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AOR review consultations and data experiments

The consultations are now closed. Initial outcomes were announced on 23 November 2023 along with a timescale for future announcements:

Aggregate Offshore Record consultation - initial outcomes

Our summary of responses to the consultations can be found here:

AOR major review and Student record expansion for England and Wales - summary of responses

AOR major review for Scotland and Northern Ireland - summary of responses

The Office for Students has published its own response to the consultation for providers in England.

Please contact [email protected] if you have any queries or feedback

AOR review webinar

Question: Will you be sharing the slides? 

Answer: Yes, we will be sharing them after the event. 

Question: Good to have the regulator for HE in Wales here today, were OfS invited to attend as I'm sure there might have been a few questions surrounding data burden. 

Answer: Yes all were invited, but given it was very specific dates not everyone could make it. Any questions directed to the regulators will be passed on to them after the session. 

England/Wales Proposal 1 

Question: With a full Student record being required for partnership students, would this be all fields of the Student record, or a reduced return as is required for (e.g.) incoming exchange or dormant students in the Student record? 

Answer: This will be a full Student record return (including some new data items as specified in the consultation). 

Question: Will students returned in the ILR to the ESFA no longer be returned in the Data Futures Student record? 

Answer: Any students that are currently returned in the ILR, should remain in that return. We mention the ILR when talking about the partnership students - but only covering students that are not already being returned. 

Question: We don't fully understand the definition for Proposal 1. Please can we have some scenarios describing this (the scenarios currently provided are all for TNE: "students studying in the UK that are taught by the reporting provider or studying for an award of the reporting provider, but are not registered by the reporting provider"). We have some of these, (eg pre-sessional language courses) but they are not part of partnerships. 

Answer: When drafting the consultation, we found the scenarios we were put together were too generic to be helpful, which is why there aren't any included.  

Example in Wales: FE college has a specifically designated course that is not currently returned (not regulated by HEFCW or returned in the LLWR), though most of these will be returned by the FE College in future. 

Post session answer: Example in England: A OfS registered university is the awarding body for a college that is not registered with the OfS or an OfS registered provider is teaching students on behalf of another provider who is not registered with the OfS. 

Question: Would the expansion of the record mean that we would need to return data for students who are not studying for provider credit or award bearing? 

Answer: The general coverage statement in the Student record would still apply here: so if the students are not studying for an award or credit, they would not be required in the return. 

Question: Are there scenarios for what data needs to be collected for UK partnerships where your organisation is the awarding body of a validated partner who has not submitted data to HESA in their own right? 

Clarification from attendee: A partner owns the programme, we validate it, the partner is in the UK and registered with the OfS in their own right. We don't register the students, but simply award the degree. I don't think that partner returns data to HESA. Who's responsibility is it for returning the data? If it's us - what data do we need to return? 

Post session answer: If the students are registered with a provider that is registered with the OfS in their own right then they will be required to return data to HESA or the ESFA, through the ILR. As a result you will not need to return the students in your HESA return. If the provider is not registered with the OfS then the proposal is that you would need to return these students, as they would not be returned by the partner provider. 

Question: If a partnership student is not currently reported to HESA because they are not studying at the required HE level, does this change? 

Answer: The level of study and who we want in the Student record does not change - so if they are outside this, the proposals in this consultation would not include them. 

England/Wales Proposal 2 

Question: Would there be an option to return all the same data fields as our normal students returned in the HESA return? It might be easier for us to treat them the same as all others rather than separate them. 

Answer: We can't collect more data than we require - so it likely we won't allow a full return where that isn't needed (particularly the personal characteristics and equality data fields). This is something we can explore further and include this in the review outcomes. 

Question: For students that move between the UK and overseas over the course of their studies, will the "rule" that once you're in the Student return you need to stay in the Student return for the entire engagement still apply? i.e. no TNE reduced return after they've been in the standard population in a previous return? 

Answer: This was something we discussed during our investigations, but struggled to make a robust enough mechanism to allow this. It is something we'd like to revisit, perhaps with a group of providers who have a lot of these examples. For now, the current guidance will remain - once you're submitting the full return then you have to continue submitting the full return. 

Question: Just to clarify - if the TNE data is collected once a year, would that still be a separate "AOR" return (or would it form part of the Student return, just on a different timeline)? 

Answer: The proposal is that the TNE students in England and Wales would join the Student record. So if it's collected once a year TNE students would be in one of the reference periods only and not appear in the other. This would then have consequences in terms of the period of activity being returned for TNE students in that reference period which would need to be worked through.  

This question is included in the consultation because we'd like to understand if this approach is preferable to providers (but requires them to remove students from one return), or if including all the students together in both returns would be better. 

