Third-country students in higher education – admission, residence permits and organisation of education

Source: The Swedish National Audit Office’s processing of data from Statistics Sweden.

2.3 Highest number of third-country students in technology and engineering

In the autumn semester of 2023, around 3,500 English-language higher education courses and programmes in total were offered at Swedish HEIs. They were aimed at Swedish students, EU/EEA students and third-country students. About 80% of the courses and programmes were taught on campus, while the remainder were taught remotely.[51] Among third-country students who came to Sweden for on-campus studies, an overwhelming majority were enrolled in a second-cycle programme.[52] The fields of technology and natural sciences dominated among the second-cycle programmes, although HEIs also offered many courses in the humanities and social sciences.[53]

The average tuition fee was SEK 70,000 for second-cycle programmes starting in autumn 2023.[54] The average tuition fee in Sweden is lower compared to a sample of countries examined in the audit, with the exception of Finland, where the average tuition fee is at roughly the same level.[55]

In general, tuition fees are highest in fine arts, technology and medical programmes, and lowest in social sciences programmes (see Figure 2). However, there are large variations in the rates of fees within both subject areas and higher education institutions.[56]

Figure 2 Tuition fees for second-cycle programmes in 2023 in different subject areas; minimum, average and maximum

Source: The Swedish National Audit Office’s processing based on data retrieved from Universityadmissions.se. (Web scraping on 18 October 2023). The figure only refers to second-cycle programmes offered on campus.

The number of third-country students varies between different HEIs and subject areas.[57] The largest number of third-country students can be found at Lund University and Uppsala University, which also have a large number of students in total. HEIs with a focus on technology (KTH Royal Institute of Technology and Chalmers University of Technology) attract many third-country students. Technology and the engineering industry is also the subject area with the highest number of enrolled third-country students.

2.4 Coming to Sweden as a student

Third-country students planning to attend on-campus studies are subject to a lengthy process for admission to Swedish universities, involving several government agencies. Chart 1 provides a simplified description of the process from the student’s perspective.[58]

Chart 1 The admission process to Swedish higher education institutions

Note: (1) The application fee is set out in Section 2 of the Ordinance on application fees and tuition fees at higher education institutions. (2) In 2024, the application fee was SEK 1,500 for adults and SEK 750 for accompanying children. (See the Swedish Migration Agency, ‘Avgifter för ansökan om uppehållstillstånd för studier och deras familjemedlemmar, retrieved on 6 May 2024.) (3) In some cases, the student may need to travel to a Swedish embassy or consulate-general in another country if there is no embassy or consulate-general in their home country. (4) Provided that the student has not already received a rejection. In addition, in 2024 the Swedish Migration Agency has launched a pilot project in which applicants from certain visa-exempt countries can perform a digital passport control without visiting an embassy or consulate. (See the Swedish Migration Agency’s ‘Digital passkontroll’, retrieved on 11 October 2024.) (5) This step only applies to students from countries where visas are required. Students from visa-exempt countries can pick up their residence permit card at one of the Swedish Migration Agency’s offices in Sweden.

2.5 HEIs’ work related to third-country students

Swedish universities recruit third-country students in competition with other education destinations that offer teaching in English. The universities actively engage in recruitment, including participating in international education fairs, advertising online, and hiring agents who can inform about education in Sweden and support students in their application process.

Third-country students interested in studying in Sweden can access information on websites provided by Swedish government agencies.[59] The common admission for international students is structured in the same way as the system for domestic students. Students rank courses and programmes at the various universities and are admitted to the one they rank highest, given their qualifications.[60] When receiving their admission decision, students will also receive information about any reserve placements.

2.5.1 Coordination in the assessment of foreign qualifications

HEIs are responsible for assessing the students’ qualifications and they also make the decisions to admit students. First-cycle studies require general entry requirements corresponding to a Swedish upper secondary school degree, and second-cycle level studies require a degree corresponding to a Swedish Bachelor’s degree of 180 credits.[61] HEIs may also require additional specific entry requirements, which are necessary for the student to complete the programme.[62] Students must also have English proficiency equivalent to the Swedish upper secondary school course English 6 or higher.[63]

There is a high level of coordination in the assessment of foreign qualifications and international students’ eligibility for higher education studies at Swedish HEIs. The practical assessment of the general entry requirements of individual applications is performed by admissions officers operating within the ‘virtual organisation’ (VO), which is a collaboration between the UHR and the HEIs.[64] Admissions officers employed by universities work temporarily within the VO, where they collaborate with UHR officers. Universities, in turn, employ the VO to assess the general entry requirements of international applicants. The UHR coordinates the VO using resources from the universities and the UHR for this assignment. The universities themselves assess whether their specific entry requirements have been met.[65] In addition, if there is competition for places, each university ranks students based on merit-based criteria so that a selection can be made.[66]

2.5.2 Separate admission − fee-paying students may be admitted under a special quota

Since 2014, HEIs have been able to make use of separate admission, which means that fee-paying students from third countries can be admitted in a separate selection group.[67] In separate admission, the university specifies how many students can be admitted under each quota (paying and non-paying) and in the selection process, students’ qualifications are only compared within each group.[68]

Separate admission was introduced to facilitate planning and an earlier admission round for international students, and help increase the overall number of students.[69] In addition, HEIs can use separate admission to balance the number of paying (third-country students) and non-paying students (mainly students from Sweden and the EU/EEA) in academic programmes or courses. For example, a university can adjust the number of places in the quota for paying students ahead of the next application round if they consider that there are too few third-country students in the programme or course.[70]

2.5.3 Admission and registration

Once the entry requirements assessment and ranking of students has been completed, places are allocated to applicants using UHR’s place allocation model, and students subsequently receive their admission decisions. In connection with the decision notification, they will also be notified of any scholarships. Students must then pay the first instalment of the tuition fee in order to apply for a residence permit for studies.[71]

Many students drop out during this process. After the admission decision stage, many admitted students do not pay the tuition fee. Students who have hoped for, but did not receive, a scholarship may need to relinquish their study slot for financial reasons. Some students may have been accepted to universities in other countries and choose to decline on these grounds. This loss of students means that HEIs often need to accept more students than the number of available places.[72]

Once a student receives their residence permit, they can enter the country and begin their studies. Students register for their academic programmes or courses online, although some universities require students to attend a roll call before registering.[73] Students must also pay the tuition fees by the due date in order to continue studying.

