When Michael Day began working at an overseas campus jointly operated by a UK university and a provider from that country, he quickly realised his role overseeing assessment and examinations for an entire faculty was not going to be an easy one.

Now associate professor in higher education learning and teaching at the University of Greenwich, Day is “increasingly concerned about the way quality assurance processes are being applied in some international joint venture partnerships involving UK institutions”, he told ����Vlog. “Some practices appear to raise questions of method, ethics and transparency, and I believe they merit closer scrutiny.”

His concerns at the campus in question ranged from what he saw as the insufficient English language skills of students studying degrees taught in English to the questionable qualifications of certain senior staff and the nature of some staff-student relationships. But when he and others raised these concerns, they were discouraged from pursuing them further.

“What is the mechanism for students or staff who are working in these settings to raise significant concerns?” Day asked.

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In transnational education (TNE) – the delivery of degrees abroad – the question of oversight is becoming more pressing. Facing mounting financial challenges and immigration restrictions at home, Western institutions are increasingly expanding their operations abroad. Most recently, a wave of Western branch campuses have been announced in India, for instance, including at least six from the UK.

Among English institutions, income from TNE increased by 13.6 per cent between 2022-23 and 2023-24 and is forecast to increase by a further 28.1 per cent by 2025-26, (OfS). And, facing pressure from the Trump administration, institutions in the US are also widely predicted to begin expanding their operations abroad.

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But, as offshore student numbers grow, ensuring quality becomes ever more important – and difficult. TNE operations, by their nature, are often thousands of miles away from awarding bodies’ home campuses and outside domestic regulatory jurisdictions. In addition, they are commonly run in partnership with private companies and are subject to the often complex regulations and changing policies of foreign governments.

“Anybody who has any understanding of how quality assurance works would know that it is difficult enough to quality-assure in an institution that you have direct operational control over,” said Day. “It is very, very difficult to quality-assure degrees at a distance. Typically, only a small sample – usually around 10 per cent of a class, which can include hundreds of students – is submitted for moderation, marking and review.”

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While universities are quick to defend their practices abroad, Day is not alone in his criticisms. Writing for THE last year, Anthony Killick, now a lecturer in media, culture and communication at Liverpool John Moores University, discussed his experience of teaching at a UK-validated university in the Middle East where, he alleged, managers were advertising programmes that did not exist to get students through the doors and UK staff turned a blind eye to lapses in quality.

And, in a 2024 sharing mid-point findings from its TNE evaluation scheme, the Quality Assurance Agency for ����Vlog (QAA) found that while “initial scrutiny, approval and ongoing monitoring of partnerships and other arrangements” were “well managed” by UK universities, there was a “less consistent approach to examining the impact of expansion of activity. This applies to the addition of new programmes to a partner’s portfolio and to increasing student numbers on their approved courses.”

In particular, the report found “a lack of planning and assessment of the impact of expansion…[on] the workloads of staff involved in partnership management, administration and academic delivery, as well as professional services and external examiners” – suggesting that when institutions expand offshore, there is a risk that quality declines.

Moreover, expansion is often the name of the game.

“The vast majority of TNE is delivered by universities that want scale,” said Ishan Cader, senior director of consultancy at THE. “Some institutions might just have single arrangements that work quite well. Others do overstretch: they do lapse on quality.”

That peril is exacerbated by the fact that the relationship between accrediting university and the partner organisation “can be very transactional”. The former might send the latter “an updated curriculum once a year, but they don’t come to the country and really review things, so there’s gaps in practices.”

That view was endorsed by Nigel Healey, a consultant in international higher education. “Your TNE operation, unlike the UK campus, is wholly dependent on teaching revenue,” Healey said. “There’s no other income stream, so if it doesn’t hit recruitment targets, it’s going under.”

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Moreover, with money tight at home, institutions are increasingly turning to private partners to front the cash for overseas campuses. But “the joint venture partner is in it for the money,” said Healey, and may pressure the accrediting institution to recruit more students if it is not seeing returns on its investment.

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While there are frameworks in place to protect students abroad, these are not always complementary, with universities subject to multiple, and sometimes misaligned, regulators, including within the UK, where higher education is devolved.

In recent years, the OfS, England’s regulator, has made moves to increase its oversight of TNE. In an , it said that students registered with English universities and colleges abroad are “entitled to expect the same quality and standards as those resident in England, and their courses are subject to the same regulation”.

But while offshore students can technically raise their concerns with the OfS, “whether a [TNE] student…whose primary loyalty might be to the partner university, not to the awarding body, has actually heard of the Office for Students or is aware of their ability to [report complaints to it] is a completely different question,” said David Carter, head of the International Study and Language Institute at the University of Reading.

And since the OfS takes a data-led approach to monitoring TNE, primarily based on information shared by registered providers, any deficiencies in data gathering and reporting by universities limit the regulator’s ability to intervene. Although the ����Vlog Statistics Agency (Hesa) collects information from institutions on offshore enrolments, the numbers are not linked to funding and it is widely suggested that some universities fudge them, either to appear bigger than they are or to protect valuable commercial information about actual enrolments. And little further data is collected, on factors such as student experience or outcomes.

“The problem with the data-led approach is that it’s only as good as the data you have to hand, and the Office for Students has a huge amount of data to go on when it comes to UK-based undergraduates, but rather less to go on when it comes to offshore students,” said Carter. 

