Commissioner for Fair Access: annual report 2025/26

4 - Considerations for innovation and evidence

Fair access in Scotland is already underpinned by much good practice (section 2 of this report) and is informed by a rich evidence base (section 3 of this report). However, there are ways in which both evidence and practice could be strengthened. In this section, I make ten recommendations to enhance the RoWA (4.1.1) and some suggestions for the wider evidence base (4.1.2). I also make a recommendation to change the way in which we describe articulation (4.2). Finally, I suggest three issues to strengthen fair access practice (4.3).

4.1 – Evidence

4.1.1 - RoWA

As is clear from the previous section of this report and previous Commissioner reports, the Report on Widening Access (RoWA) provides a very useful evidence base from which to appraise progress in achieving fair access to higher education in Scotland.

The RoWA is the primary source of public data that reports on the Scottish Government’s fair access targets. However, the RoWA – as with its predecessor Learning for All,^[109] which addressed similar issues and was published between 2007 and 2016 - serves a broader purpose in sharing a wider range of fair access data on tertiary education in Scotland.

The Scottish Funding Council (as author of the RoWA) has also been receptive to suggestions to increase the utility of the RoWA. Notably, the data tables that accompany the last two RoWA reports have included a breakdown by decile of entrants from SIMD 0-40 areas. These data have been provided for tertiary institutions (FEIs and HEIs) and for Scotland as a whole (first degree at university and all undergraduate higher education). We now have an evidence base to ascertain whether – as some have speculated - the focus on facilitating access for those from SIMD20 areas is at the expense of those from SIMD 20-40 areas (refer to 3.4, point 1 in this report).

There are nine more ways in which RoWA could be strengthened by increasing the granularity of the evidence base.

1. Improve the evidence base on retention by disaggregating according to degree year.

The RoWA reports on retention rates, which are described as “returning to study in year 2” (CoWA Tables 2 and 2a, Background Tables 3 and 4). Data are not disaggregated by degree year and therefore do not allow comparison of retention rates across:

• Those starting the academic year in the first year of a degree.
• Those starting the academic year in the second year of a degree.
• Those starting the academic year in the third year of a degree.

Although described as “returning to study in year 2”, this is a little misleading on three counts. First, it is not clear that ‘year 2’ means next year of study (which can be into the second, third or fourth year of a degree). Second, it suggests that the purpose of these data is to estimate non-continuations (rather than non-completions). Third, it disguises the very sensible interpretation of SFC that students who achieve and exit with a qualification are counted among those who continue, and not counted among those who did not return to study. For example, students who articulated with a Diploma into the third year of a degree, and who then graduated with an Ordinary Degree are not counted among those not returning to study (although they did not return to study and were not retained, they did exit with an award).

Data Recommendation 1: Introduce a more accurate way of describing and/or explaining ‘retention’ data

Data Recommendation 2: Disaggregate retention data by year of study

2. Examine the merits of strengthening the evidence base on retention by disaggregating for continuing and articulating students.

As noted above, the RoWA reports on retention rates, which are described as “returning to study in year 2” (CoWA Tables 2 and 2a, Background Tables 3 and 4) and currently does not disaggregate by degree year. Were my Data Recommendation 2 to be actioned, there is a further way in which the utility of these retention data could be strengthened. Data could be further disaggregated to compare the retention rates of articulating and non-articulating students. This could comprise:

• Degree year 2: Presenting data for students who started their studies in year 1 and those who articulated to start their degree in year 2.
• Degree year 3. Presenting data for students who started their studies in year 1, those who articulated to start their degree in year 2, and those who articulated to start their degree in year 3.

Data Recommendation 3: Disaggregate retention data according to year of entry to degree.

3. Enable direct comparison of institution retention rates for students from SIMD20 areas and those from SIMD20-100 areas.

RoWA presents data for each HEI on the retention rate of students from SIMD20 areas and the retention rate of all students (CoWA Table 2a). Given that the retention data for institutions for all students incorporates data for students from SIMD20 areas, these data under-estimate the differences in retention rate between students from SIMD20 areas and those from SIMD20-100 areas.