2.6 Residence permits for studies

International students’ right to residence and work permits in Sweden is set out in the Aliens Act and the Aliens Ordinance. The EU’s Students and Researchers Directive[74] was implemented in Swedish law on 1 January 2020 by the addition of new chapters to these regulatory frameworks.[75]

The requirements for a residence permit for studies in higher education include meeting a ‘maintenance requirement.’ This means that the student must demonstrate to the Swedish Migration Agency that they have sufficient funds to support themselves during their studies, for example by submitting a bank statement showing sufficient balance or a scholarship certificate. In 2024, the maintenance requirement was SEK 10,314 per month. In addition, the student needs to have sufficient funds for the entire permit period.[76] The student must also demonstrate that they will be covered by comprehensive health insurance and will not pose a threat to public policy, public security or public health.[77] Furthermore, the applicant must prove their identity by presenting a valid original passport.[78] The student must also show that they have been accepted to a higher education institution[79] and that the studies will be mainly conducted on campus and constitute full-time studies.[80] An application may be rejected if there are clear grounds to believe that the applicant does not intend to study in Sweden.[81] If documents have been falsified or fraudulently acquired, the application is to be rejected.[82]

2.6.1 One-year residence permits are common, with a possibility for extension

In the period under audit, it was most common for third-country students − including those admitted to a longer education like a Master’s programme − to be granted a 13-month residence permit.[83] According to the Swedish National Audit Office’s international comparison, in other countries, it is common for students to be granted a residence permit corresponding to the length of their programme of study, which means they do not need to extend their permit during their studies as they do in Sweden.[84]

To extend their residence permit in Sweden, the student needs to make acceptable progress in their studies.[85] The Migration Court of Appeal has stated that academic achievements equivalent to 15 credits (equivalent to half a semester of full-time studies) in the first year, 22.5 credits in the second year and 30 credits in the third and following years is to be regarded as acceptable progress.[86] Lower academic achievements may be acceptable in the event of illness or on similar grounds.[87] It should be noted that the requirement of 15 credits is often lower than the HEIs’ own advancement requirements.[88]

In 2018−2023, the Swedish Migration Agency and five universities together carried out a pilot project for the purpose of granting two-year residence permits for students studying in academic programmes. It required universities to fully report to the Swedish Migration Agency when a student interrupted their studies to enable the Agency to investigate cases where a residence permit may need to be revoked.[89] A two-year residence permit means that the applicant will need sufficient funds to support themselves for a longer period than previously. In 2024, the Swedish Migration Agency began to sign agreements with several universities under the same premises as in the pilot project.[90]

2.6.2 Third-country students may work unlimited hours while studying

Third-country students in Sweden have the right to work an unlimited number of hours during their studies without applying for an additional permit.[91] Under the EU’s Students and Researchers Directive, third-country nationals have the right to work at least fifteen hours per week during their studies.[92] Therefore, Swedish legislation is more generous than the EU Directive, and even as compared with other countries. For example, in Finland, third-country students may work up to 30 hours per week, and in Denmark and Norway, students may work up to 20 hours per week. However, students are often allowed to work without restrictions during their study break in the summer months.[93] The fact that students do not need to apply for a work permit also means that they may take employment that does not meet the conditions, for example in terms of requirements for working conditions and salary.[94]

Furthermore, after completing 30 credits, third-country students may change their residence permit for studies and apply for a work permit without leaving the country.[95] To be granted such a change, the student and the employment must meet the requirements for a work permit.[96] Students may also apply for a one-year residence permit to seek employment or explore the possibility to start their own business after completing their studies.[97]

2.6.3 Students’ accompanying family members may work or study in Sweden

Students who come to Sweden to study may bring accompanying family members[98], who are then granted a residence permit for the same period as the student.[99] This is also common in other countries.[100] As for the student’s residence permit, certain requirements must be met, for example, the accompanying family member must secure their livelihood during their stay, either through the student’s funds or on their own.[101] An accompanying family member can choose to study or work in Sweden. If the accompanying family member chooses to study, as a general rule, they are exempt from tuition fees.[102]

2.6.4 Original passport and visit to a Swedish embassy

Since November 2022, all students from third countries need to visit a Swedish embassy or consulate-general to present their passport for their residence permit application to be granted.[103] The requirement of presenting their passport means that many people may need to travel far. In the United States, for example, only the Swedish embassy in Washington, D.C. processes migration cases. In Asia, many students need to travel to another country to visit a Swedish embassy.[104] Previously, the Swedish Migration Agency granted residence permits for studies based on scanned passport copies, which allowed third-country students to apply entirely online. Only after their residence permit was granted did the student need to visit an embassy or consulate-general to provide their fingerprints and collect their residence permit card.[105] In 2022, this changed when the Legal Affairs Department at the Swedish Migration Agency announced that third-country students must present their passport in order to establish their identity.[106] In 2024, the Swedish Migration Agency initiated a pilot project to offer digital passport controls for students who do not need a visa.[107]

2.6.5 Processing requires close cooperation between the Swedish Migration Agency and embassies

When a person applies for a residence permit for studies, the application must be made from abroad.[108] This means that the case officer at the Swedish Migration Agency in Sweden does not meet the student. Several important steps in the process are therefore carried out by local staff at Swedish embassies on behalf of the Swedish Migration Agency. However, the Swedish Migration Agency are responsible for making a decision in the case.[109]

The Swedish Migration Agency’s processing of residence permits for studies takes place mainly at four permit assessment units at different locations in Sweden.[110] The units are assigned cases depending on which higher education institution the student has been admitted to.

About 60 Swedish embassies and consulates-general have a migration section. Local staff and posted staff from the Swedish Migration Agency or the Ministry for Foreign Affairs are employed there. The local staff handle student cases, affiliation cases and visa applications.[111] The posted staff from the Swedish Migration Agency or the Ministry for Foreign Affairs manage the local staff and make decisions on visa cases.[112]

The overall processing of first-time applicants[113] for higher education and their accompanying family members is described below.[114]

• After the application has been registered, the Swedish Migration Agency examines whether the requirements for the permit have been met. This means that the case officer checks that the student has paid their tuition fee, has been admitted to an approved programme of study at a Swedish HEI and can show that they have sufficient funds for their maintenance. The latter is often done by examining a scanned bank account statement. For accompanying family members, scanned copies of documents that can prove their relationship are checked. These may be documents such as marriage certificates for married couples, birth certificates for children or proof that the parties have lived together in a cohabiting relationship.[115]
• If the application is incomplete, the student or accompanying family member needs to send the documentation required to the Swedish Migration Agency. If applicants do not meet the requirements, their application will be rejected. If the application is considered complete and is deemed to be approved, the student or accompanying family member is summoned to the nearest embassy or consulate-general to present their passport and possibly submit biometric information.[116]
• If the Swedish Migration Agency initially assesses that a student does not intend to study or that the accompanying family member’s affiliation to the student is questionable, an order is sent to the nearest embassy or consulate-general for an investigation, that is, a face-to-face interview.[117] The case officer encloses a template with questions and any additional instructions.[118] They can also order a document review or verification of bank statements, if they suspect that a document has been manipulated.[119]
• The interview with the student is conducted in English by the local staff at the embassy.[120] The accompanying family member is interviewed about their relationship. In connection with the investigation, the local staff examines the passport and collects biometric information. The local staff send the documentation to the case officer together with the results of the document review.[121]
• The Swedish Migration Agency’s case officer examines the documentation from the embassy and, on this basis, approves or rejects the application.[122] For applicants from countries that require a visa, a residence permit card that is required for entry into Sweden, is produced. The card is sent to the Swedish embassy via courier mail from the Ministry for Foreign Affairs.[123] Once they pick up their residence permit card at the embassy, the student may enter Sweden.[124]

