Your President, Jubair Ahmed, has written an open letter to Prime Minister Keir Starmer urging the Government to pause the proposed international levy. He has the support of other Students' Unions across the country, as well as MPs and other community leaders. While the coalition strongly supports the Government’s objective to reintroduce targeted maintenance grants for disadvantaged students, it warns that the proposed £925 flat-fee levy on international student fee income is a fundamentally flawed mechanism that would undermine the very higher education system it seeks to strengthen.

You can read the letter in full below, or download a copy here. The press release is available for download here.

Formal Consultation Response: International Student Levy Proposal

• Dear Prime Minister,
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• I write as President of the University of Hertfordshire Students' Union and on behalf of a broad coalition of Members of Parliament, councillors, student leaders, high commissioners and community representatives. We submit this formal response to the consultation on the proposed international student levy outlined in the Immigration White Paper and related changes to the Graduate Route visa.
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• We unreservedly support the Government's objective to reintroduce targeted maintenance grants for disadvantaged home students studying priority subjects. Widening participation is central to our mission. However, we must respectfully submit that the proposed levy represents a fundamentally flawed mechanism for achieving this objective. While we support the destination of these funds, the mechanism creates a counterproductive cycle that will undermine the very system it seeks to strengthen.
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• The levy would extract an estimated £620-£630 million annually from English higher education institutions. For the University of Hertfordshire, this represents approximately £15-£17 million based on our £147 million in international tuition fee income. This is not surplus income. It already cross-subsidies home student education, funds research, maintains facilities benefiting all students, and supports local employment. International fees provide an estimated £28 billion annual cross-subsidy sector-wide, enabling courses to remain viable that could not otherwise be sustained.
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• The Institute for Fiscal Studies calls it a ‘tax on a major UK export’. Whether the tariff goes on international student fees – which research indicates will lose us 16,000 students straight away – or is absorbed by universities (which they are in no position to cope with) jobs will be lost. The loss of 16,000 students implies 4,000 jobs at risk in higher education and 4,000 more jobs in local economies. In December, Martin Wolf in the Financial Times wrote, ‘the proposed…tax on international student fees is a dagger aimed at one of the UK’s most successful export industries’. Who can disagree!
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• The Government is arguing that there is no alternative to fund domestic student maintenance (which to be clear is a worthy cause for support). I can’t be the only one who can think of an obvious alternative. Current US policy is hammering the competitiveness of the market leader, so that offers the UK a golden opportunity, if government would only work with the sector to grow our international education exports rather than endlessly restricting them.
• Independent modelling by Public First estimates the levy will trigger a £1.8 billion loss to the UK economy in its first year, with nine of twelve regions losing over £100 million. In Welwyn Hatfield constituency, international students at the University of Hertfordshire contribute approximately £95 million in gross value added and support 1,650 full-time equivalent jobs through off-campus spending. The Home Office technical annex acknowledges the levy could depress international student numbers by 7,000. This substantially underestimates the true demand elasticity when combined with the proposed Graduate Route reduction from twenty-four to eighteen months, stricter compliance thresholds, and the cumulative negative perception created by successive policy restrictions.
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• The central flaw in the policy design is clear. The levy extracts funding to support disadvantaged students while simultaneously weakening institutions' capacity to recruit international students whose fees make courses viable that home students alone cannot sustain. International recruitment is not a discretionary activity. It is the mechanism successive governments mandated for financial sustainability without increasing burden on taxpayers. The 2019 International Education Strategy explicitly tasked universities with growing international numbers to ensure viability. The University of Hertfordshire responded to that directive and achieved a King's Award for Enterprise in International Trade in May 2024, with approval from both yourself as Prime Minister and His Majesty The King. The result of the levy will be a predictable downward spiral. Reduced international income will lead to fewer course offerings, diminished research capacity, and ultimately fewer opportunities for the very domestic students the policy purports to assist.
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• With 118 providers already forecasting deficits for 2024-25, representing a forty per cent increase from the previous year, the levy risks accelerating institutional financial distress. The Migration Advisory Committee review in May 2024 found no evidence of Graduate Route abuse, identified clear economic and societal benefits, and explicitly warned that changes would damage UK global competitiveness. The sector is recovering from the January 2024 visa changes, with international applications increasing thirty per cent year-to-date through May 2025. Implementing further restrictions now will abort this recovery and compound reputational damage to the UK as a destination for international students.
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• Sector analysis has identified fundamental implementation challenges. The definition of international fee income for levy purposes remains unclear. The policy has not specified whether this includes gross fee income, net income after agent commissions that can reach twenty per cent of first-year fees, foundation year fees paid to partner institutions, or fee income after scholarships and discounts. Current data infrastructure cannot support real-time levy calculation. The levy will impact institutions unevenly, disproportionately affecting providers at the price-sensitive end of the market who recruit from lower-income countries, while well-resourced institutions recruiting affluent students can more readily absorb or pass on costs.
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• Alternative funding mechanisms exist that would achieve the widening participation objective without undermining international education. These include progressive taxation on broader tax bases that distribute burden equitably across society, restructured student loan repayment terms particularly given the 2022 changes that extended repayment for lower earners from thirty to forty years while relieving higher earners, or reformed national redistribution of existing Access and Participation Plan expenditure to address current inequities where Russell Group institutions spend £2,362 per disadvantaged student compared to £726 at other providers.
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• No stakeholder group represented in this coalition supports the levy in its current form. We seek constructive engagement to identify policy options that reconcile the legitimate objective of supporting disadvantaged students with the imperative to preserve sector competitiveness and regional economic benefits. We formally request that the Government pause further progression of the levy proposal pending completion of a comprehensive independent impact assessment covering international student recruitment demand elasticity, institutional financial sustainability particularly for teaching-intensive and regional providers, regional economic effects with constituency-level detail, research capacity and skills pipeline implications, and alternative funding mechanisms that achieve the stated objectives.
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• We respectfully submit that the APPG for International Students exists as the appropriate parliamentary mechanism for evidence-led dialogue on these matters. We strongly urge the Government to engage formally with the APPG, alongside Universities UK, the National Union of Students, representative student unions, and local authority partners to develop policy that serves the shared interests of social mobility, economic prosperity, and global academic leadership. The University of Hertfordshire and our coalition partners stand ready to provide detailed institutional data, economic analysis, and operational insights to support this process.
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• We request the opportunity to meet with yourself or relevant ministers to discuss these concerns and to explore evidence-based alternatives. The international education sector contributes between £37 billion and £41 billion to the UK economy annually and supports over 400,000 jobs. It strengthens research capacity, addresses critical skills shortages, and enhances Britain's global standing. Policy development must balance the legitimate objective of supporting disadvantaged students with the preservation of these substantial national assets.
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• Thank you for your consideration of this formal consultation response.
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• Yours sincerely,
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• Jubair Ahmed
• President, Hertfordshire Students' Union
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• On behalf of Members of Parliament, Councillors, High Commissioners, and Student & Community Leaders Supporting the UK's Higher Education Excellence.
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• The Rt Hon Bridget Phillipson MP, Secretary of State for Education; The Rt Hon the Baroness Smith of Malvern, Jacqui Smith, Minister of State for Skills; Minister of State for Skills and Further Education;  The Lord Bilimoria CBE DL Karan Faridoon Bilimoria, APPG for International Students; Professor Edward Peck CBE, Chair, Office for Students.