Data Recommendation 4: Present data in CoWA Table 2 on the retention rate of students from SIMD20-100 areas, alongside the existing data on retention rates for all students and for students from SIMD20 areas.

4. Examine the merits of presenting data on exit qualifications for HEIs.

RoWA presents data on qualifiers (CoWA Table 3, 3a, 3b and 15). A range of exit qualifications are included in these counts:

• Table 3a counts Graduate Level Diplomas, HNC, HND, CertHE, DipHE and Foundation Degree, as well as all exit qualifications in Table 3b.
• Tables 3, 3b and 15 count First degree with honours, Ordinary (non-honours) first degree, and Integrated undergraduate/postgraduate taught Masters degree.

Exit qualification could be further disaggregated by SCQF level to better understand the achievements of the student population, i.e.:

• SCQF Levels 7, 8, 9, 10 and 11 for Table 3a.
• SCQF Levels 9, 10 and 11 for Tables 3, 3b and 15.

Data Recommendation 5: Examine the practicalities of disaggregating exit qualification data by SCQF Level of qualification.

5. Improve the evidence base on Graduate Apprenticeships.

It would be helpful to provide separate totals for Scottish-domiciled first-degree entrants (for Graduate Apprenticeships and the remainder of degree courses). At an appropriate point in time, it would be helpful to provide a similar breakdown for qualifiers.

Data Recommendation 6: Disaggregate totals to provide data for Graduate Apprenticeships where data are already provided for Scottish-domiciled full-time first-degree entrants.

6. Improve the evidence base on part-time first-degree students.

The RoWA background tables currently provide data on enrolments (Table 5) and completions (Tables 6 and 7) for part-time students pursuing higher education in Scotland’s colleges. Data are also provided for participation across subject areas for both full-time first-degree entrants and all entrants (Tables 8a, 8b and 8c). More generally, RoWA tables provide data for two national aggregates:

• Scottish-domiciled full-time first-degree entrants/qualifiers to higher education in Scotland.
• Scottish-domiciled undergraduate entrants/qualifiers to higher education in Scotland, which comprises:
  • Scottish-domiciled full-time first-degree entrants (core CoWA, data presented in RoWA).
  • Scottish-domiciled part-time first-degree entrants.
  • Scottish-domiciled entrants (all modes of study) to sub-degree courses of higher education. This could include:
    • In FEIs: Scottish Baccalaureate, Professional Body Qualification, Scottish Vocational Qualification or National Vocational Qualification, SQA Professional Development Award, Graduate Level Apprenticeship, SQA Advanced Higher Award, HNC/HND, Advanced accredited qualification not specified elsewhere.
    • In HEIs: Evening language courses; Upskilling courses; Access courses; HNC/HND; and Certificates or Diplomas of HE.

The broad range of higher education that is included in the totals for Scottish-domiciled undergraduate entrants/qualifiers to higher education in Scotland, means that subtracting from this data for Scottish-domiciled full-time first-degree entrants does not provide totals for Scottish-domiciled part-time first-degree entrants. It would be helpful to provide separate totals for part-time Scottish-domiciled first-degree entrants (alongside full-time Scottish-domiciled first -degree entrants) and to do so for both FEIs and HEIs.

Data Recommendation 7: Disaggregate totals to provide data for Scottish-domiciled part-time first-degree entrants where data are already provided for Scottish-domiciled full-time first-degree entrants and Scottish-domiciled entrants (all modes of study) to sub-degree courses of higher education.

7. Examine the merits of presenting data on higher education in colleges for courses of less than 160 hours duration.

The benchmark of 160 or more hours of study in colleges is used to indicate a ‘substantial’ period of study^[110]. RoWA does not report on whether higher education is being pursued in colleges for courses that are less than 160 hours duration (and whether students from more disadvantaged backgrounds are more likely to engage in these shorter courses).

Data Recommendation 8: Examine the practicalities and utility of presenting data on higher education in colleges for courses of less than 160 hours duration.

8. Extend sub-division of data for courses of 160 hours+ in colleges to improve data profiling of higher education in colleges.