2.7 The Government and government agencies’ policies and activities

Since 2015, in accordance with their joint appropriation directions, universities and other higher education institutions have been required to report how many students paying tuition fees have been admitted through separate admission and how this admission has affected activities funded by tuition fees. The universities’ cooperation with the Swedish Migration Agency and certain financial data on activities funded by fees must also be reported back.[125]

2.7.1 The Internationalisation of Swedish Higher Education and Research Inquiry

In 2017, the Government appointed an inquiry to propose new objectives and a national strategy for the internationalisation of higher education institutions to increase the attractiveness of Sweden as a study destination and knowledge nation. The Inquiry’s proposals included a joint website for foreign students’ applications to higher education institutions. The point of departure was that a student would be able to retrieve all relevant information on a website and monitor the progress of their case in a common system that would be able to handle applications to courses and programmes, scholarships and residence permits. The Inquiry also proposed that third-country students be followed up from registration to graduation.[126] Another proposal included certifying HEIs by the Swedish Migration Agency to assess the applicant’s intention to study, in part to shorten processing times.[127]

The Government pursued some of the proposals, commissioning five government agencies to form a collaboration platform to facilitate HEIs’ internationalisation efforts.[128] The collaboration, Platform for Internationalisation, was launched in 2022 and replaced the previous Forum on Internationalisation. As a result of the inquiry, a provision in the Higher Education Act was also amended to the effect that international activities should strengthen the quality of higher education and research and make a national and global contribution to sustainable development.[129]

2.7.2 Assignment to the Swedish Higher Education Authority

In 2016, the Government tasked the Swedish Higher Education Authority (UKÄ) with studying the tuition fees charged by HEIs to foreign students.[130] The UKÄ’s report found that HEIs had different interpretations of full coverage of costs and that the rules on repayment of tuition fees needed to be clarified. The report also showed that few HEIs applied separate admission.[131]

In addition, on its own initiative, in a special report published in April 2024, the UKÄ followed up the academic achievements of students paying tuition fees. The report shows that freemover students have a higher retention rate[132] and graduation rate than Swedish students. However, retention and graduation rates have declined among some groups of paying freemover students, mainly from Pakistan and Bangladesh. Among the students who stay in Sweden, there is a high rate of establishment in the labour market.[133]

2.7.3 Assignments to the Swedish Migration Agency and investigations concerning migration law

The Swedish Migration Agency and HEIs were commissioned to implement measures to make it more difficult to abuse residence permits for studies. The assignment was reported in April 2024 and some measures have been taken, including measures aimed at increasing the precision of the processing of residence permits and improving the assessment of study intentions.[134]

The Swedish Migration Agency was also tasked with implementing measures to make it easier to present a passport when applying for a residence permit for studies.[135] The Swedish Migration Agency describes numerous measures, but according to the Agency, a contract with an external service provider will be needed in the long term due to future EU legislation.[136]

An investigator was tasked with carrying out a review of the regulatory framework, which included the aim of preventing abuse of the system for residence permits for studies.[137] When a student’s residence permit has been revoked, the Swedish Migration Agency is unable to revoke the residence permits for accompanying family members who have entered Sweden.[138] The Government has commissioned an investigator to analyse and propose how to extend the possibilities of revoking residence permits granted to family members under the provisions of the Aliens Ordinance.[139]

3. Third-country students’ study performance and establishment in the labour market

Overall, our findings show that third-country students generally manage their studies well and to a large extent either advance to doctoral studies or join the labour market. However, there are indications that, compared to Swedish students, relatively many third-country students work in low-skilled professions.[140] We find no clear indications of any widespread problem of residence permits for studies being used for purposes other than studies in Sweden. The analyses in this chapter are largely based on register data of students at the second-cycle level.

3.1 Operationalised assessment criteria

Based on the overall assessment criteria described in Chapter 1, we use the criteria described below to assess whether third-country students intend to study, whether they manage their studies and to what extent they join the Swedish labour market.

3.2 Third-country students manage their studies well

Our analysis shows that third-country students earn credits and persist in their studies to a similar extent as students from Sweden and the EU/EEA. Third-country students have a higher graduation rate compared to students from Sweden, but a lower graduation rate compared to students from the EU/EEA. Third-country students also have similar grades as students from Sweden and the EU/EEA.

However, not all third-country students are equally successful in their studies. In all the measures of performance and student completion that we examined, students from some countries generally perform worse compared to other third-country students.

3.2.1 Minor differences between students from third countries, the EU/EEA and Sweden

Third-country students earn credits and remain in their studies to a similar extent as students from Sweden and the EU/EEA. The performance rate, that is, the extent to which students achieve the credits they have registered to study, is generally high and differences between third-country students and students from Sweden and the EU/EEA are minor.[141] The retention rate, that is, the proportion of programme entrants who continued to be registered in their academic programme in their second semester has decreased slightly over time among third-country students.[142] However, the differences in retention rates between third-country students and students from Sweden and the EU/EEA are minor for each year.

The graduation rate among third-country students is higher than among students from Sweden, but lower than among students from the EU/EEA (see Figure 3).[143] In 2011, the graduation rate was significantly higher among third-country students and students from the EU/EEA than among students from Sweden. Over time, the graduation rate among third-country students and students from Sweden has converged, while students from the EU/EEA continue to have a higher graduation rate.

Figure 3 Graduation rate among students in Master’s programmes per entry year

Source: The Swedish National Audit Office’s processing of data from Statistics Sweden.

There are only minor differences in performance and academic retention between the sexes.[144] The difference in graduation rates between men and women is relatively small among students from Sweden and the EU/EEA, while among third-country students, the graduation rate is higher among women than among men.[145]

Study performance differs between HEIs and subject areas.[146] In almost all HEIs and subject areas, third-country students perform just as well or better than students from Sweden.[147] Among all students, retention rates are generally higher at large, established HEIs and specialised universities compared to new HEIs.[148] The difference in graduation rates is greatest at new HEIs, where the graduation rate is most often significantly higher among students from the EU/EEA than among students from third countries and Sweden.[149]

3.2.2 Poorer academic performance among students from certain countries

On average, performance rates and retention rates are lower among third-country students from Pakistan and Bangladesh than among other third-country students. Their graduation rate is also significantly lower.[150] For example, in the period 2011−2017, the graduation rate among students from Pakistan and Bangladesh was 33%, compared to 75% among students from other countries. Pakistan and Bangladesh are also two countries from which Sweden receives the most third-country students.[151]

3.2.3 Third-country students and other students have similar grades

Third-country students and students from Sweden have similar grades. A failed grade (F) is somewhat more common among students from Sweden compared to students from third countries. In other respects, the grade distribution is similar for the two groups. This can be seen in information on students’ grades on a grading scale from A to F in Master’s programmes at six HEIs (see Figure 4).[152]

Figure 4 Grade distribution among students from third countries and Sweden

Source: The Swedish National Audit Office’s processing of data from Ladok and Statistics Sweden.

