The Scotland Act 1998 (Agency Arrangements) (Specification) (Recognition of Qualifications) Order 2025 Equality Impact Assessment

Stage 2: Data and evidence gathering, involvement and consultation

Data and evidence gathering for the EQIA has been challenging, as there is very limited data available in relation to the UK ENIC services in respect of Scottish users and their protected characteristics. The majority of those for whom the service is accessed are individuals applying to study at Scottish universities who have qualifications from abroad, most of whom are assumed to be abroad at the time of their application. Whilst we have equality data for students offered places, no such data is collected for those students who apply but are not offered a place (in respect of UK ENIC services are also likely to have been used).

A trawl of UK Parliamentary Questions did not suggest any issues in the service in relation to equality.

The vast majority of access to the databases are not recorded by Ecctis Ltd as they are made through subscribers checking qualifications for themselves; Ecctis Ltd has no data on the individuals in respect of whom these checks are made. For those individuals accessing the service directly, the current contract (from 28 March 2025) requires only the collection of age, gender and nationality. Over the three years 2022 to 2024, just under 1,300 individuals resident in Scotland made applications for statements of comparability from the UK ENIC services. This represents a very small fraction of the estimated many thousands of people on whose behalf the service was accessed by an organisation.

A narrative of our findings is set out below, alongside the small amount of data for the specific characteristics we have been able to identify.

Scottish higher education institutions are all subscribers to the UK ENIC services and use it heavily as it is an essential tool for admissions teams in assessing the comparability of overseas qualifications, principally for students applying from abroad. The UK ENIC services might be expected to help to promote diversity in undergraduate and postgraduate populations. Equality data for international students is set out in the table below.

Only some colleges are subscribers; again, the UK ENIC services might be expected to help promote diversity in the college student population.

SDS careers service advisers use the services to support individuals in Scotland to move toward study or work. They take referrals of refugees from the Scottish Refugee Council and the service assists this vulnerable group with the comparability of their overseas qualifications. The data they have is set out below.

Age

Evidence gathered

From the data available to us at this time, we have no evidence of young people under the age of 18 accessing this service directly as individuals. However, we estimate that there were 16,000 overseas applicants to Scottish universities for full-time first degree courses starting in academic year 2024-25, in respect of whom the UK ENIC services are highly likely to have been used when (see below) some of these were aged under 18. A similar pattern of use is likely to occur under the Scottish ENIC legislation. (source: UCAS Undergraduate end of cycle data resources 2024 | Undergraduate | UCAS)

In AY 2022-23, 635 (7%) out of the total 8,980 international entrants on undergraduate courses to Scottish universities were aged 17 and under, and 415 (5%) aged 30 and over. For the whole undergraduate entrant cohort, 15% are aged 17 and under while 23% are aged 30 and over. (It should be noted that international students do not necessarily have overseas qualifications, as international students can sit A-level or UK equivalent exams before applying to UCAS.)

(source: HE Student Data | HESA)

SDS careers service data indicates that, of the 1,136 individuals in respect of whom they accessed UK ENIC services between 2022/23 and 2024/25:

• 106 were under 18 years old,
• 91 were 18 to 20 years old; and
• 939 were 21 years old and over.

(source: Skills Development Scotland Careers Services)

Whilst some unaccompanied child refugees aged 16 or 17 years old attend college to address language skills, there is no confirmed use of the UK ENIC services in respect of this group.

Data gaps identified and action taken to address the data gaps

Apart from university admissions data, which reflects the significant majority of organisations with UK ENIC services membership in Scotland, we have been unable to access any statistical data on the age of UK ENIC users.

The available evidence suggests that there is a lesser diversity of age in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) than in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Disability

Evidence Gathered

In AY 2022-23, 875 out of the total 8,980 international entrants on undergraduate courses to Scottish universities declared a disability^[3]. This is 10% of the international entrants and compares with 20% for all entrants on undergraduate courses. (source: HE Student Data | HESA)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a smaller proportion of people with disabilities in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) than in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Sex

Evidence gathered

In AY 2022-23, out of the total 8,980 international entrants on undergraduate courses to Scottish universities 3,790 were male, 5,115 female and 10 other^[4]. This means 57% of the international entrants were female and compares with 60% for all entrants on undergraduate courses. (source: HE Student Data | HESA)

SDS Careers service data indicates that, of the 1,136 individuals for whom they accessed UK ENIC services between 2022/23 and 2024/25, 695 were female and 412 male. (source: Skills Development Scotland Career Services)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a slightly smaller proportion of women in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) than in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Pregnancy and Maternity

Evidence gathered

In AY 2022-23, out of the total 8,980 international entrants on undergraduate courses to Scottish universities:

• 120 had young people/children dependants; and
• 75 both young people/children and relatives/friends dependants^[5].