As noted above, the benchmark of 160 or more hours of study in colleges is used to indicate a ‘substantial’ period of study. RoWA data are provided on enrolments (Table 5) and completions (Tables 6 and 7) for four cohorts of college student, i.e.,

• Full-time, higher education.
• Part-time, higher education.
• Full-time, further education.
• Part-time, further education.

However, there is no disaggregation by these four cohorts of student when data focuses on subject area (superclass) (Tables 9, 10, 11) and participation by “groups of specific interest” (Table 17).

Data Recommendation 9: Disaggregate totals where data are already provided (currently for courses of 160 hours or more duration) to distinguish between part-time and full-time students.

9. Extend the base against which articulation data are reported.

Background Table 14 of the RoWA presents a range of useful data on articulation, i.e., counts for the three ‘levels’ of articulation for both of the ways in which articulation is measured (14a), the number and proportion of students articulating with Advanced Standing for six population groups (14b), the number and proportion of students articulating with Advanced Standing for university subject areas (14c), and the number and proportion of SIMD20 entrants who progressed through a college route (14d). Although wide-ranging, these data do not estimate the number and proportion of entrants for each university subject area who do not enter with advanced standing (i.e., the number considered to have entered with ‘progression’ or ‘advanced progression’). This would serve the useful purpose of understanding which parts of higher education are more likely not to (be able to) facilitate progression with advanced standing.

Data Recommendation 10: Present data for subject areas on each of the three ‘levels’ of entry to university education for college students.

4.1.2 - Evidence – beyond RoWA.

HESA data is – and should be – the key source of intelligence on fair access. However, these data are not the only useful source for understanding fair access in Scotland as has been evidenced by the Student Finance and Wellbeing Study Scotland report (commissioned by the Scottish Government)^[111], and Public Perceptions of Higher Education Funding in Scotland (commissioned by the Carnegie Trust for the Universities of Scotland)^[112]. Bespoke cross-sectional studies of this ilk are to be welcomed. However, there are also ways in which regular data series beyond RoWA could be used to strengthen the evidence base. I make reference to three data series, one established, one pending, and one yet to be developed.

1. Early withdrawals.

For reasons that are understandable, institutions are not required to submit a student record for students who leave within two weeks of starting their studies unless (i) the student was on a short course which they had completed, or (ii) the student applied for a loan with the Student Loans Company (SLC) and where the attendance had been confirmed to the SLC. Institutions could return records for students who do not satisfy these criteria but they will be excluded from the HESA Standard Registration Population, which is the standard population filter used for all SFC reporting and HESA’s own reporting. Although it is unlikely that there would be a substantial number of early withdrawals from higher education, it would be helpful to understand the scale of the issue and to understand whether those from disadvantaged backgrounds comprise a disproportionate share of this group.

2. Regular annual survey of Access and Participation practitioners.

SCAPP has intimated that it intends to administer the first nation-wide survey of access and participation practitioners in Scotland in 2026. I strongly support this development, and have contributed to the design of this survey. This has the potential to strengthen the work of SCAPP, to provide intelligence on work to promote fair access in Scotland, and to better understand the challenges faced by those designing and delivering it. Ideally, this will provide an authoritative comment on access work, and will be administered on an annual basis to enable changes in access practice to be tracked through time.

3. Access to Postgraduate Education.

Since 2021-22 (for its student-led competition) and 2023-24 (for its supervisor-led competition), the Scottish School for Graduate Social Science has profiled its applicants. It does not collect data on SIMD status (either at the point of entry to higher education or the point of application to postgraduate research). However, it profiles applicants by whether they were in receipt of free school meals, whether they first in family to attend university, and the occupation of the main household earner when they were aged 14 (alongside other data on sex, age, ethnicity, disability, sexual orientation, asylum seeker/refugee status, whether school education was completed in the UK, whether they have caring responsibilities, whether they are a care-experienced student, the result of their undergraduate degree, whether they have a Masters degree, and the type of school they attended between the ages of 11 and 16). Although comprising only a small (but important) part of postgraduate education, this is a most welcome development that provides insight into access at the very highest levels of tertiary education. Given that retrospective data is asked of applicants, it would be helpful to collect data on SIMD status, to align with the core CoWA work on fair access. It would also be interesting to explore whether such data could be collected for other forms of postgraduate education. Similarly, it would be helpful to disaggregate these data to profile Scottish-domiciled students (particularly those who were domiciled in Scotland at the point of entry to higher education).

