Speaking at the UKCISA 2026 conference in Glasgow, Sanjay Parmar, Migration Supervisor at Fragomen LLP, cautioned that while current compliance modifications may look basic on paper, in practice they represent “a bigger shift” in how the system acts and how organizations must run within it.
Compliance, he stressed, “is clearly no longer a technical compliance issue. It’s clearly ending up being a tactical institutional danger for the organization”.
He stressed the need to move away from dealing with the Fundamental Compliance Assessment (BCA) purely as a numerical obstacle. While the 5% visa rejection limit has actually drawn sector-wide attention, he cautioned that “it’s not really about sitting at 5%”.
Instead, organizations that are coping finest are “building that platform to 4% or lower” and dealing with refusal, enrolment, and conclusion metrics as part of a live, whole-journey danger photo. He argued that organizations must “comprehend your entire journey and how you position yourself as an institution, and it’s not almost that a person metric”.
Parmar argued that risk typically develops “rather quietly in the background”. What causes difficulty, he said, is restricted visibility, irregular decisions, and detached teams.
Many institutions are still counting on “detached systems and spreadsheets”, which indicates they only discover issues through “retrospective reporting, which is what you don’t wish to be doing”.
The minute you sign a CAS, you’re successfully accepting that threat Sanjay Parmar, Frangomen Instead
, he called for a more “live view of where you sit as organizations”, with much better use of core student record systems.
Evidence collection was referred to as important, not optional. Parmar urged institutions to collect and file documents on withdrawals and visa-related modifications as early as possible.
Without it, when problems do develop, institutions can find themselves scrambling: “We’ve needed to assist organizations in the past try and balance info if they have actually been in problem,” stated Parmar.
Stronger suppliers, by contrast, are currently “taking a look at patterns, where is the pressure structure, where have problems show up in the past, and … what’s that going to tell them about what’s coming next,” he included.
CAS issuance was singled out as the essential control point in the trainee journey. Parmar told delegates: “The minute you sign a CAS, you’re efficiently accepting that risk.”
He required more strategic, structured methods to credibility interviews and pre‑CAS checks, noting that across the sector there is still “disparity about who, for example, gets interviews, what the criteria are, how results are taped, how concerns are escalated”.
Another stress he highlighted was the balance between compliance and wider institutional priorities. Organizations are not only considering visas; they are likewise “rather rightly stabilizing academic judgment, fairness, experience, retention, income, reputation”, he recommended.
Parmar noted that the threat under the brand-new BCA structure is that many little, separately reasonable decisions– “late arrivals or large new enrolments”, or generous exceptions– can, when increased across departments, “quietly move your enrolment and completion rates and outcomes”.
To address this, he indicated great practice such as “setting up little review groups or panels” to manage challenging cases regularly, and advised institutions to ask, “Are you being too extreme? Are you eliminating trainees too rapidly? What can you do to attempt and reduce those students that leave?”.