3.3 Many third-country students stay in Sweden and advance to doctoral studies or join the labour market

Our audit shows that almost 45% of all third-country students have remained in Sweden five years after starting their studies. Approximately 90% of third-country students who stay in Sweden advance to doctoral studies or to work.

Among third-country students who stay in Sweden, 16% enter a doctoral programme, compared with 6% among Swedish students. The labour market outcomes for third-country students are similar to those of EU/EEA students. However, compared to students from Sweden, it is more common for third-country students to work in low-skilled occupations and at a lower salary.

3.3.1 Proportion of third-country students staying in Sweden is increasing

The proportion of third-country students who are still living in Sweden five years after starting their studies has increased over time (see Figure 5). Among the students who started their studies in 2011, around 25% of both third-country students and students from the EU/EEA stayed in Sweden. Among those who started in 2016, 44% of third-country students stayed in Sweden, while the proportion of EU/EEA students remained at the same level as in 2011. In terms of the number of individuals, among all third-country students who started their studies in 2011−2016, a total of approximately 4,300 were still living in Sweden five years after starting their studies.

Figure 5 Percentage of new entrants to Master’s programmes residing in Sweden five years after the programme start

Source: The Swedish National Audit Office’s processing of data from Statistics Sweden.

Even among Swedish students, there are a number of individuals who are no longer living in Sweden five years after starting their studies (see Figure 5). However, the number of Swedish students in Master’s programmes who leave Sweden is significantly lower than the number of students in Master’s programmes from the EU/EEA and third countries who stay in Sweden. The total number of students in Master’s programmes who remain in Sweden five years after starting their studies is thus greater than the number of Swedish students who begin international Master’s programmes in Sweden.

The probability of staying in Sweden differs between different student groups and educational choices.[153] Third-country students who have graduated are less likely to stay in Sweden. Third-country students who have studied at specialised HEIs are more likely to stay in Sweden than those who have studied at other HEIs. The probability of staying in Sweden is also higher among third-country students who started their studies in the subject area of technology and manufacturing compared to those who started studies in other subjects. Technology is an area in which the Riksdag and the Government have expressed the importance of third-country students’ contribution to the labour market.[154]

Approximately 70% of the students from third countries and the EU/EEA who stay in Sweden have a degree from a Swedish higher education institution.[155] This corresponds to approximately 3,000 students from third countries and 4,300 students from the EU/EEA. Among third-country students, however, the proportion of graduates dropped in the last years of the period examined.

Among third-country students who stay in Sweden and have obtained a degree at a Swedish higher education institution, a relatively large proportion have a degree in the subject area of technology and manufacturing (52%) compared to students from the EU/EEA (30%). By contrast, a relatively small proportion of third-country students have a degree in the subject areas of social sciences, law, trade and administration, humanities and arts (22%) compared to students from the EU/EEA (38%).

3.3.2 Large proportion of third-country students start doctoral studies or work

Figure 6 shows the proportion of third-country students who have stayed in Sweden and have started their doctoral studies or work five years after starting their Master’s studies. The total proportion of third-country students who stay in Sweden and either pursue doctoral studies or work has remained reasonably constant throughout the observed period, at around 90%. The corresponding proportion for students from the EU/EEA is almost identical, while it is slightly higher for students from Sweden.

Among those who started their studies in the period 2011−2016, 16% of third-country students who remained in Sweden started their doctoral studies (approximately 700 individuals), compared to 19% for students from the EU/EEA (approximately 1,100 individuals) and 6% for students from Sweden (approximately 2,300 individuals). However, the proportion of third-country students who remained in Sweden entering doctoral studies has decreased over time, from 22% for those who started their Master’s programme studies in 2011 to 13% for those who started their studies in 2016.[156]

As regards the proportion of students who start doctoral studies, the Swedish National Audit Office’s results differ from the results reported by the UKÄ.[157] While we find that the transition to doctoral studies is about three times as large for students from third countries and the EU/EEA compared to Swedish students, the UKÄ’s results show that the transition to doctoral studies is almost identical for the three groups − around 9%. An important explanation of the differences in results is that we report the proportion who begin doctoral studies among those who have stayed in Sweden, while the UKÄ reports the proportion who begin doctoral studies among all students regardless of whether or not they have stayed in Sweden. Since the proportion of students who stay in Sweden is lower among students from the EU/EEA and third countries compared to students from Sweden, the different measurement methods lead to different results.[158]

Figure 6 Percentage of third-country students remaining in Sweden who are doctoral students or working five years after starting their studies

Source: The Swedish National Audit Office’s processing of data from Statistics Sweden.

3.3.3 Large proportion of third-country students conduct research in the subject area of technology

There are several similarities between students who stay in Sweden and start doctoral studies, regardless of whether they come from a third country, the EU/EEA or Sweden. In all three groups, students start their doctoral studies on average just over two and a half years after they start their Master’s programme studies. The degree of activity in the first semester of their third-cycle programme – just over 60% − is also almost identical among all three groups.

Among third-country students who remained in Sweden entering doctoral studies, a relatively large proportion pursued their doctoral studies at specialised universities and new HEIs, while a relatively large proportion of students from the EU/EEA and Sweden pursue their doctoral studies at large, established universities. It is also more common for third-country students to pursue their doctoral studies in the subject of technology (40%) compared to students from the EU/EEA and Sweden (22% in both groups).

In line with the Riksdag’s intentions, third-country students constitute an important recruitment pool for further research in Sweden in the field of technology. Among third-country students who remained in Sweden and started their studies in the period 2011−2016, 45 individuals on average per year started doctoral studies in the subject of technology. This can be seen in relation to the fact that there are just over 600 new doctoral students in total per year in the subject of technology.[159] Third-country students thus make up approximately seven per cent of new doctoral students. Over time, third-country students have become an increasingly important part of the recruitment pool; from 2011 to 2016, the number of new doctoral students in the subject of technology has almost tripled. For Sweden, third-country students are also a less costly recruitment pool, since third-country students have paid for their own Master’s degree, unlike, for example, students from the EU/EEA.

Third-country students who advance to doctoral studies obtain a third-cycle qualification to a similar extent as doctoral students from the EU/EEA and Sweden. A larger proportion of doctoral students from third countries stay in Sweden after their third-cycle qualification (85%) compared to students from the EU/EEA (70%).[160]

3.3.4 Many are employed in natural sciences, technology and IT professions, but unskilled occupations are also common

Among those who started their studies in the period 2011−2016, 75% (3,200 individuals) of third-country students who remained in Sweden were working (see Figure 6). The labour market outcome for third-country students is similar to the outcome for students from the EU/EEA, although they do not have equally qualified jobs or equally high salaries as students from Sweden.

Almost 70% of the remaining students from third countries and the EU/EEA who work five years after starting their Master’s programme studies are employed in occupations that require higher education. The corresponding proportion for students from Sweden is 80%.

Relatively many third-country students who remained in Sweden work in occupations requiring higher education qualifications in natural sciences, technology or IT (50%). Among students from the EU/EEA and Sweden, the corresponding proportion is 33%. The annual income is slightly higher for students from third countries (SEK 443,582) compared to students from the EU/EEA (SEK 427,879), but lower compared to students from Sweden (SEK 500,537). This is despite the fact that a higher proportion of third-country students work in professions that are generally highly paid, such as technology.

