Speaking at the UKCISA 2026 conference in Glasgow, Sanjay Parmar, Migration Manager at Fragomen LLP, warned that while current compliance modifications might look basic on paper, in practice they represent “a larger shift” in how the system behaves and how organizations must run within it.
Compliance, he stressed, “is certainly no longer a technical compliance problem. It’s clearly becoming a strategic institutional risk for the institution”.
He stressed the need to move far from dealing with the Basic Compliance Evaluation (BCA) purely as a numerical difficulty. While the 5% visa rejection threshold has drawn sector-wide attention, he warned that “it’s not actually about sitting at 5%”.
Rather, institutions that are coping finest are “building that platform to 4% or lower” and treating rejection, enrolment, and completion metrics as part of a live, whole-journey threat photo. He argued that institutions must “comprehend your whole journey and how you position yourself as an organization, and it’s not practically that one metric”.
Parmar argued that risk typically builds “quite quietly in the background”. What causes problem, he said, is restricted presence, inconsistent choices, and disconnected teams.
Numerous organizations are still depending on “detached systems and spreadsheets”, which implies they only discover concerns through “retrospective reporting, which is what you don’t want to be doing”.
The moment you sign a CAS, you’re successfully accepting that risk Sanjay Parmar, Frangomen Instead
, he called for a more “live view of where you sit as organizations”, with better usage of core student record systems.
Evidence collection was described as critical, not optional. Parmar prompted institutions to collect and file documents on withdrawals and visa-related modifications as early as possible.
Without it, when issues do arise, institutions can discover themselves rushing: “We’ve had to help organizations in the previous shot and balance information if they have actually been in trouble,” said Parmar.
Stronger suppliers, by contrast, are currently “taking a look at patterns, where is the pressure building, where have issues show up in the past, and … what’s that going to inform them about what’s coming next,” he added.
CAS issuance was singled out as the essential control point in the trainee journey. Parmar informed delegates: “The minute you sign a CAS, you’re efficiently accepting that danger.”
He required more strategic, structured techniques to credibility interviews and pre‑CAS checks, keeping in mind that across the sector there is still “inconsistency about who, for example, gets interviews, what the criteria are, how results are taped, how issues are intensified”.
Another tension he highlighted was the balance in between compliance and more comprehensive institutional top priorities. Organizations are not just thinking of visas; they are likewise “rather rightly stabilizing scholastic judgment, fairness, experience, retention, earnings, credibility”, he suggested.
Parmar noted that the danger under the new BCA framework is that numerous small, separately affordable choices– “late arrivals or large new enrolments”, or generous exceptions– can, when increased across departments, “silently shift your enrolment and conclusion rates and results”.
To address this, he indicated great practice such as “establishing small evaluation groups or panels” to handle difficult cases consistently, and urged institutions to ask, “Are you being too extreme? Are you eliminating students too rapidly? What can you do to try and minimise those students that leave?”.