What next for TEF and APP?

This blog was kindly authored by Professor Liz Austen, Associate Dean Learning, Teaching and Student Success and Institutional Lead for the Access and Participation Plan at Sheffield Hallam University.

The OfS consultation in late 2025 outlined proposals for a future quality system in higher education (England and Wales). These proposals have significant implications for the design and regulation of the Teaching Excellence Framework (TEF), the Access and Participation Plan (APP) and the B Conditions of Registration. The first cohort of new TEF assessments are scheduled for 2027-28 and the sector is still waiting to hear what happens next. Those leading on the strategic delivery of teaching excellence and access and participation, including myself, are particularly interested in how these imminent changes will land.

There are several possible scenarios for how TEF and APP, as existing regulatory submissions, might be integrated. The one that seems most likely is that accountability for the wider range of differential student success outcomes, currently under the APP umbrella of ‘equality of opportunity’, will have a significant place in the TEF. To avoid duplication, the APP will then refocus on access, akin to when OFFA introduced Access Agreements in 2006.

But what does this actually mean? Split metrics by student demographics for most outcomes are already assessed within the TEF, with the TEF narrative playing an important role in explaining any significant contextual factors. However, this is currently a retrospective and defensive narrative to explain current metrics; it does not then formulate a plan to improve them, as the APP currently does.

What if the TEF became a Plan?

Imagine a TEEOP – Teaching Excellence and Equality of Opportunity Plan – has been created, modelled on the existing structure of the APP. In this hypothetical regulatory move, providers are asked to review the OfS Benchmarks for Student Experience, B3 Thresholds Student Outcomes and the Equality of Opportunity Risk Register to consider the various risks that their student population and different groups of students might face. Providers will set timebound and measurable objectives to address these risks. Objectives will be translated into numerical targets, such as

Objective 4c: University x will improve the student responses to NSS questions in the category ‘Teaching on my course’ from 86.1% to 82%.

Intervention strategies will detail how the Provider will meet these student experience, student outcomes and equality of opportunity objectives and an evaluation plan will detail how progress will be monitored and impact reported. A financial report will be submitted to the OfS annually on accountable spend on delivering and evaluating TEEOP interventions.  The TEEOP data would be reviewed every 4 years, where new targets would be set and interventions designed. Judgements of excellence would be based on the effectiveness of the Plan and evaluative data reported through the Higher Education Evaluation Library (HEEL).

Considerations

Whilst there are stipulated limitations of not having an APP (e.g. fee caps) and reportable events connected to plan activity and evaluation reporting, no penalties have been applied in the history of the APP. As Jim Dickinson recently noted, APP targets frequently go unmet from one Plan cycle to the next:

Of the 777 assessable targets, 488 – 63 per cent – missed the 2023–24 milestone that the provider had agreed with OfS.

This sits in contrast to the TEF, which is more forthright in the distinction of excellence and has explored the possibilities of sanctions for Bronze or Requires Improvement ratings. If the TEF looked more like the APP, then it would be seriously toning down the regulatory scrutiny and perceived market differentiation of Providers. There are certainly flaws in both these assumptions.

A further challenge is the APP language of ‘intervention’, which is described as a discrete action with a clear beginning and end point, and can be neatly evaluated (Austen in Austen & McCaig, 2025). Actions to improve the student experience are often curriculum based. They might involve course redesign and adaptations in pedagogy and practice. This type of change doesn’t always align to this notion of an ‘intervention’. The NSS is also a flawed measure of impact. This means that the application of APP-style evaluation, and the search for causal evidence historically promoted by TASO, becomes less applicable; a quality process of continuous improvement is more often the means of review, monitoring and evaluation.

A more integrated model would benefit those institutions who are predominantly widening access and securing success for students who are typically underrepresented in higher education. When your APP interventions are more business as usual than targeted, a holistic model of quality regulation is more appealing.

What if the APP became a Framework?

Alternatively, imagine a TEEOF – Teaching Excellence and Equality of Opportunity Framework (for the golf lovers) – is created and modelled on the TEF. In this hypothetical scenario, the OfS sets the number of minimum requirements for Student Experience, Student Outcomes and Equality of Opportunity. The TEF indicators are produced by the OfS and include NSS, continuation, completion, progression, and differential gaps by student group for the most recent 4 years. The TEEOF would include attainment/awarding (good honours) as an additional indicator, previously only included in the APP. OfS set the benchmarks for these indicators. In the TEEOF, this would include sector benchmarks for all differentials, including the ethnicity degree awarding gap, and any other risks to quality of opportunity such as socio-economic disadvantage or care and family responsibilities. Providers obtain a rating of Gold, Silver, Bronze and Requires Improvement based on a panel’s assessment of their indicator data, and a provider narrative submission. A student submission will also be submitted, which specifically includes student voices from students who face risks to equality of opportunity. The TEEOF will assess the quality and equality of undergraduate courses in the first iteration and include postgraduate courses in subsequent years. An indication of the judgements on the feature of excellence would be as follows:

Outstanding quality – signifying features of the student experience, outcomes and equality of opportunity that are among the very highest quality found in the sector for the mix of students and courses taught by a provider

Considerations

The OfS judgements of excellence would explicitly include APP attainment objectives and would include the ethnicity degree awarding gap. As Katharine Hubbard has shown in her HEPI report ‘Making Metrics Matter’,Providers in the current regulatory system are able to obtain TEF Gold while still having substantial Black awarding gaps. Hubbard explicitly concludes that there are ‘multiple TEF Gold and Silver providers with significant racial inequity of outcome’ and of 47 TEF Gold institutions, 7 had Black awarding gaps greater than 25 percentage points. Crucially, this would provide a more authentic appraisal of the quality of provision and would elevate the responsibility to address racial disparities in higher education.

Similarly, but with less enthusiasm than the APP, the TEF does have existing expectations about presenting impact, and references evaluation as a source of this impact evidence. However, this evidence is used as a justification for what has gone before; the TEEOF would not include regulatory expectations for the planned delivery and evaluation of interventions to improve experiences and outcomes. A new set of regulatory guidance, learning from the APP evaluative expectations, could inform Provider narrative submissions.

Conclusions

It is hoped that evaluations of the TEF and the APP, alongside the sector’s consultation responses, have provided a wealth of evidence on a future integrated model. This model should retain those elements that work for both Provider and Regulator, and importantly current and future students. Whether that’s a forward-looking plan or a retrospective account, or a bit of both, remains to be seen.

The OfS could look across the border to the Scottish Funding Council’s ‘Outcomes and Assurance Model’ where the holistic regulatory focus is now clearly on the Provider level outcomes achieved by institutions, rather than the activities they plan to undertake. This includes high quality teaching, learning and student experience alongside access and success outcomes, but also has stipulations for broader outcomes such as financial viability, good governance and EDI. Providers then have their own forward focused strategic and operational plans underpinning their regulatory progress and assurance is achieved through engagement and regulatory interactions and monitoring through review and data oversight.