Making OfS Condition E10 Work for Students and Universities
Condition E10 can strengthen confidence in university partnerships. Its value depends on how institutions connect their policies to evidence, decisions and timely action.
By Dr Tola Adesina, CEO of Plethro
I support the purpose of OfS Condition E10. Universities that work through delivery partners should be able to explain how those arrangements serve students and demonstrate that they are overseeing them effectively. Done well, the condition can strengthen the credibility of a model that has an important place in widening access to higher education.
Partnerships can bring education closer to students' homes, offer more accessible ways to study and connect universities with communities they might otherwise struggle to reach. My work in university leadership and higher education partnerships has made me a strong advocate for that potential. It has also shaped my view that the capacity to oversee a partnership must grow alongside the ambition for it.
E10 makes that relationship especially important. The Office for Students introduced the condition from 31 March 2026, following concerns about risks to students and public funding in some subcontracted provision. For institutions already within scope, implementation should now be part of routine governance.
What Condition E10 requires
Broadly, E10's substantive requirements apply to OfS-registered lead providers with 100 or more students across relevant subcontractual courses, or a material likelihood of reaching that threshold. The count is across relevant provision, rather than a separate allowance for each partner. The precise definition, exclusions and advance trigger rules matter when determining scope.
The condition requires providers to identify and address risks to students and taxpayers, maintain a single Subcontracting Information Source, or SIS, and operate in accordance with it. The SIS can be one comprehensive document or a summary document that explains and references the necessary supporting detail. Superseded versions must be retained for at least five years.
The OfS's minimum content requirements cover the rationale for subcontracting, assessment of new arrangements, governing body oversight, policies and procedures, and adaptability. They include due diligence, admissions oversight, academic quality, verification of partner information and protection of students if delivery fails. The rationale must explain how students' needs take priority over financial considerations.
The OfS expected the SIS to be in place and implemented by 30 June 2026, with an earlier expectation when relevant contracts were entered into or varied after commencement. That milestone has passed. The practical question now is whether the arrangements described in the SIS are working.
Why this can benefit the sector
Effective oversight gives responsible partners a stronger basis on which to demonstrate their quality. It also helps universities make better decisions about where to invest, where to provide support and when growth should pause.
Clear expectations can improve the relationship between a university and its partners. Both sides should understand what evidence is needed, how performance will be reviewed and what happens when concerns arise. That creates a more dependable environment for delivery and reduces the scope for important issues to sit unresolved between organisations.
I would like the sector to use E10 to improve the quality of that relationship. A well supported partner with clear responsibilities and predictable oversight is better placed to deliver a good student experience. Compliance becomes more useful when it informs how the partnership operates every week.
Implementation needs an evidence trail
The difficulty often lies in connecting information held by different teams. Academic quality may hold a monitoring report, finance may identify a funding concern, and the partnership team may be negotiating expansion. Each team can perform its own role diligently while the institution lacks a shared understanding of the overall risk.
My view is that every significant concern needs an identifiable owner, a response deadline and evidence that the action taken has addressed the problem. Governing bodies need to see material exceptions and the reasoning behind decisions. A long policy document cannot, by itself, provide that assurance.
Technology can make this work easier by keeping requirements, evidence and actions connected. Its value depends on the quality of the information entered and the willingness of leaders to act on it. A completed task or a green status should prompt scrutiny of the evidence supporting it.
How PlethroPro supports E10 implementation
We have developed PlethroPro around the practical sequence of assessing the institution's position, preparing its SIS, implementing improvements and maintaining oversight. The toolkit brings those activities together in one place.
The diagnostic assessment helps teams identify gaps across their E10 arrangements and organise the work that follows. It provides a shared starting point for discussion, helping institutions move beyond different departments holding different views of readiness.
The SIS builder offers a section-by-section editor, regulatory references and AI-assisted drafting. This can reduce the effort involved in assembling a coherent initial document. Institutional colleagues still need to check that the content accurately describes their own arrangements and that they can deliver the commitments it contains.
The partner register brings contract information, due diligence dates and E10-related clause checks together. That makes it easier to identify relationships requiring attention and to connect the policy position to individual partnership arrangements. Suggested contract amendments remain subject to appropriate professional review.
Action planning turns identified gaps into tasks with owners, due dates and supporting evidence. The benefit is clearer responsibility: teams can see what remains open and what evidence is available to support closure.
Board pack export helps bring the assessment, SIS and implementation information into a format that can support committee scrutiny. Version history and scheduled reviews, with reminders, help maintain continuity as policies and partnerships change.
Taken together, these functions can reduce repeated administration and make outstanding work more visible. They give specialist staff more scope to focus on interpreting evidence and resolving issues. They do not establish compliance automatically, and the institution remains responsible for its decisions and delivery.
Keep oversight proportionate and connected to students
I favour a proportionate approach that directs attention towards the most significant risks. Collecting additional information is worthwhile when it improves a decision or provides meaningful assurance. Repeated requests for evidence that nobody examines can consume the capacity needed for more valuable work.
At the same time, a portfolio dashboard cannot be the entirety of the institution's assurance. The SIS requirements include access to necessary partner information and verification, including onsite inspections. Aggregate indicators can direct attention, but universities still need appropriate access to the underlying evidence and ways to test its reliability.
The lead provider also needs enough skilled people, effective processes and governance capacity to manage the scale of its provision. The OfS can identify a breach of the overarching obligation even where detailed requirements appear to have been met.
E10 can help build a more credible and sustainable partnership sector. I believe the strongest implementation will combine experienced institutional leadership, constructive partner relationships and technology that makes oversight practical. That is the contribution we want PlethroPro to make.
Visit PlethroPro to explore the E10 compliance toolkit, or speak to Plethro about combining the platform with specialist support for your institution's subcontracting arrangements.
About the author
Dr Tola Adesina is CEO of Plethro and a former Associate Provost for Global Engagement at the University of Derby. He advises higher education institutions on strategic growth, partnerships, governance and international expansion.
