UK issues new guidance for universities to assess risks in overseas partnerships

The UK government has issued new guidance asking education providers in England to take a more systematic approach to assessing risks associated with international partnerships and overseas operations. The framework covers collaborations with foreign universities and organisations, transnational education (TNE), joint research, qualification licensing, student and staff mobility, and the delivery of education services abroad.

Published by the Department for Education (DfE) on November 11, the guidance sets out how institutions should conduct due diligence before entering into partnerships, identify potential legal and operational risks, protect staff and students, and maintain oversight after an agreement has been signed.

The framework comes as the UK seeks to expand its international education presence. Its International Education Strategy 2026 aims to increase the value of education exports to £40 billion annually by 2030. The government has also acknowledged that overseas delivery and international partnerships can expose institutions to financial, legal, security and geopolitical risks.

The guidance does not seek to discourage international collaboration. It says most partnerships are legitimate and beneficial, and that enhanced scrutiny should be proportionate to the scale and nature of an activity, the partner involved and the environment in which it operates.

Five areas of risk for international partnerships

The DfE identifies five broad dimensions that institutions should consider when evaluating overseas arrangements: security, political and values-related, commercial and legal, safety, and geopolitical risks.

On security, providers are advised to consider whether a partnership could give an overseas entity access to institutional systems, sensitive information, research, technology, intellectual property or networks. They are also asked to examine whether state-linked actors could use a relationship to influence institutional decisions, obtain sensitive knowledge or monitor individuals.

The political and values-related assessment includes the local environment for freedom of speech, civil liberties, human rights, equality, academic freedom and institutional autonomy. Providers should consider whether censorship, compulsory curriculum requirements or restrictions on discussion could conflict with their own legal obligations and academic standards.

Commercial and legal checks should cover the stability and enforcement of local laws, contract terms, licensing requirements, taxation, intellectual property, currency controls and the ability to recover money or assets if a partnership breaks down.

The safety assessment focuses on risks to staff and learners, including surveillance, detention, discrimination, crime, terrorism, civil unrest and restrictions on travel or exit. Institutions are expected to consider whether particular individuals could face heightened risks because of their work, public profile or access to sensitive information.

The geopolitical dimension includes the possibility of sudden disruption arising from conflict, sanctions, diplomatic tensions, changes in regulation, transport restrictions or interruptions to financial and data flows.

Stronger checks before signing agreements

The guidance asks institutions to establish the identity, ownership, control and financial position of a prospective partner before entering into an agreement. This includes examining its key decision-makers, funding sources, affiliates, agents and subcontractors, as well as any relevant links with government, defence, security or law-enforcement bodies.

Providers are also advised to assess the motivations of both parties and establish whether the benefits and responsibilities are proportionate. Agreements should clearly define the purpose and scope of a collaboration, including limits on the use of institutional branding, educational content, data, research and intellectual property.

The framework recommends that institutions document their findings, identify safeguards and assign responsibility for accepting and reviewing any remaining risks. Higher-risk arrangements may require more extensive checks, additional contractual protections and approval by senior institutional leaders.

It also advises providers to examine whether their activities could create excessive dependence on a single overseas partner or market. Such dependence, the guidance notes, could leave an institution vulnerable if access to campuses, funding, student recruitment, technology, licences or other services were suddenly disrupted.

Academic freedom and institutional autonomy

A substantial part of the guidance concerns the protection of independent decision-making. It warns that partnership arrangements can create formal or informal channels through which an overseas partner may seek to influence appointments, admissions, curriculum, assessment, research, public statements or institutional events.

Providers are therefore advised to specify which decisions must remain under their own control. They should also establish transparent governance arrangements, record material decisions and provide safe channels through which staff and students can report concerns.

The guidance calls for safeguards against censorship, self-censorship, surveillance, interference in academic activity and retaliation against people who raise complaints. Institutions should ensure that their overseas arrangements do not compromise educational quality, academic standards or their ability to meet regulatory responsibilities.

For partnerships involving research, access to research facilities, data or technology, providers are encouraged to use relevant research-security processes and seek specialist advice from the government’s Research Collaboration Advice Team.

Continuous monitoring and exit plans

The framework treats risk assessment as an ongoing process rather than a one-time exercise before an agreement is signed. Institutions are expected to review partnerships periodically and reassess them when there are significant changes in ownership, leadership, funding, activity, local law or geopolitical conditions.

They should also establish clear procedures for responding to concerns. Depending on the circumstances, a provider may continue a partnership, impose additional conditions, pause activities, seek advice, suspend an arrangement or terminate it.

The guidance recommends that institutions plan for possible exits before signing contracts. Such plans should address the continuity of education for students, the safety and repatriation of staff, the recovery of funds and assets, and the handling of data, equipment and intellectual property.

The DfE makes clear that there is no fixed list of countries, organisations or activities that automatically require enhanced risk assessment. A partnership should be evaluated in its specific context, taking account of the partner, the activity, the operating environment and the safeguards available.

The document applies to England and is intended to complement, rather than replace, existing legal, regulatory, safeguarding and quality-assurance obligations. It provides a framework for institutions to make informed decisions about whether to proceed with an international arrangement, introduce additional safeguards or withdraw from it.