Question: If we are going to be returning the in-year in 2024/25 and having to plan for AOR being in Student in 2025/26 will HESES still be required in 2024/25 as there will be considerable burden in getting this ready and then also resolving HESES as resources limited at regular institutions. 

Post session answer: The OfS are considering the shape of the HESES return as we move towards in-year data collection. It is too early at this stage to provide details of what that this will look like, but they will make sure that they keep the sector informed and they will consult on any major changes to HESES or the funding method. 

Question: Is the intention that TNE students just form a part of the main HESA return(s) rather than a separate return as it does now? 

Post session answer: Yes that is the intention behind the proposal for England and Wales. 

Question: If the general consensus is for TNE students to be collected once a year instead of twice, would the reporting period cover the entire year (i.e. 1st August - 31st July) or would it be for just one of the reporting period (i.e. 2nd December - 31st July)? 

Answer: If TNE data is collected once a year, this would be for the full reporting period, covering 1 August - 31 July. 

Question: Do we have any idea of how the OfS will apply definitions of Continuation and Completion to TNE students? Will the definitions be the same? (Knowing that the data for TNE students is lagged) 

Post session answer: The OfS plan to consult on the definitions and thresholds in due course. Details of this were set out in pargraphs 108-111 of the OfS's Student Outcomes consultation ( 

Question: Love the supporting definitions. Really helpful! One that I've come across is when a partner uses a hub approach to deliver to students in multiple countries, e.g. students might study by distance learning through a partner organisation but fly in to somewhere like Trinidad from other Caribbean islands for face-to-face sessions run by the university or the partner. The partner may or may not be a Trinidadian organisation! These students are often very geographically mobile (so might study by distance learning in multiple countries). I'm struggling how to see the students would be returned in this case. Any ideas? 

Post session answer: we will need more details on this in order to answer, for example how often are the face to face sessions happening? Not every example is covered in our scenarios as we have focused on the main ones, so it may be that your example sits outside of that. 

Question: If you are delivering a programme at a physical location owned by a Partner but that partner has no involvement in teaching and assessing the programme. Which scenario do they fall under? 

Answer: There isn't quite enough information here to place this into one of our scenarios. The scenarios don't cover absolutely all the cases, just some main ones. 

England/Wales Proposal 3

Question: Will the field definitions for the AOR data be the same as for Data Futures data, where applicable? 

Post session answer: yes all the field definitions are intended to remain the same as the Student record. Where there are any variations this would be mentioned in the AOR consultation. 

Question: Will you do a SID for students who started prior to 2022/23 or HUSID? 

Answer: For any new students we expect this to be SID. If the current guidance was followed any continuing student with a HUSID could be returned with that, but we won't have seen these HUSIDs in our returns and so validation rules will trigger. Please could providers include how many students they might want to return HUSIDs for in their consultation response, and that will allow us to assess the scale of this question. 

Question: Will you not be collecting modules and module instances for TNE students? 

Answer: We will not be collecting any data on modules or module instances as there was no statutory requirement to do so. 

Question: The concept of mode of study differs around the world with different partners/countries having definitions that don't fit with the way we would normally apply those to UK based students. How will this be recognised and/or adapted into these proposals? 

Post session answer: We suggested these are categorised using the regulators definitions where possible, and if not, as best they can recognising that it may be the best guess in some cases. For example, using time to complete 3 years for a degree as full-time, anything more as part-time. Some examples of this would be welcome in the consultation response if you believe it is going to be a significant problem. 

Question: The academic years of our partners do not routinely follow the UK model. We have programmes starting every month of the year which means that most cross the artificial "HESA academic year". This also means that for a lot of our partners they can start and delay and, in effect, move to a later cohort. We're concerned that there will be overly burdensome reconciliation required at submission time to explain the (seemingly) mass movement of students. 

Answer: We are not expecting TNE student data to look the same as the UK students. The Data Futures model is designed to allow for different start dates throughout the year and not force a fit into the HESA reporting year. However, you may still get changes if there are movements with study patterns, as you will with the rest of the Student record. Please do include examples in your consultation if you are particularly concerned about this, or email Liaison. 

Question: As information on a student's change in status is held by our overseas partners, there is often a delay in when we are notified of a change. Will there be a tolerance for this if we have to submit a session status change with a backdated date? 

Answer: As with the Student record, if you don't know that information, then you can't return it to us. When you do know the information then please include it. You will likely trigger a rule, but until we start seeing data (or understand the scale of this) we can't make amendments to the rules as yet. This is something we will be looking at over time (for Student as well as when TNE students join the record). 

Question: What is the point of asking for STUDYABROAD for TNE students - if they aren't studying abroad they aren't TNE? 

Answer: Agree that this is a bit of reverse logic as the STUDYABROAD flag would actually be the UK time for TNE students.  

