The OfS response and the regulatory outlook
The publication of the revised CUC Code of Governance was immediately welcomed by the Office for Students (OfS). In a letter to university chairs dated 24 June 2026, the OfS Chair, Professor Edward Peck, described the revised Code as sending "a strong signal about the priority that institutions place on effective governance" and reflecting "a clear commitment to strengthening practice through sector-led action."
The letter also signals important next steps in the regulatory landscape: the OfS intends to consult formally on its ongoing conditions of registration on effective governance in early 2027, building on the revised Code.
Governing bodies should therefore approach their implementation of the revised Code not merely as an exercise in sector-led self-governance, but as preparation for a forthcoming regulatory consultation that will, in all likelihood, draw directly on the Code's framework and language.
Over-optimistic student number forecasts
In the same letter, Professor Peck drew chairs' attention to the sector trend for forecasts that repeatedly assume surpluses from 2026/27 onwards, warning of the danger that some providers are signing off over-optimistic student number forecasts that may mask the need for significant changes to their size and shape, and emphasising that effective board oversight of financial risk and guarding against rose-tinted forecasting are critical in the current context.
This serves as a direct signal that the OfS will be scrutinising the quality of board-level financial challenge when it develops its updated governance conditions.
CUC Higher Education Code of Governance: Key topics
- The OfS response and the regulatory outlook
- Student and staff board members
- Charity and OfS governance
- New structural architecture
- Culture and behaviours
- Strategy, sustainability, risk and assurance
- Board composition
- Academic governance and board effectiveness
- Formalised individual role responsibilities
- Steps to implementation
- Frequently asked questions
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