will evaluate whether: ‘All requirements are met’ or ‘requirements are not met.’

3.2 Proposals relating to the principles of inspection methodology

ISI has four principles which underline our inspection methodology. Inspectors will adhere to the principles when conducting inspections of colleges. These are explained below:

• Manageability: Inspectors align inspection with day-to-day operations of colleges, avoiding unnecessary workload for college staff and for inspectors.
• Collaboration: Inspectors work alongside leaders and staff where appropriate. The lead inspector will offer some opportunities for college leaders to join inspection activities, for example, some observations of teaching and learning. Inspectors discuss the evidence and share emerging findings with college leaders throughout the inspection.
• Triangulation and Typicality: Inspectors consider multiple sources of connected evidence and consider what is typical over time in order to reach valid evaluations and judgements about whether the requirements are met or not met.
• Proportionality: Inspectors will take a proportionate approach to minor errors that are easily rectified before the end of the inspection. However, systemic issues may indicate that requirements are not met.

3.3 Proposed inspection framework sections

It is proposed that the inspection framework and the inspection report will have four sections. Each section will cover the related requirements. Inspectors will report in each section the extent to which relevant requirements are met.

Section One: Leadership and Management

As part of the inspection process, inspectors will evaluate: financial sustainability; the effectiveness of leadership and governance; recruitment to appropriate courses; and effective quality assurance that uses self-evaluation and considers students' views.

Section Two: Quality of Education

Inspectors will evaluate: the validity of courses; approved qualifications for UKVI purposes; the planned curriculum; teaching that enables progress for students; the effectiveness of assessment and feedback for students; support for students who speak English as an additional language and for students who have special educational needs and/or disabilities; suitable resources for effective teaching; promotion of respect for fundamental British values; and Equality Act 2010 compliance.

Section Three: Students’ Wellbeing

Inspectors will evaluate: safer recruitment processes, including pre-appointment safeguarding checks, for teaching staff; suitable premises; suitable arrangements for health and safety; risk assessment, fire safety, first aid, and evacuation/lockdown; and suitable arrangements for accommodation, including private fostering arrangements. The safeguarding arrangements for students under the age of 18 must adhere to any guidance issued by the Secretary of State for pupils under 18 and for vulnerable students in educational settings.

Section Four: Advice and Guidance

Inspectors will evaluate: the usefulness and accuracy of pre-enrolment information; induction arrangements; the complaints policy for students; and advice offered to students on progression and/or careers.

3.4 Proposals for reporting

• Inspection reports set out whether each requirement is met or not met.
• The summary section provides an evaluative overview of each section of the framework, and states whether requirements are met or not met.
• Reports will include areas for action where requirements are not met; and for every inspection recommended next steps will identified.

 3.5 Proposals for the inspection frequency 

• ISI proposes that there will be one type of inspection which will follow the same format.
• To fulfil Home Office requirements, and to check that education quality standards are maintained, ISI will conduct a routine student educational oversight inspection typically once every two years.
• Where requirements are not met at the inspection, colleges will have a follow-up inspection, within six months, to evaluate progress and to determine whether the requirements are now met or not met.
• ISI may bring forward inspections if there are complaints or serious concerns about a college.
  

3.6 Material changes that trigger an inspection

• College leaders must notify ISI within 28 days of a material change of its circumstances as laid out in Student Sponsor Guidance Document 2: Sponsorship duties.
• Changes to financial or governance circumstances must also be notified. ISI may request additional checks in these circumstances.
• ISI will bring forward inspections within the routine two-year cycle, where necessary, if a material change triggers an inspection. The next routine inspection will then take place approximately two years from the date of the previous inspection.
  

 3.7 Proposals for the duration of the inspection

• A typical inspection will last three days.
• The first day of the inspection will be held remotely and will include meetings with the lead inspector and college leaders and staff.
• The second day of the inspection will be for inspectors to review and consider the information provided on the first day of the inspection and to plan the on-site day.
• The remaining day will be on site when inspectors will talk to students and gather first-hand evidence of teaching and learning and of the suitability of premises and health and safety arrangements.
• The length of the inspection may be extended by one additional on-site day for large multi-site colleges and/or colleges with residential provision. ISI will discuss with college leaders the length of the inspection and the number of inspectors required for each inspection.
• Inspections will be led by a lead inspector, with at least one team inspector.

3.8 Proposals for the process of the inspection 

• ISI will notify college leaders three weeks ahead of the inspection.
• Pre-inspection planning calls will take place (three weeks and one week ahead of the inspection).
• The college will be required to distribute pre-inspection surveys for students and staff.
• Day one of the inspection will be held remotely. It will include: meetings with college leaders and staff; review of policies; evidence of self-evaluation and improvement plans; and evaluation of course offer and curriculum plans.
• During the second day of the inspection, the lead inspector will review the information provided on day one of the inspection and plan the on-site element of the inspection.
• During on-site days (day three plus an additional day where necessary), inspectors will gather first-hand evidence of curriculum implementation, will have discussions with students, leaders, proprietors and/or governors, and will visit premises (including of any residential provision).
• There will be regular keeping-in-touch meetings throughout the inspection, and provisional feedback on the final day of the inspection.