A relatively large proportion of third-country students who remained in Sweden work in professions with no or little educational requirements, such as advertising and newspaper distributors, restaurants and kitchen assistants, and cleaners. Almost 12%of third-country students work in these professions, compared to just over half a per cent of students from Sweden.[161]

Most (73%) third-country students working in unskilled occupations do not have a Master’s degree and almost 40% had dropped out of higher education before the second semester. This group consists largely of men (82%) and students from Pakistan, Bangladesh and India (70%). Among these students, it is also more common that they worked alongside their studies during their first year of study. Allowing third-country students to work unrestrictedly alongside studies risks circumventing the legal framework for work permits and for third-country nationals to use residence permits for studies for the purpose of work.

3.4 Misuse of residence permits for studies

Several reports investigating the prevalence of misuse of residence permits for studies have found indications of widespread misuse. In one report, the Swedish Migration Agency notes that there are strong indications of extensive abuse of residence permits for studies among students from Pakistan.[162] The Swedish National Audit Office has also previously noted that one in four residence permits for studies can be called into question.[163]

The analyses in the current report suggest that misuse of residence permits for studies is significantly less extensive than indicated in previous reports. However, as we have shown in this chapter, there is a grey area of people who drop out of their studies and start working in unskilled occupations. On the other hand, dropping out does not necessarily mean that the student is abusing their residence permit (see fact box).

One possible explanation for the partial discrepancy between the results in this report and the results of the Swedish National Audit Office’s previous audit is that many people with student permits have left the country without their emigration having been registered in the population register and without the student permit having been revoked.[164] In our analysis, we have been able to take into account such deficiencies in the population register.

3.4.1 No clear indications that misuse is widespread

To investigate the misuse of residence permits for studies, we used data from the Swedish Migration Agency, the UKÄ and Statistics Sweden. We examined the extent of misuse using two analyses. We examined the difference between the number of granted residence permits and the number of first-time registered third-country students, as well as the proportion of individuals in the population register with a residence permit for studies who are not enrolled in studies in Sweden.

First, we examined whether the number of granted residence permits for studies is greater than the number of first-time registered third-country students at the HEI. This should be a clear indication of misuse of residence permits. In the Swedish Migration Agency’s data on granted residence permits, exchange students are not distinguished from students subject to tuition fees. A comparison between the number of granted residence permits for both first-time exchange students and fee-paying students and the number of first-time registered students, showed that the difference is negligible.[165]

Then, we examined whether third-country nationals who have been granted a residence permit for studies, entered Sweden and registered with the Swedish Tax Agency, have registered for studies in Sweden. If they have not registered, this is also an indication of misuse. Our analysis shows that 93% of these third-country nationals are enrolled in some form of education in the year of immigration.[166]This means that about 250−350 people per year have not enrolled in studies. We cannot determine with certainty, on the basis of the register data, whether these individuals are abusing their residence permit.[167] However, even if all these people abuse their residence permits, the total number of individuals is limited.

Although our audit does not find clear indications that misuse is widespread, the occurrence of misuse is problematic, regardless of its extent.[168] Some HEIs have experienced systematic problems concerning lack of study intention among third-country students in some of their programmes, leading to empty study places and courses with few participants. This includes preparatory English courses, with few or no prior knowledge requirements.[169] However, today, there is a greater awareness of the problem compared to a few years ago, which is reflected in the SUHF and the Swedish Migration Agency’s cooperation on the matter.

4. HEIs’ admission and organisation of education for third-country students

Our findings show that the system for admission of third-country students operates properly, even though it is based on the national admissions system and has not been adapted to the conditions for international student recruitment.

Our audit also shows that centralised assessment of foreign qualifications in the virtual organisation (VO) is an effective way to operate and pool knowledge about education systems around the world. An important finding in the audit is the lack of systematic follow-up of third-country students’ study achievements both in the sector as a whole and at university level, making it difficult to develop activities and improve quality.

4.1 Operationalised assessment criteria

Based on the overall assessment criteria described in Chapter 1, we use the criteria described below to assess whether HEIs have designed admissions and education of third-country students to operate effectively.

4.2 Admissions functions properly, but shortcomings in service to students

Our audit shows that the admission of third-country students is organised in such a way as to enable students to apply and receive an admission decision in a timely manner. At the same time, there is a conflict of objectives regarding the time of application. Early application is important for the possibility of obtaining a decision on a residence permit in time. However, as a whole, the process is lengthy, with the effect that students may accept offers from HEIs in other countries that provide a more rapid response.

The Swedish National Audit Office also notes that admissions officers consider the application processing system to be outdated and that the web-based application system for students provides them with very limited information about their application status. This means that the UHR has to devote resources to answering questions from applicants, while the HEIs perceive the web-based application system to be inadequate as a student service and a competitive disadvantage.

4.2.1 Early application allows students to be notified in time

The UHR and HEIs hold a special admissions round (‘the international round’) for admissions to Master’s programmes taught in English. It is open for applications from October of the previous year until mid-January, for studies starting in the autumn semester. The national round is open between 15 March and 15 April.[172] The purpose of earlier admission is to give third-country students time to receive their admission decision in good time to apply for and receive a residence permit.

HEIs can choose to admit students to the same programme in both admissions rounds, but must decide on the number of places in both rounds. Students admitted in the early round are guaranteed places and do not compete for places in the later round. At the end of March or in early April, students who have applied in the international round will be informed whether they have been offered a place.[173]

In interviews, representatives of HEIs highlight that there is a drawback to such an early application period because it requires students to plan their studies well in advance. They describe it as a competitive disadvantage because other countries have a later application period. It is also a challenge to sustain students’ interest for such a long period before they start their studies, as in the meantime, they may be offered a place at an HEI in another country.[174] On the other hand, the Swedish National Audit Office’s international comparison shows that other countries also have a January application deadline for second-cycle studies. Nevertheless, there are examples of countries where the migration process is considerably shorter than in Sweden, thereby shortening the overall process.[175]

4.2.2 Separate admission is used as needed and provides flexibility

‘Separate admission’ allows HEIs the opportunity to accept fee-paying third-country students and other students in two separate selection groups, which means that students’ qualifications are compared within each group. A 2017 UKÄ survey showed that just over one in four HEIs used separate admission.[176] According to responses to the Swedish National Audit Office’s 2024 questionnaire survey, 42% of HEIs currently use separate admission.[177] In the free text section of the survey, several HEIs stated that they do not apply separate admission because there is no need as they accept all eligible applicants.[178]

Survey responses and interviews with HEIs show that when there is competition for places, separate admission is used to balance the composition of third-country and EU/EEA students in the international programmes and courses.[179] The Swedish National Audit Office thus notes that separate admission fulfils a function, provides flexibility and is used by HEIs when the need arises.

