Commissioner for Fair Access: annual report 2025/26

5 - The Commissioner’s report card: reviewing previous recommendations and action points

5.1 - Holding the Commissioner to account

The initial response to my sixth report was positive, with reflections shared, for example, by the Scottish Funding Council,^[115] Universities Scotland,^[116] Colleges Scotland,^[117] the British Educational Research Association,^[118] and Wonkhe.^[119] The Scottish Government published a formal response in the Autumn of 2024,^[120] through which it committed to act on those recommendations within its remit, and offered support for all but recommendation six (The Scottish Government should consider strengthening the remit of the Commissioner for Fair Access to assume responsibility for advising on fair access to the whole of tertiary education).

5.2 – Review of the priority actions specified in 2024

Ten priority actions were specified in the last report. In practice, greater urgency was placed on following-up on the report’s twenty recommendations, although progress was also made on these priority actions. These are ordered below using a ‘traffic light’ system, from green (delivered) through amber (progress being made) to red (lack of progress).

“Green” priorities – delivered.

Priority 1. To follow up on each of my recommendations and to report on progress in my next annual report:

• Self-evidently, addressed in this report
• This will continue as a priority action, following up on the recommendations made in this report

Priority 7. To reflect on insight from the Student Finance and Wellbeing Survey commissioned by the Scottish Government, and the wider evidence base, to better understand how students’ financial situation impacts on fair access:

• Addressed in the second section of this report
• This priority action will be amended, with the focus on emerging intelligence on students’ financial situation.

“Amber” priorities – progress being made.

Priority 4. To engage with school leaders and universities in Scotland to explore whether inefficiencies in SCQF Level 7 can be addressed through system change and/or institutional practice:

• The issue has been raised when engaging with school leaders and when discussing the operations of the SCQF. Preliminary discussions have also taken place to discuss issues for specific subject groups, i.e., mathematics. However, more focused work is required before recommendations can be made, and there is a need to engage universities.
• This priority action will continue in its current form.

Priority 5. To engage with Universities Scotland and Colleges Scotland to better understand the prospects for increasing the proportion of HN students articulating with so-called ‘Advanced Standing’ into SCQF Level 8 and 9:

• Although this issue has been raised, in passing, when deliberating with Universities Scotland and Colleges Scotland, there is a need for more formal engagement on this issue, before recommendations can be made.
• This priority action will continue in its current form.

Priority 6. To examine retention rates for SIMD20 entrants, focusing on why these have not improved substantially since the introduction of the CoWA agenda:

• RoWA data have been analysed to better understand trends, and the issue has been raised when engaging universities. However, there is a need to draw together this evidence base to draw definitive conclusions and make recommendations.
• This priority action will continue in its current form.

Priority 8. To explore possibilities to enhance and promote regional intelligence, and to strengthen cross-institutional collaboration in regions to advance the fair access agenda:

• Background work has been undertaken to better understand the nature of existing regional collaborations. However, more focused work is required, before recommendations can be made.
• This priority action will continue in its current form.

Priority 10. To engage with professional bodies, Programme leads, and Heads of Department (or equivalent) to promote shared responsibility for the fair access agenda in Scotland:

• The issue has been raised when opportunities have presented to engage with professional bodies and university staff. However, more focused work is required before recommendations can be made.
• This priority action will continue in its current form.

“Red” priorities – lack of progress.

Priority 2. To produce a second annual report, to be published as soon as is practicably possible after the release of the SFC’s Report on Widening Access 2022-23:

• As explained in the Introduction to this report, it was judged counter-productive to publish this second report soon after the release of the RoWA from 2022-23.
• This priority action will be amended, with a commitment to publish the next report soon after the publication of the next RoWA.

Priority 3. To produce my first bi-annual report, ideally to be published at the start of 2025, i.e., halfway between annual reports, to provide a timely update on progress to promote fair access:

• As alluded to in the Introduction to this report, circumstances dictated that it was not helpful to publish an interim report.
• This priority action will be amended, introducing a commitment to publish briefings on specific issues of interest.

Priority 9. To review the deployment of contextual admissions and Minimum Entry Requirements across Scottish HEIs to appraise whether the impact on fair access is optimal:

• No work has been progressed on this issue.
• This priority action will continue in its current form.

5.3 – Review of the recommendations made in 2024

“Green” recommendations – achieved.

Recommendation 1. The primary focus for fair access should continue to be improving outcomes for those who experience or have experienced socio-economic disadvantage:

• Socio-economic disadvantage remains the primary focus of my work. There also seems to be agreement across the sector that socio-economic disadvantage should be the primary focus of fair access work in Scotland. There is an understanding that focusing on socio-economic disadvantage does not preclude action to improve outcomes for other disadvantaged groups. Indeed, due to the geographical concentration of some disadvantaged populations in disadvantaged areas, a SIMD focus can facilitate this. The focus of fair access work on socio-economic disadvantage has not precluded focused fair access work with other populations, for example, the former Minister for Higher and Further Education’s concern with rural access^[121], and the interest expressed by the Scottish Parliament’s Education and Young People Committee on access for disabled and BME students.^[122]
• Although achieved, this is an on-going ask and remains one of my recommendations.