Conduct and College Guidance

• Inspectors follow a code of conduct. 
  They will:
  • act in the best interests of the students at the inspected college and always prioritise the safeguarding and welfare of students
  • uphold ISI’s values at all times and evaluate objectively in line with ISI’s frameworks and regulatory requirements
  • refrain, at all times, from any behaviour which might bring ISI into disrepute
  • use their ISI inspector designation only in relation to their inspection work for ISI, unless previously agreed with ISI senior staff
  • maintain up-to-date knowledge of ISI’s inspection frameworks, handbook, policies, and practice and associated requirements and guidance
  • maintain strict confidentiality about the identity of the college to be inspected, the timing and scheduling of inspections and not divulge any information about the inspection (including but not limited to the region, the type of college or any identifying features) other than the fact they are going to be deployed at that time
  • declare all actual and perceived conflicts of interest and have no real or perceived connection with the inspected college prior to or following inspection, which could undermine the integrity of the inspection
  • act promptly and in line with ISI guidance on any safeguarding or health and safety issues that may arise on inspection
  • work with professionalism, sensitivity, and integrity, treating all with respect and courtesy
  • liaise immediately with senior staff at ISI if inspectors become aware that college staff are experiencing exceptional stress
  • follow requirements and good practice in relation to the secure management of information
  • be mindful of the additional workload that inspection can create, be sensitive to the needs of college staff and take reasonable steps to prevent undue anxiety and stress
  • avoid any requests or suggestions that may cause undue disruption to business as usual for the college
  • communicate regularly and productively with college leaders, and keep them informed of emerging findings and judgements clearly and honestly
  • evaluate the work of the college objectively and impartially supported by clear and secure evidence
  • report fairly and without favour, ensuring that judgements are reliable
  • respect the confidentiality of inspection evidence and judgements
  • wear their ISI inspector identification badge at all times when on college premises.
• Colleges are asked to treat inspectors professionally, to send pre-inspection surveys promptly, to provide access to evidence, facilitate meetings, ensure inspector safety, maintain communication, raise concerns promptly, and to respect confidentiality.
• If access to accurate information is not facilitated, requirements may be judged to be not met. Where the credibility of the college or authenticity of the evidence is in doubt ISI may find that requirements are not met.

3.9 Proposals relating to complaints

• Providers can use the ISI inspection complaints policy if they have concerns about the conduct of inspectors, the inspection process or the inspection evaluations.

4. Objectives of the consultation

• ISI requests views on the clarity and workability of the proposed framework and inspection principles.

5. Options for consideration

• Option A – Adopt the proposed inspection framework without change.
• Option B – Adopt the proposed inspection framework with modifications.

(ISI will decide after reviewing consultation feedback. No decision has been taken yet.)

6. Impact assessment (high-level)

Students:

• Clear feedback on the quality of course provision, safety, and welfare.
• Clear monitoring of attendance and safeguarding.

Colleges:

• Evidence-based feedback and clear recommendations.
• Manageable and collaborative inspection process.

Equality and Diversity:

• The Framework requires compliance with the Equality Act 2010 and promotion of British values.
• Teaching must not discriminate and must promote respect for those with protected characteristics.
• Safeguarding arrangements for students under 18 and for any vulnerable students are prioritised.

Risks and Mitigations:

• Risk: Increased workload. 
  Mitigation: Principle of manageability.
• Risk: Ambiguity in the basis for evaluations and inspection processes
  Mitigation: ISI will publish the Inspection Framework, the Inspection Handbook for Inspectors and Frequently Asked Questions.
• Risk: Variability in evaluations. 
  Mitigation: Robust inspector recruitment and training, robust quality assurance processes, advice and guidance for inspectors during inspections, and learning from feedback from the complaints process.

7. Proposed inspection requirements 

Section One: Leadership and Management

• Financial sustainability, governance, and management compliance with Home Office requirements.
• Leaders have the knowledge and skills to meet all requirements.
• Recruitment follows UKVI guidance on English proficiency and students are placed on appropriate courses.
• Quality assurance processes use accurate self-evaluation and consider the views of students.

Section Two: Quality of Education

• Valid courses, approved qualifications for UKVI.
• Appropriate curriculum.
• Teaching that promotes students’ progress.
• EAL support for students.
• Regular assessment and feedback.
• Teaching underpinned by effective pedagogy and appropriate resources.
• Promotion of fundamental British values and adherence to the Equality Act 2010.

Section Three: Students’ Wellbeing

• Safer recruitment with accurately recorded pre-appointment checks.
• Suitable, well-maintained premises and residential accommodation.
• Health and safety, risk assessment, fire safety, first aid, evacuation and lockdown procedures.
• Suitable management of accommodation, and private fostering notifications where applicable.
• Monitoring attendance and punctuality including reporting to UKVI where required.
• Safeguarding guidance is understood and followed for students under 18 and for vulnerable students.

Section Four: Advice and Guidance

• Accurate pre-enrolment information.
• Effective induction.
• Access to a complaints process for students.
• Relevant advice on careers and/or further education and next steps.

8. Proposed timeline and next steps

• Consultation opens: 26 January 2026
• Consultation closes: 23 March 2026
• Analysis and consideration of responses: 23 March 2026 to 20 April 2026
• Publication of consultation outcome and final framework: week commencing 4 May 2026
• Pilot phase: May/June 2026
• Implementation start: 1 September 2026

ISI will publish an outcome report summarising responses and setting out the changes made (or reasons for not making changes).

9. How to respond

Please submit your response by 23 March 2026 23:59 GMT via any of the following:

• This online form
• Email: pfeconsultation@isi.net (subject: “ISI Consultation Response”)

Accessibility: If you need materials in an alternative format, please contact pfeconsultation@isi.net

Confidentiality & Data Protection: Responses will be handled securely. If you wish your response to remain confidential, please state this clearly. ISI will process data in line with data protection regulations.