Post session answer: Students could also be studying abroad and doing a study period in another non-UK country. For example, the campus is in Asia, but the study abroad is in Europe (outside the UK). Regulators currently don't see any value in this data, so responses in the consultation will be key to understanding if this will be considered. 

Question: You say that this won't add to the burden for students who are already in coverage. How will we identify partnership students who will need registration details, given that there is no proposal to give them their own flag? 

Post session answer: this can be derived from the proposed Registration entity - if the organisation identifier is not the reporting provider then we know it's a partnership student. 

Question: At the moment we don't have to return the course role proportion which relates to the delivery which we undertake, only that undertaken by another provider. Once the country flag is added to the course role entity will that mean that by default we have to return our proportion as well, given that our provision could be undertaken in this country or abroad? If so, will that only be the case for TNE students or will it also apply to those students already in coverage? 

Answer: We weren't intending to add any more reporting requirements to the existing Student record, but we haven't yet considered the guidance on this. It was intended that only TNE students would be required to return the new country fields. 

Post session answer: we can use the TNEFLAG to identify when these course role or country fields will be required for TNE students. 

Question: Will all the new country fields apply only to TNE students? If so, that means that we will be providing more information about those students than we do about the abroad study periods for current PRINONUK students. Is that deliberate? 

Answer: Yes the new country fields are only applicable to TNE students, because other identifiers aren't relevant overseas. 

Question: What happens where the 'hub' is in UK for a short time i.e. 4 days? 

Answer: The coverage for completing a full Student return states the student will "spend more than 8 weeks in the UK", so where the study is only for a few days they would remain on the TNE level of data. 

Question: You've just mentioned that you're not interested in the country in which a distance learning student is studying (in the question about the hub scenario) but you are asking for the country in the study location entity for those students whose DISTANCELEARNING flag is 02. 

Answer: The country field captured in the StudyLocation entity would be required for distance learning students. 

Question: Think the issue is most software providers still tie the data together using the concept of an academic year. 

Answer: We have a Teams group set up with software suppliers (and those with in-house systems) to discuss things together and offer support where we can. 

England/Wales Proposal 4 

Question: A non-mandatory trial please, simply just opening up the HDP for this would be perfect 

Answer: Yes, this is something we could consider if providers would find that helpful. 

Question: Will there be an opportunity to trial the enhanced submission of AoR data prior to the full launch in 2025 in the same way as we have had for the Data Futures return? 

Answer: This isn't something we had considered, but if providers would find this helpful we could look into it. 

Question: Would there be any consideration given to starting with one return a year when the changes are rolled out and review this later as to whether two returns a year would work? We may benefit from seeing how the move to two reference periods for Data Futures Student works fully first before moving into 'AOR' as well. 

Answer: This could be a potential option to consider - please include this in your consultation response if this is something that would of benefit to you. 

Northern Ireland/Scotland Data Items 

Question: What impact do you expect on the Student return as some of the fields are already in use but slightly different in that return i.e. course role. 

Answer: We don't want to make any changes to the data items required for students currently within coverage of the Student return. 

Question: What onward use do you expect with Venue name if we cannot get consistency cross sector? 

Answer: This is something we recognised when developing the proposals to include organisation name. We know that free text fields aren't an ideal way to collect data, but we struggled to identify an alternative that would not create a significant amount of burden. We would welcome suggestions for alternatives. 

Question: Are programme type and provision type the same thing? languge changes throughout. 

Answer: Believe we did mean the same thing here. Programme type and venue type will be the names for the new fields. 

Consultation itself 

Question: Is the expectation that there is one consultation response per institution? 

Answer: Ideally yes, one per provider please. However, you can add an additional response flagged an individual if you would like to. 

Question: Are software suppliers allowed to respond to this consultation? Our answer to whether we'd prefer one return or two depends entirely on what our software supplier could manage! 

Answer: Anyone can respond to the consultation, yes. We understand that some sector organisations are also considering responding. 

Question: Is it a single response per institution or a response per type of role at an institution? 

Answer: Ideally one per provider please. However, you can add an additional response flagged an individual if you would like to. 

Question: Whilst you say that Scotland/Northern Ireland can provide feedback on the England/Wales model if we were to aim for UK-wide parity - is the converse true in that England/Wales might opt to contribute to this consultation and aim for maintaining an aggregated return? 

Answer: We would allow providers in England / Wales to respond to this consultation but, given there is a requirement for individualised data, we have not encouraged this as there is not an option to remain as aggregate in those countries. 

Related content

AOR major review supporting definitions and scenarios

AOR major review project mandate and steering group

Consultation (closed): AOR major review and Student record expansion for England and Wales

Consultation (closed): AOR major review for Scotland and Northern Ireland