Quick guide to the consultation on new registration conditions
Part 3: Applying to register
The third part of our consultation seeks views on proposals for new registration application requirements.
We are making these proposals so that we can register well-prepared providers efficiently and without unnecessary delays.
The proposals encourage high quality applications and make it easier to refuse incomplete applications.
We are also proposing to require more information about a provider's financial readiness to address the increased challenges facing the sector.
What are we proposing?
Requirements for a registration application
We are proposing new requirements for registration applications. Our aim is to support providers to submit high quality applications which contain all the information we need when they first apply.
The requirements include new information that providers would need to submit if we adopted the new proposed initial conditions of registration relating to treating students fairly and effective governance.
A provider’s application would need to meet these requirements, or its application could be refused. This is a change to the current application process.
To support providers seeking registration, we propose to offer a pre-application virtual meeting. This would signpost the provider to our registration guidance and give an opportunity for it to ask questions.
Financial information
We are proposing that a provider submits financial scenario modelling as part of its application to register.
This would take the form of an additional financial table, and associated commentary and mitigations.
These would model different scenarios that we specify (for example, less favourable levels of student recruitment) and their impact on the provider’s financial viability and sustainability.
A provider will also need to ensure it has given us all the information and documents we need to assess their financial viability and sustainability at the point of application.
We are proposing that a provider should submit updated financial tables towards the end of the registration assessment. This will make sure our final financial assessment is accurate and up to date.
We are proposing that a provider should submit audited financial statements for any financial years that are completed during the registration assessment, within nine months of the financial year end.
Ownership and corporate structure information
We are proposing that a provider should submit a diagram showing its corporate structure and ownership with its registration application.
Disclosing investigations
We are proposing that a provider must inform us of any investigations it has been subject to during the 60 months preceding its registration application. This is so we can understand their impact and whether they are relevant to our assessment.
We also set out how we would treat a situation in which a provider submits an application while it is subject to an ongoing open investigation.
Reporting changes
We are proposing that a provider must proactively report certain listed matters that may affect its registration assessment during the registration process, including:
- a change to the provider’s ownership or legal form
- a merger with another registered or unregistered provider
- a change to the provider’s partnerships or awarding arrangements
- a change in the set of governing documents it submitted as part of its application
- the opening of an investigation
- withdrawal of financial support underpinning its financial viability and sustainability.
Resubmission restriction
We are proposing to introduce a restriction preventing a provider reapplying for registration within 18 months of having a previous registration application refused.
We feel that 18 months gives a provider time to implement changes to address the issues in its previous application, and to demonstrate that the changes are effective and sustainable.
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