On 21 September the QAA published its Advice and Guidance for Principle 12 of the UK Quality Code, which covers concerns, complaints, and appeals processes. It is publicly available on the QAA website and was written and peer-reviewed by practitioners from providers across the UK. It sets out six Key Practices, with reflective questions and scenarios for each.
The guidance says that it is not mandatory. QAA and national regulators do not treat it as a set of compliance indicators, and it does not interpret statutory requirements. Its status for your institution depends mainly on which UK nation you are in.
How it applies in each nation
England. There is no regulatory requirement to use the Quality Code in England, unless a provider is subject to QAA’s Educational Oversight review. QAA has compared the Code with the OfS conditions of registration, and links Principle 12 to condition C2. That condition requires providers to cooperate with the OIA scheme and make students aware of it. (QAA also suggests English providers check whether collaborative partners expect them to align with the Code.)
Wales. QAA says the 2024 Quality Code has applied in Wales from 2025-26. Medr’s Quality Framework took effect on 1 August 2026. It lists compliance with the principles of the Quality Code among its expectations for higher education providers. Welsh institutions may find the Principle 12 guidance useful when showing how they meet this.
Scotland. The Quality Code is one of the reference points Scottish institutions are expected to address in Tertiary Quality Enhancement Review (TQER). The guidance recognises that the SPSO Model Complaints Handling Procedure has no informal stage. Wherever it refers to informal resolution, it adds that in Scotland this means resolution at Stage 1 or Stage 2 of a formal, logged complaint.
Northern Ireland. QAA has said the Department for the Economy intends the Quality Code to be a reference point in its planned review method. I have not been able to confirm whether that method is now in place. Colleagues in Northern Ireland may want to check the current position with the Department.
The guidance also notes that “concerns” has a specific regulatory meaning in Scotland, Wales, and Northern Ireland, where it refers to systemic quality issues. In this guidance the word has its everyday meaning: a minor issue that can be resolved early.
Complaints bodies and final letters
The guidance says providers’ timeframes should align with those of the relevant external body. It also recommends consulting that body when processes change. In England and Wales this is the OIA, in Scotland the SPSO, and in Northern Ireland the NIPSO.
Providers should be clear with students about when they can and cannot take a complaint to that body. In England and Wales, the Completion of Procedures letter marks this point. In Scotland and Northern Ireland, it is the final investigation response, which tells the student how to take the complaint further. The guidance says providers should avoid implying that every outcome produces such a letter, because only the final internal position does.
What it says about conduct, harassment, and hate
Most of the guidance, and most of its scenarios, are about service complaints and academic appeals. However, several parts may still be relevant to those who handle reports of misconduct.
- Scope. The definition of a complaint includes the behaviour or conduct of staff or other students, “including how an individual has been treated in social, residential or other non-academic settings”. Appeals include decisions made by disciplinary bodies.
- Separating roles. Decision-makers should have no prior involvement in the matter. Providers “maintain clear separation between investigative and decision-making functions”.
- Communication. Communications should be “neutral in being clear, factual and free from judgement or blame”. They should also be compassionate, recognising the student’s experience and any distress. Verbal updates and outcomes should be followed up in writing.
- Sensitive information. Providers should explain how, why, and with whom information will be shared. They should only ask for sensitive information where it is necessary. Requests for evidence should be proportionate, so that they do not burden the student.
- Accompaniment and adjustments. Students can be accompanied or represented at meetings. Processes should allow for reasonable adjustments, and for someone to submit a complaint on a student’s behalf.
- Timescales. Providers should set realistic timescales for complex or multi-party cases, and keep students updated about delays.
- Triage and risk. Some cases are not suitable for informal resolution because of their seriousness or complexity. Providers need ways to identify a risk of serious harm, refer to safeguarding, and make sure processes “do not exacerbate harm”.
- Training. Staff should be trained to recognise disclosures and respond appropriately, with clear routes for referral.
Much of this is consistent with trauma-informed and procedurally just practice and many institutions may already do most of it.
Where the guidance is less clear
The guidance is written mostly from the point of view of the student raising a complaint. It says that all parties should be treated respectfully and fairly. It says little else about the student who is the subject of a complaint, or how to communicate with them.
It suggests providers may offer mediation, conciliation, or facilitated discussion in complex cases. It does not say whether these are suitable for complaints about harassment, sexual misconduct, or hate, or where there is a power imbalance between the people involved. Institutions may want to take care before applying this suggestion to those cases.
The guidance does not refer to condition E6 in England or specifically to Medr’s welfare condition in Wales. Both set more specific expectations about harassment and sexual misconduct. On 15 September the OIA also published a new Good Practice Framework section on handling reports about harassment and sexual misconduct. It applies in England and Wales and goes into more detail on these cases and for cases like these it may be the more detailed reference point.
Monitoring, review, and learning from outcomes
Key Practices e and f ask providers to monitor and review their processes, and to use outcomes to improve provision. The guidance suggests:
- reviewing past decisions for consistency and impartiality
- involving independent observers or independent review
- reporting themes to governance
It also cautions providers against “viewing an absence of complaints as a sign of a healthy system”. In harassment and sexual misconduct work, low reporting numbers can reflect barriers to reporting and this point may be worth raising with governance.
When a complaint is upheld, the guidance asks providers to:
- consider whether anyone else was affected by the same issue
- name who is responsible for any actions to address wider issues
- make sure any apology is sincere and explains what will change (note that the SPSO has very good guidance on meaningful apologies)
Questions to ask in your own institution
- Are the people who investigate separate from the people who decide (e.g. panels)?
- How do you explain to students why you need sensitive information, and who will see it?
- Do your timescales for complex or multi-party cases reflect how long these cases take, and are students told about expected timescales or delays?
- Does your triage identify cases that are not suitable for informal resolution or mediation?
- What information and support do you give the student who is the subject of a complaint?
- How are themes from conduct cases reported to governance, and does anyone look at low numbers as well as high ones?
You can read the Principle 12 guidance, and the Advice and Guidance for the other Principles, on the QAA website.
At Campus Resolve we can help you to comprehensively review both policy and practice against relevant regulatory frameworks. We provide clear and RAG-rated reports, always explained in clear language, and we can include action lists to take away. Read more about our consultancy services at https://campusresolve.co.uk/services/#advisory