4.2.3 Old processing system and shortcomings in information to applicants

Students’ applications are processed in the NyA system, which is administered by the UHR. NyA has been developed primarily for processing applications in the national admissions round.[180] Interviews and free text responses in the survey show that admissions officers consider that while the NyA system is old and outdated, and is not ideal for processing third-country students’ applications, nonetheless it operates satisfactorily.[181]

Although NyA functions adequately from an administrative perspective, several admissions officers and representatives of both the UHR and HEIs have pointed out that there are shortcomings in terms of information from the system to applicants. Applicants from third countries are unable to identify themselves to log in and see how their case is progressing and what qualifications have been registered.[182] The UHR therefore devotes unnecessarily large resources to answering individual students’ questions during the application process, especially related to the entry requirement status.[183] There are no possibilities to clarify the information and communication with the applicants within the system.[184]

4.2.4 Most HEIs follow the recommendations on payment deadlines

It is important that students who are admitted pay the tuition fee as soon as possible after they receive their admission decision, as this is a prerequisite to be able to apply and be granted a residence permit in time. HEIs can speed up the process by communicating a final payment date for the tuition fee.

According to the SUHF, the HEIs must notify the Swedish Migration Agency which students who are subject to tuition fees have made their payment by 15 June before they begin their studies in the autumn semester or by 15 December before they begin their studies in the spring semester, unless the HEI makes a special agreement with the Swedish Migration Agency on a later date.[185]

In the HEI survey, 30 out of 33 HEIs state that they have set a final payment date for both the autumn and spring semesters.[186] Three HEIs state that their final payment date is later than 15 June for the autumn semester, and seven HEIs state a date later than 15 December for the spring semester.[187] At the same time, several HEIs state that they set a final payment date that is far earlier than recommended.[188]

Furthermore, it is important that HEIs’ communication about the final payment date and the Swedish Migration Agency’s practices regarding acceptable documents are harmonised. The Swedish Migration Agency does not accept certificates demonstrating that the student has own funds to meet the maintenance requirement that are older than four months from the start of the residence permit. This practice limits how early a student can apply for a residence permit and may therefore reduce the benefit of bringing forward the final payment date.

4.3 Coordinated assessment of foreign study documentation is an effective approach

Our audit shows that centralised assessment of foreign study documentation is organised efficiently. In the vast majority of cases, HEIs use selection criteria based on students’ qualifications.

4.3.1 Programmes and courses from recognised HEIs confer eligibility

Under the Higher Education Ordinance, a first-cycle degree comprising at least 180 credits or an equivalent foreign degree confers general entry requirements to second-cycle studies.[189] The Ordinance does not specify what the term ‘equivalent’ entails.

One of the SUHF’s working groups, the National Admissions Assessment Group (NBA)[190], has drawn up recommendations that admissions officers can use as support in their assessment of whether foreign qualifications meet the general entry requirements.

For general entry requirements to second-cycle studies, the NBA recommends that all higher education diplomas from recognised HEIs around the world that are deemed to correspond to 180 higher education credits should be accepted. A ‘recognised HEI’ means that the education has been accepted by the educational authority of the country of education. Beyond this, no further assessment is made of whether the quality of the foreign education differs from a corresponding Swedish education. The recommendations provide that the assessment should take into account whether there are significant differences between the foreign and the equivalent Swedish education.[191] According to the interviews, ‘substantial differences’ are used to distinguish, for example, education in alternative medicine, as well as ideological and military training, which are not considered to meet the requirements.[192]

The recommendations have been prepared on the basis of international conventions on the recognition of qualifications.[193] The conventions require parties to recognise higher education diplomas issued by other parties, unless a substantial difference can be demonstrated between each party’s diplomas.[194] The NBA recommends that, in assessing qualifications, this principle should apply generally, even to countries that are not signatories to the conventions.[195]

The NBA has also drawn up recommendations for the assessment of students’ English proficiency qualifications, which must correspond to the Swedish upper secondary school’s English 6 in order to meet the entry requirements. There are four categories of credentials that are recommended to confer eligibility:

• English upper-secondary school qualification from certain countries
• higher education in which the language of instruction was English from certain countries
• a degree corresponding to a Swedish Bachelor’s degree with English as the main subject
• recognised international language proficiency tests.

Following indications of lacking English language skills among third-country students from certain foreign higher education institutions, the recommendations have been updated in several stages, most recently as from the 2024 spring semester. In most cases, higher education studies in which English is the language of instruction from a non-English-speaking country outside the EU no longer qualify.[196] This means that students from these countries must now, to a greater extent than before, take an English proficiency test and achieve a result equivalent to English 6 to qualify for admission.

4.3.2 Centralised assessment of foreign qualifications enhance HEIs’ efficiency

HEIs are formally responsible for the entry requirement assessment. However, through an agreement with the UHR, HEIs engage the VO to determine whether a student meets the general entry requirements.[197] At the VO, case officers specialise in education systems from around the world and sometimes even have special language skills that are needed to interpret foreign study documentation. At the VO, case officers’ work is partly based on the recommendations drawn up by the NBA.[198]

General and specific entry requirements for second-cycle courses and programmes are determined in two steps through a collaboration between the UHR and the HEIs. As a first step, the VO assesses whether the applicant meets the general entry requirements by reviewing their study certificates, enclosed with the application. Information about recognised HEIs around the world has been entered into the NyA system, which means that case officers do not normally need to make enquiries about the HEI.[199] If it involves a recognised university, the case officer assesses whether the qualifications correspond to the general entry requirements, that is, a degree of 180 credits.

Although the VO’s assessment is based on the NBA’s recommendation, it is not binding. In principle, HEIs can choose to carry out their own entry requirement assessment to determine general eligibility. However, they are obliged to comply with the international conventions concerning the recognition of qualifications that Sweden has ratified.[200] Our audit has found few cases in which HEIs have departed from the VO’s assessment and made their own assessments to determine general eligibility, although there are some such instances.[201]

After the VO’s assessment, the case proceeds to each respective HEI for assessment of the specific entry requirements. This process is organised differently at different universities. At some HEIs, the assessment is carried out by the HEI’s admissions unit at the central administration, while at other HEIs, the process is decentralised, and the specific entry requirements and evaluates qualifications are reviewed by the respective department.[202]

We note that the VO’s centralised assessment plays an important role in the admission of third-country students. The case officers have specific country expertise and even if knowledge is documented in country manuals, their work is largely based on accumulated experience. Coordination via the VO is an efficiency and quality gain compared to local processing. According to our interviews and survey responses, cooperation within the VO functions properly.[203]

4.3.3 VO verifies foreign higher education documentation through spot checks

The VO’s task of processing student applications includes determining the authenticity of students’ academic documentation. The case officers examine uploaded copies enclosed with the application. It is not possible to determine whether the document is genuine by examining a copy of a document. However, having sound knowledge of what a document should look like, case officers can detect obvious cases of forgery. Case officers at the VO process a large volume of cases from the same countries of previous education, allowing them to build up experience and expertise, making it easier to detect deviations.[204]