Recommendation 2. Retain SIMD as the central metric to indicate national progress in achieving fair access:

• The sector continues to monitor the impact of its work using SIMD, and uses SIMD to help target activity. This has not precluded work that monitors fair access on other populations^[123] and has not precluded work to explore the prospects of adopting an individual/household metric to gauge progress.
• Although achieved, this this is an on-going ask and remains one of my recommendations.

Recommendation 4. Withdraw the SIMD institutional target but introduce a commitment from each HEI to take action to increase the proportion of SIMD20 among its entrants or, if this is demonstrably not possible without adverse consequences, to match the highest proportion and number of SIMD20 entrants that it achieved since 2013-14:

• As noted earlier, the Minister supports this action and has intimated that this should be introduced for academic year 2026-27.
• This recommendation will be amended with focus shifting to monitor the impact of the new approach.

Recommendation 20. Stakeholders and leaders should reaffirm their commitment to promote fair access and commit to take those actions necessary to attain the next interim target for 2026:

• The actions reported in the opening substantive section of this report affirms the on-going commitment of a wide range of stakeholders to achieving fair access. However, it should not be assumed that this commitment will continue. First, there will be a new Scottish Government following the parliamentary elections in 2026. Second, many HEIs have new leadership (Glasgow, Strathclyde, Glasgow Caledonian, Napier, Open), as has Colleges Scotland. There is a need to ensure that the strong commitment of education leaders to fair access continues.
• Although achieved, this is an on-going ask and remains one of my recommendations.

“Amber” recommendations – progress being made.

Recommendation 3. To strengthen the utility of SIMD to understand fair access, SFC and institutions are encouraged to report evidence in deciles up to SIMD40, in addition to quintiles:

• As noted earlier, the inclusion by the Scottish Funding Council of an SIMD decile table in the RoWA has enhanced our understanding of fair access. Next step is to review the extent to which this granularity of analysis is informing the work of individual HEIs.
• This recommendation will be amended to acknowledge that it has been actioned by SFC.

Recommendation 7. The Scottish Government should take the necessary preparatory steps to embolden the fair access agenda beyond 2026 by transitioning toward individual-level indicators of socio-economic disadvantage, and thereafter to challenge institutions to achieve fair access for prospective students who have experienced such disadvantage:

• As noted earlier, the options for transitioning to an individual-level indicators of socio-economic disadvantage are being appraised, with bi-monthly meetings to discuss developments.
• This recommendation will continue in its current form.

Recommendation 8. The fair access agenda should be recalibrated to give equal weight to entry, student experience, and outcomes.

• There is much evidence of the work being undertaken after the point of admission to sustain fair access. This has been reviewed on an ad-hoc basis. Next step is to undertake a more robust and systematic appraisal of what constitutes good fair access practice that leads to successful outcomes for student experience and outcomes.
• This recommendation will continue in its current form.

Recommendation 9. The primary focus on fair access should remain on Scottish-domiciled, full-time, first-degree entrants. However, for a rounded perspective on fair access to higher education, it is necessary to also focus on Graduate Apprenticeships, part-time undergraduate study, and postgraduate study:

• As noted earlier, some preliminary work has explored fair access in some parts of postgraduate education. More focused data analysis is also providing insight into entry and retention for Graduate Apprenticeships and part-time study. Next step is to draw together this evidence and intelligence to develop a case for a less limited focus on fair access to higher education.
• This recommendation will continue in its current form.

Recommendation 12. SFC should act on the advice of the previous Commissioner for Fair Access, specified as a recommendation in each of his last four annual reports, to commit to more secure and longer-term funding for SCAPP:

• There is growing recognition across the public sector that multi-year funding settlements are both more efficient and more equitable, with the Scottish Government piloting multi-year funding settlements to support third sector organisations providing essential services and tackling poverty.^[124] I have raised the issue in meetings with the Skills, Enhancement, Access and Learning Committee (Scottish Funding Council), and although unable to commit to this due to how the block grant from Scottish Government is received, the Committee expressed support in principle.
• This recommendation will continue in its current form.

Recommendation 13. It should be re-affirmed that the central purpose of SCAPP is as a vehicle to support the development and professionalisation of a widening access and participation practitioner community in Scotland:

• SCAPP continues to promote the development and professionalism of the access and practitioner workforce in Scotland, and to engage with similar bodies outwith Scotland. The importance of SCAPP in promoting fair access seems to be acknowledged by other stakeholders (notably the Minister delivered the keynote address at the SCAPP annual conference in 2025, and the SFC continues to provide financial support). The work to support the evaluation capacity within the community Is welcomed, and does not detract from the core purpose of delivering fair access as practitioners.
• This recommendation will be amended to focus on monitoring rather than re-affirming the purpose of SCAPP.