While the OfS has previously suggested it may ask providers to share more TNE-related data, it has . And, for some, that delay is welcome.

“Capturing student TNE data and so on would have brought so much pain to institutions,” said Antonius Raghubansie, pro vice-chancellor (international) at Keele University.

Instead, he said, the OfS should be “trusting our institutions to know that they’re good and that the systems that they’re introducing are good and then pressing the button as and when something comes up…The sector is pretty good at that kind of stuff”.

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Keele is one of the approximately 75 providers signed up to the QAA’s voluntary TNE regulation scheme, the Quality Evaluation and Enhancement of UK TNE (QE-TNE) – accounting for about 70 per cent of the UK’s entire higher education TNE student population. Originally commissioned by Universities UK and GuildHE in 2021, the programme evaluates UK provision in three countries per year.

It’s “a way to kind of bring coherence and cohesion across the UK landscape”, said Shannon Stowers, head of international policy and engagement at the QAA. “We’ve got different systems in the four [UK] nations and I think that can be quite hard to communicate internationally and can be quite hard to understand.”

However, the QAA’s findings on TNE quality assurance are rarely made publicly available – instead, only being shared with paying members of the programme. And while there is logic to this model given that the QAA is a private company that has to cover its costs, it prevents the lessons being learned across the sector, said Carter – who recently authored a report on student experience in TNE.

As a result, “public assurance” on TNE quality is lacking, Carter continued. And that makes it a strange anomaly: “It seems odd to me that the sector and regulating bodies bend over backwards to provide these kinds of assurances for UK-based students but not necessarily for offshore students.”

In an ideal world, all UK regulators would require providers with TNE student numbers above a certain threshold to join the QAA scheme, Carter belies. This would, overnight, make the QE-TNE “a much more useful tool for measuring quality in transnational education”. But his sense is that “probably…there isn’t any appetite for it”.

Given the existing demands from regulatory bodies at home – and the cost of adhering to these – universities are understandably reluctant to sign up to more regulation. That is particularly true given that the rules of the country in which they are working can be very different from those in their home countries.

“The potential for [regulations] to come into conflict is huge,” said Healey, giving the example of universities that are equal opportunities employers trying to employ international staff in countries that might not recognise same-sex relationships.

While universities generally welcome clear regulations from host countries, which make operating there less risky, what entails quality is far from universally agreed.

When new TNE regulatory guidelines were released by the Indian government in 2022, for instance, they were widely celebrated for making it significantly easier to operate in the country. But neither franchise programmes nor online provision would be recognised – apparently because of perceptions that these forms of education are of lower quality than that offered by fully fledged branch campuses. 

For universities, navigating cultural differences can make TNE harder – but it can also become an excuse for lapses in quality assurance. Greenwich’s Day believes that, in some instances, staff who emphasise the importance of maintaining UK academic standards are told they lack an understanding of the cultural context in which they are working. But while he acknowledged that academic colonialism remains a significant concern in transnational education, he also pointed out that many countries set clear expectations for offshore provision to align closely with the education delivered at home campuses.

Some wonder whether the scale of TNE is now such that universal quality standards need to be developed. And starting to meet that considerable challenge is the ambition of new work being overseen by Unesco.

As part of the Global Convention on the Recognition of Qualifications – which aims to promote cross-border credit mobility – states including the UK, Australia and South Korea have agreed to develop international guidelines for TNE quality assurance.

Agreeing on quality standards globally is essential to ensuring that qualifications are recognised across borders, said the convention’s chair, Stig Arne Skjerven. And although Unesco’s guidelines won’t be legally binding and won’t attempt to come to a universal definition of quality, they will provide a shared jumping-off point.

“I think that’s a piece of work that is so essential,” said Vangelis Tsiligkiris, professor of international education at Nottingham Trent University. “You cannot come up with something that is going to be actionable at institutional level for the entire world, but it will be something that will be a benchmark for national bodies and other organisations, which will then inform institutional or national policies around quality assurance,” he said.

The QAA’s Stowers cautioned that there is “no one single approach to quality, and I think that’s fine…because we live in a very diverse world and I think we need to make sure that regions can maintain their distinctiveness and their identity”. Hence, “when it comes to quality assurance of TNE, it’s a negotiation”.

Nevertheless, “if we’ve got all of these different [quality assurance] mechanisms that are all being developed at the same time, it’s really important for them to be aligned because, otherwise, you just add more confusion to a landscape that’s already quite complicated. And that’s not helpful to anybody.”

Still, even as quality assurance agencies plough on with work to improve standards in TNE, there are doubts about how closely institutions – and governments – are prepared to engage with it.

“We’ve seen rapid commentary about student visas…but we’ve seen no commentary from our government in the United Kingdom suggesting that we might want to really focus on the regulatory assurance and experience of our rapidly expanding university sector overseas,” said Day.

"I do believe that, because of neoliberalism and business requirements, it is unlikely that we will look too closely at this emergent space,” he said, pointing to the financial implications of uncovering concerning practices that may affect reputations or even lead to the closure of some programmes.

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Even when potential risks to academic standards are recognised, he fears that in discussions about the need for stronger TNE quality assurance, some in the sector may take the view that “the disadvantages far outweigh the advantages.”