This means 4% of the international entrants had some form of dependents and compares with 13% for all entrants on undergraduate courses, where dependant status is known. (source: HE Student Data | HESA)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a much smaller proportion of people with dependents in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) than in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Gender reassignment

Evidence gathered

In AY 2022-23, 75 out of the total 8,980 international entrants on undergraduate courses to Scottish universities were transgender^[6]. This means 1% of the international entrants were transgender and compares with 1% for all entrants on undergraduate courses, where gender reassignment status is known. (source: HE Student Data | HESA)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a similar proportion of transgender people in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) as in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Sexual orientation

Evidence gathered

In AY 2022-23, out of the total 8,980 international Entrants on Undergraduate Courses to Scottish Universities:

• 710 were bisexual
• 165 gay or lesbian
• 5,450 heterosexual / straight; and
• 165 of other sexual orientation^[7]

This means 16% of the international entrants were other than heterosexual / straight and compares with 16% for all entrants on undergraduate courses, where sexual orientation is known. (source: HE Student Data | HESA)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a similar proportion of people whose sexual orientation is other than heterosexual / straight in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) as in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Race

Evidence gathered

Skills Development Scotland (SDS) provide support for individuals from abroad, including refugees through their careers service.

UK ENIC services support refugees and those in refugee-like situations. Applications are treated with additional discretion as it is understood that applicants may not be able to provide all of the documentation that is usually required.

India, Hong Kong and Nigeria had the highest volumes of individual applications to the UK ENIC services between January and June 2022. There is no reporting as to whether these applications relate to individuals looking to work or study in Scotland or elsewhere in the UK. (Source: UK Enic Summary Trends & Themes)

In terms of HESA data, ethnicity is not collected in respect of international students.

SDS career service data indicates that of the 1,136 individuals for whom they accessed ENIC services between 2022/23 and 2024/25, 291 were refugees/asylum seekers, 250 were from Ukraine and 6 from Afghanistan. Of the 291 refugees/asylum seekers:

• 41 were less than 18 years old;
• 23 were 18 to 20 years old; and
• 223 were 21 years old and over.

(source: Skills Development Scotland careers Services)

Data gaps identified and action taken to address the data gaps

Whilst the evidence shows that the UK ENIC services help individuals living in Scotland from different ethnic backgrounds, in particular refugees, to access education/employability services, and also those from abroad to access Scottish universities, there is no baseline data with which to make comparison. In any case, the Scottish ENIC legislation should not have any direct impact on these groups.

Religion or belief

Evidence gathered

In AY 2022-23, out of the total 8,980 international entrants on undergraduate courses to Scottish universities:

• 225 were Buddhist (3%)
• 1,470 Christian (23%)
• 475 Hindu (7%)
• 60 Jewish (1%)
• 740 Muslim (11%)
• 35 Pagan (1%)
• 105 Sikh^[8] (2%)

This compares with the following percentages for all entrants on undergraduate courses:

• Buddhist (1%)
• Christian (30%)
• Hindu (2%)
• Jewish (0%)
• Muslim (5%)
• Pagan (0%)
• Sikh (0%),

of those where religion or belief is known.

(source: HE Student Data | HESA)

Data gaps identified and action taken to address the data gaps

The available evidence suggests that there is a greater diversity of religion or belief in the international student entrants on undergraduate courses (of which a high proportion are likely to have been direct or indirect users of UK ENIC services) than in the cohort as a whole. However, the Scottish ENIC legislation should not have any direct impact on these groups.

Marriage and civil partnership

Evidence gathered

There is no requirement for the Scottish Government to provide EQIA assessment against this protected characteristic.

Data gaps identified and action taken to address the data gaps

No available data.