The conditions for verifying information in the academic documentation are different for each country of previous education. For some countries, the VO does not accept uploaded documents, requiring documents to be sent directly by the university. This measure aims to reduce opportunities for fraud and forgery.[205] For some countries, national databases allow digital verification of academic documentation.[206]

Case officers at the VO follow the EAR Manual[207], which advises that documentation should be presumed to be authentic unless there are indications to the contrary. Although verification is an important part of the recognition process, the EAR Manual points out that it is also important not to subject applicants to unnecessarily extensive scrutiny.[208]

In the event of suspected forgery, the VO sends a verification request to the issuing HEI, and the student’s qualifications are not accepted until they have been verified. Unusual documents or deviations from the typical academic documents may also be subject to verification, even if there is no suspicion of forgery.[209] Random checks of digitally verifiable certificates are also carried out; the frequency of these checks varies between countries of previous education and is determined according to the risk of discrepancy based on past experience.[210]

Generally speaking, VO case officers do not regard forgery as a major problem, although there are variations between regions and countries.[211] One HEI states that falsified documents are underreported in the VO.[212] The VO does not keep any statistics on falsified documents, nor has it followed the recommendation of the EAR Manual to set up a database of falsified document samples.

4.3.4 Selection based on credits and personal statement most common

When selecting candidates, HEIs must take into account the applicants’ qualifications.[213] The survey responses show that 76% of HEIs use previous academic credits as a selection criterion for international second-cycle courses and programmes. Personal statements are used as a selection criterion by 45% of HEIs, while grades and merit rating are used by 33% of HEIs in their selection.[214] Since the VO only registers 180 credits in the NyA system (even for students who have more credits), all third-country students have identical qualifications. Selection based solely on the number of credits thus means that students must be selected by drawing lots.[215] Several HEIs have pointed out that this approach is not compatible with a merit-based selection.[216] Based on our interviews and the survey responses, it is clear that, in practice, the number of credits is seldom the sole selection criterion. HEIs use the number of credits in specific subjects, in combination with other selection criteria, to rank students. A few HEIs state that they do not carry out their own qualification assessment and that selection is therefore sometimes done by drawing lots.[217]

The qualifications to be used in the selection process are set out in each course or programme syllabus. How qualifications are assessed and students are ranked can differ significantly. At many HEIs, the programme coordinators at the departments are tasked with ranking the students; they use, for example, point systems in which they score personal statements and previous academic credits, which are then weighted together.[218] There are also examples of centralised qualifications assessment, where admissions officers translate the academic grading systems of international HEIs to a common scale.[219]

4.4 Competition for places varies between HEIs, affecting quality

Our audit shows that there are significant differences in competition for places between HEIs. In many international programmes and courses, especially at new universities, there is no competition for places, and all those who are qualified are admitted. HEIs consider this to be a problem, as the selection situation that arises in competition for places leads to better academic conditions for the admitted students, thus contributing to a better quality of education.[220]

4.4.1 Selection leads to better quality, but is uncommon in international Master’s programmes

In our interviews, HEIs state that it is important to produce a situation in which applicants are selected, as this means that students who will be admitted have better prior academic skills and thus help maintain good quality in the education.[221] At the same time, both the UHR’s admission statistics and our interviews with HEIs show that there is often no competition for slots in international Master’s programmes.

The number of applicants per place varies between higher education institutions and is lower at new universities and other HEIs. At a majority of HEIs, there is no competition for places to more than half of their programmes (see Figure 7). Overall, the share of third-country students admitted to competitive programmes has been around 55−60% in recent years, which is an increase compared to the initial years after the introduction of tuition fees.[222]

Figure 7 Proportion of Master’s programmes with competition for places, international admissions autumn semester 2023

Source: The Swedish National Audit Office’s processing of UHR’s admission statistics.

The fact that selection is associated with better quality and better results is also confirmed by our statistical analyses. We have examined the retention rate in the fourth semester among students who were admitted to two-year Master’s programmes in the autumn semester of 2017, broken down by student group and whether there was competition for places. The retention rate was higher in programmes that had competition for places, across all student groups.[223]

4.4.2 Equal treatment of qualifications is legally certain but may mean that students are admitted without sufficient prior academic skills

When there is no competition for places, all qualified applicants must be admitted. Among admitted third-country students, the educational background may vary greatly. The quality of education differs between countries and HEIs, and a Bachelor’s degree is not always a guarantee of sufficient prior academic skills.[224] In our interviews, HEIs expressed that while equal treatment of qualifications from all recognised HEIs around the world is perceived to contribute to legal certainty and objectivity in admissions, but when there is no competition for places, it may also lead to the admission of students who have insufficient academic skills.[225]

Representatives of HEIs who have long worked with international students state that they recognise a pattern in which the performance of qualified students with different educational backgrounds varies. They explain that they sometimes admit students who they know in advance will not be able to complete their studies, because of their poor educational background.[226]Local staff at one Swedish embassy have also questioned why prestigious universities in Sweden admit students from foreign universities that, in their opinion, are of poor quality.[227] A similar picture emerges from the Swedish National Audit Office’s survey. Only half of the HEIs state that all students have sufficient prior academic skills to complete their academic studies. Students are sometimes reported to have well below the expected level of academic skills, even though they formally meet the entry requirements, according to the NBA’s recommendation.[228]

Nevertheless, as we have shown in Chapter 3, as a group, third-country students perform relatively well, so although some students may have poor prior academic skills, it is not a general problem.

The specific entry requirements must be used to ensure that admitted students have the necessary prior academic skills to be able to benefit from the programme. However, representatives of HEIs consider that specific entry requirements are not suitable to address the problem of lacking prior academic skills. Raising the entry requirements would instead exclude many qualified applicants.[229]

In our survey, 85% of HEIs state that they have taken measures to recruit third-country students with sufficient prior academic skills. The free text responses show that measures include targeted marketing to specific HEIs or countries where the quality of education is perceived to be high, and clear information to students about the required prior academic skills and the scope of their studies. Many HEIs also list the new requirements for acceptable qualifications in English as an example of a measure.[230]

4.5 Range of programmes partly meets future labour market needs

Our audit shows that most third-country students are enrolled in studies for professions in which there is an expected shortage or imbalance of skilled labour in the Swedish labour market in the long term. Interviews with HEIs show that while strategic decisions on the range and volume of programmes and courses are uncommon, adjustments are made as needed.

4.5.1 One in five third-country students graduate in fields in which a surplus of educated people is expected

To determine the potential contribution of third-country students to the Swedish labour market, we use Statistics Sweden’s assessments of future shortages or surpluses of educated people in various educational groups.[231] A majority of third-country students who graduated between 2017 and 2022 have a degree in a field that is assumed to be in balance or where there will be a shortage of labour. However, just over 20% of students have an education in a field where a surplus of educated people is expected.[232] These students are primarily represented in programmes in the social sciences, biological and environmental sciences, and architecture.

