Speaking at the UKCISA 2026 conference in Glasgow, Sanjay Parmar, Immigration Supervisor at Fragomen LLP, warned that while recent compliance changes might look simple on paper, in practice they represent “a bigger shift” in how the system behaves and how institutions must operate within it.
Compliance, he stressed, “is obviously no longer a technical compliance issue. It’s clearly becoming a strategic institutional risk for the institution”.
He stressed the need to move away from treating the Basic Compliance Assessment (BCA) purely as a numerical hurdle. While the 5% visa refusal threshold has drawn sector-wide attention, he cautioned that “it’s not really about sitting at 5%”.
Instead, institutions that are coping best are “building that platform to 4% or lower” and treating refusal, enrolment, and completion metrics as part of a live, whole-journey risk picture. He argued that institutions must “understand your whole journey and how you position yourself as an institution, and it’s not just about that one metric”.
Parmar argued that risk often builds “quite quietly in the background”. What causes trouble, he said, is limited visibility, inconsistent decisions, and disconnected teams.
Many institutions are still relying on “disconnected systems and spreadsheets”, which means they only discover issues through “retrospective reporting, which is what you don’t want to be doing”.
The moment you sign a CAS, you’re effectively accepting that riskSanjay Parmar, Frangomen
Instead, he called for a more “live view of where you sit as institutions”, with better use of core student record systems.
Evidence collection was described as critical, not optional. Parmar urged institutions to gather and file documentation on withdrawals and visa-related changes as early as possible.
Without it, when problems do arise, institutions can find themselves scrambling: “We’ve had to help institutions in the past try and balance information if they’ve been in trouble,” said Parmar.
Stronger providers, by contrast, are already “looking at trends, where is the pressure building, where have issues come up before, and… what’s that going to tell them about what’s coming next,” he added.
CAS issuance was singled out as the key control point in the student journey. Parmar told delegates: “The moment you sign a CAS, you’re effectively accepting that risk.”
He called for more strategic, structured approaches to credibility interviews and pre‑CAS checks, noting that across the sector there is still “inconsistency about who, for example, gets interviews, what the criteria are, how outcomes are recorded, how concerns are escalated”.
Another tension he highlighted was the balance between compliance and broader institutional priorities. Institutions are not only thinking about visas; they are also “quite rightly balancing academic judgment, fairness, experience, retention, revenue, reputation”, he suggested.
Parmar noted that the risk under the new BCA framework is that many small, individually reasonable decisions – “late arrivals or large new enrolments”, or generous exceptions – can, when multiplied across departments, “quietly shift your enrolment and completion rates and outcomes”.
To address this, he pointed to good practice such as “setting up small review groups or panels” to handle difficult cases consistently, and urged institutions to ask, “Are you being too harsh? Are you getting rid of students too quickly? What can you do to try and minimise those students that leave?”.