Recommendation 14. SFC, in conjunction with SCAPP, Universities Scotland and the wider educational research community in Scotland, should examine what steps should be taken to strengthen research and evaluation to underpin the fair access agenda:

• Significant developments include the commencement of a second SCAPP Evaluation Community of Practice in 2025,^[125] the recommendations to strengthen evaluation in SFC’s review of the National Schools Programme,^[126] and the establishment of links between SERA and SCAPP, which was referred to earlier in this report.
• This recommendation will be amended to focus on monitoring the breadth of evaluation activity and the impact of evaluation activity.

Recommendation 17. School leaders in Scotland, the SFC and its National Schools Programme, SCAPP and Universities Scotland should examine if, and if so what, steps should be taken to underpin the fair access agenda within the broad general education phase in Scottish education:

• The extension of the Young Strathclyder programme is a welcome development. More generally, this issue has been raised when opportunities have presented to engage with school leaders in Scotland. Next step is to engage more stakeholders and to glean understanding from the national review of fair access work that will be commissioned by the Robertson Trust/Carnegie Trust for the Universities of Scotland.^[127]
• This recommendation will continue in its current form.

Recommendation 18. SFC, Universities Scotland and Skills Development Scotland should examine the prospects of introducing an easily accessible user-centred web-based resource that provides a single point of reference to inform prospective students and other stakeholders of the programmes and resources that are available to support access to higher education.:

• Those responsible for the Pathways resource,^[128] have engaged Skills Development Scotland and Colleges Scotland to explore the possibility of developing this resource by embedding/integrating within My World of Work^[129]. Next steps are to monitor developments, and continue to explore whether this can be developed into a national resource.
• This recommendation will continue in its current form.

Recommendation 19. Stakeholders should explore the prospects for introducing a single student identifier to improve tracking and to facilitate more robust evaluation of the impact of fair access activity:

• As noted earlier, this is one of the priority actions that is discussed at the tripartite meetings (Commissioner, SFC and Scottish Government). Work should continue to scope possibilities, and to engage the school sector to explore how such a resource could serve the whole education system in Scotland. Next steps are to implore decision-makers to commit resource to deliver on a single student identifier that serves the best interests of Scotland, and education in Scotland.
• This recommendation will continue in its current form.

“Red” recommendations – no or little progress.

Recommendation 5. For universities in Scotland to collectively specify a basket of indicators from which individual HEIs may draw to demonstrate their wider work in promoting fair access:

• No work has been progressed on this issue. Discussions with Universities Scotland focused on the transition to an institutional target (recommendation 4): now that this has been progressed, attention will be given to this issue.
• This recommendation will continue in its current form.

Recommendation 6. The Scottish Government should consider strengthening the remit of the Commissioner for Fair Access to assume responsibility for advising on fair access to the whole of tertiary education:

• The Scottish Government was not minded to accept this recommendation. However, it is my firm belief that the future of fair access should adopt a tertiary perspective. Notably, this was also recommended in Widening Access to Higher Education – the report following the inquiry of the Scottish Parliament’s Education, Children and Young People Committee. Next steps are to strengthen the case. It will remain a recommendation, although the Scottish Government is not expected to respond to this, until the supporting argument has been developed.
• This recommendation will continue in its current form.

Recommendation 10. Wherever practicable, data on fair access should be disaggregated to understand the relative contributions of different pathways (direct entry from school; articulation; and adult wider access):

• This recommendation was not pursued while the Joint Articulation Group reviewed the definition of articulation and the Scottish Funding Council completed its review of the National Schools Programme. With the conclusion of these reviews, attention will now be paid to this issue.
• This recommendation will continue in its current form.

Recommendation 11. SFC, in conjunction with participating universities, should ensure that disaggregated data are available for each of the disciplines that comprise the ‘high demand professions’ that are part of the AHDP programme (to enable the national impact of this work to be appraised) and the Transitions programme:

• As for recommendation 10, this was not pursued while Scottish Funding Council completed its review of the National Schools Programme. With the conclusion of this review, attention will now be paid to this issue.
• This recommendation will continue in its current form.

Recommendation 15. For universities in Scotland to collectively agree what intelligence is in the national interest to promote fair access (as opposed to that which is commercially sensitive), and thereafter to ensure that this intelligence is made available to all relevant stakeholders in Scotland:

• No work has been progressed on this issue. Next step is to provide greater clarity over the nature of this specific ask, before progressing with this issue. The initial focus will be on pooling intelligence from exit surveys of those electing not to progress to the next level of study.
• This recommendation will continue in its current form.

Recommendation 16. Should the decision be taken to withdraw funding for an intervention that had been integral to promoting fair access, or if an element of such work is to be radically altered, providers should undertake (and funders should encourage) an impact assessment to ascertain the impact on pupil cohorts who have previously benefited from this provision:

• To the best of my knowledge, no new notices have been served since the publication of my last report of funding being withdrawn for any fair access programme. However, Glasgow Caledonian University intimated its intention to discontinue with Routes for All, which was a programme delivered for Focus West (the SHEP partner serving the west of Scotland). Next steps will be to consider the impact of the withdrawal of this provision on S5 and S6 pupils who were considering study Higher National Courses at college.
• This recommendation will continue in its current form.