4.2 - Presentation

Scottish education purports to promote parity of esteem, with the Scottish Credit and Qualifications Framework^[113] providing a clear statement of where there is a parity. For example, at SCQF Level 7, Higher National Certificate is considered an equivalent level of learning to the first year of a university degree (after which a student could exit with a Certificate of Higher Education). Where the substantive content of a programme of study is equivalent, the understanding is that both cohorts would be suitably qualified to progress to the second year of university study. Similarly, at SCQF Level 8, a Higher National Diploma Diploma is considered an equivalent level of learning to the second year of a university degree (after which a student could exit with a Diploma of Higher Education). In this instance, where the substantive content of a programme of study is equivalent, the understanding is that both cohorts would be suitably qualified to progress to the third year of university study.

However, the language of articulation portrays transition from college as a progression with ‘Advanced Standing’. Indeed, replication of that level of learning is described as ‘Advanced Progression’. Progression is used to describe the situation when transition results in move into a lower SCQF level of learning than that already achieved. This use of language is confusing and undermines parity (Table 7). Consideration should be given to adopting language that acknowledges transition, accepts that this is a progression of sorts, and more accurately reflects movement between SCQF learning levels. An alternative set of descriptors for progression from college to university study is proposed in Table 8.

These proposed descriptors:

• Recognise that any transition is a progression, as further learning is being pursued.
• Acknowledge SCQF Levels, describing these progressions as either:
  • At a lower level of study (if the transition results in learning at an SCQF Level beneath that previously achieved).
  • With level replication (if the transition results in learning at the same SCQF Level as previously achieved).
  • Fully credited (if the transition results in learning at a higher SCQF Level than previously achieved).

These descriptors are consistent with the new definition of articulation is being developed by the Joint Articulation Group.

4.3 - Provision

Intuitively, Student Success Officers^[114] appear to be a common-sense response to tackle some of the most pernicious challenges facing individual students and the tertiary sector as a whole, i.e., respectively, engendering a sense of belonging through person-centred interaction in a mass education system and reducing levels of early withdrawal from study. The work of Student Success Officers is also an exemplar of making more effective use of data analytics with resources that are already at our disposal. This is the type of intervention that would appear to be one that is worth adopting or adapting throughout the sector. However, before an argument can be made that institutions should commit staff resources to this work, there is a need for robust evidence of positive impact that could be used to justify investment.

More generally, although few would argue against investment in fair access, we have no clear understanding of the level of resource that is being invested, or needs to be invested, to achieve fair access. Although some budget lines are clear (e.g., SFC investment in the National Schools Programme, stipend for a Commissioner for Fair Access), there are many uncertainties and unknowns. It is not clear the level of resource that individual institutions are investing, either to finance their own widening access work, or to cross-subsidise external schemes when supplementary resources are required. It would be helpful to better understand the true cost of working toward fair access in higher education.

It would be helpful to appraise work within institutions that sustains fair access, appreciating that fair access should be concerned with entry, thriving during study, and successful outcomes. It would be helpful to better understand the nature of existing resource to support fair access work during study and to consider whether there would be merit in specifying a minimum offer of support, which should be available to students.

Similarly, SFC funding to support fair access to higher education undoubtably extends beyond its dedicated funding streams - such as the WARF (Widening Access Retention Fund), NSP (National Schools Programme), SCAPP (Scottish Community of Access and Participation Practitioners) and SWAP (Scottish Widening Access Programme). To understand the impact on fair access of how SFC disperses its funds would require an appraisal of the impact of core investment and dedicated funding streams. Notwithstanding this caveat, it would be prudent to appraise whether sufficient funds are being directed by SFC to its bespoke programmes to enable each to make an effective contribution to achieving the nation's fair access outcomes.