4.5.2 International courses and programmes initiated by academic departments

Higher education institutions decide on their own range of programmes (specialisations) and the volume (the number of places offered). Many HEIs address strategic objectives for internationalisation at a central level. However, our interviews show that the range of programmes may be decoupled from the overall strategic objectives, and that international programmes are often launched at the initiative of researchers at the departments.[233]

According to our interviews, there are few examples of programmes that were discontinued – mainly for economic reasons, because the programmes attracted too few students.[234] There are also examples of programmes which were discontinued because they attracted too many students who did not intend to study.[235]

HEIs can also rearrange their programmes and courses, or reduce the number of places to enable student selection. Our audit shows that HEIs strive to have many applicants per place and to enable making a selection.[236] Admitting fewer students is one possible solution, but at the same time, a certain volume is needed to be viable under current tuition fees. This means that reducing the number of places to individual programmes or courses is not always realistic.[237]

4.6 Follow-up of academic achievements is insufficient

Our audit shows that there is a lack of systematic follow-up of third-country students’ academic achievements both at national level and locally at the HEIs, and that no government agency has been tasked with carrying out regular follow-ups.[238] The lack of system support for cross-checking data is a contributing factor to the lack of follow-up at university level.

4.6.1 Follow-up is a prerequisite for quality-enhancing measures

The Swedish National Audit Office considers that if third-country students are to contribute to high quality in higher education, this requires a follow-up of their performance and, as needed, that measures be taken to ensure that students who are admitted have the appropriate prior academic skills.[239] This means that follow-up needs to take into account students’ previous academic achievements.

One HEI highlights the need for joint follow-up at national level, as it may be difficult for HEIs with few third-country students to determine whether the performance of students from a given country of previous education is due to individual variations or whether it reflects a systematic pattern.[240]

In the survey responses, another HEI stressed that the organisation should not focus on individual student groups, for example based on nationality, when monitoring student completion.[241] However, we note that among many HEIs, the matter of students’ country of previous education is an ongoing concern, as they are actively developing recruitment strategies aimed at specific regions and have even adjusted the requirements for English proficiency based on the country of previous education.[242]

The review of the conditions for acceptable prior knowledge of English was initiated after several HEIs notified the NBA that groups of students lacked sufficient English language skills to complete their studies in Sweden. In addition to the fact that the students failed in their studies, their lack of prior academic skills also had consequences for other students in the programmes, since, for example, group work could not be carried out as intended. The students’ inability to follow safety procedure instructions was also considered to be a problem.[243]

Ahead of the autumn semester 2020, requirements for students from Bangladesh were reinforced. However, this was not considered to be sufficient, and in autumn 2021, the NBA launched a general review of the English assessment recommendations. A consultation was performed to obtain information from HEIs to determine which student groups were concerned, and a comparison was made between Swedish requirements and requirements in the other Nordic countries, Europe and Anglo-Saxon countries. The NBA then decided on new recommendations as from the autumn semester 2024. However, there are instances in which HEIs do not fully follow the new recommendations, as they feel that they have an adverse impact on student groups that normally do well.[244]

Our analyses show that when qualification requirements for applicants from Bangladesh were raised ahead of the autumn semester 2020, the number of admitted students in that group fell by 65% compared with the previous year.[245] Reinforcing admissions ahead of the autumn semester 2024 coincides with a large drop in the number of admissions with qualifications from Pakistan (65%) and Sri Lanka (56%). These countries are among the most common countries of origin for third-country students and the amended entry requirements mean that students must pass an English language test.[246]

However, our analyses indicate that the stricter requirements regarding English for students from Bangladesh have not led to better academic achievements in the student group in question.[247] This suggests that the measure has affected the number of students admitted, but that the prospects for academic learning remain unchanged among the admitted students.

4.6.2 There is no support for systematic follow-up

In our survey, 36% of HEIs report that they follow up third-country students’ academic achievements on an annual basis at central level, 40% report that they have done so occasionally and 24% report that they have not followed up academic achievements.

The survey’s free text responses and HEI interviews show a large variation in HEIs’ follow-ups. One of the three HEIs that we studied in depth has begun a systematic follow-up of third-country students’ academic achievements, in which achievements are linked to the country of previous education, and recruitment strategies are adjusted accordingly.[248] The other two HEIs do not conduct systematic follow-up at the central level. On the other hand, both formal and informal follow-up at local programme and course level appears to be common, where academic teaching staff can see academic achievements more directly among different groups of students.[249]

Following up prior academic skills, prerequisites and academic achievements is impeded by the lack of possibility to easily link academic achievements to the country of previous education. Academic achievements are stored in Ladok, while information about the country of previous education is stored in the NyA system. HEIs explain that it is only possible to follow up academic achievements by manually linking up the data, or by engaging IT specialists to extract data from the systems and match individual information.[250]

4.7 Student composition is important for achieving internationalisation objectives

The preparatory work ahead of the tuition fee reform and the HEIs both express that a diversity of students with different backgrounds is a driving force of quality.[251] Our audit shows that the student composition varies between programmes. A majority of the programmes have students from both Sweden and other parts of the world, but there are also programmes without any Swedish students at all. Many HEIs note that when the student composition is imbalanced, this is often because students from Sweden and the EU/EEA show little interest in international programmes.

4.7.1 Student composition varies between programmes

The student composition varies significantly between different Master’s programmes. To study the student composition, we have examined the proportion of students from Sweden in a given programme. Swedish students study together with international students in a majority of the programmes (see Figure 8). However, a large proportion of programmes has only international students. On the other hand, many of the programmes with no students at all from Sweden are small, with fewer than ten registered students.

Figure 8 Proportion of Swedish students in second-cycle programmes, 2011−2022

Source: The Swedish National Audit Office’s processing of data from Statistics Sweden.

To gain a deeper understanding of how the diversity of students varies between programmes, we have also examined the student composition using a diversity index. This approach allows us to examine the student composition by dividing the students into more than two groups.[252] The index produces values between 0 and 1, where the value 1 indicates that all students enrolled in the programme come from the same geographical area. The closer the value is to 0, the more diverse the student composition of the programme.

Our analysis shows that the student composition varies between programmes.[253] Many programmes have an index value around 0.35, which is the same as the index value for the entire student population. In many programmes, all students come from the same geographic area (that is, the index value is 1). Almost all of these programmes are small, with fewer than ten registered students.

4.7.2 Lack of interest among students from Sweden and the EU/EEA affects student composition in international programmes

Although many programmes have a diverse student composition, there are exceptions. When we ask about challenges in promoting a mixed student group, HEIs state that it is difficult to attract Swedish students and EU/EEA students to the international programmes; that the lengthy application process leads many third-country students to choose a different study destination; that the Swedish Migration Agency’s processing times are a problem; and, that the international image of Sweden has recently deteriorated.[254]

Student composition is also affected by the possibility of scholarships. African applicants are often dependent on receiving a scholarship to accept their place of study.[255] For students from China, on the other hand, the university’s international status is the determining factor; even if the student is offered a scholarship, they can choose a higher ranked university.[256]

In our survey, HEIs respond that they use targeted marketing (for example to countries or regions), advertising in both the international and national admissions rounds, and separate admissions in order to promote a mixed student composition. Interviews with HEIs and the survey’s free text responses show that technology programmes apply ‘joint studies’, meaning that Swedish engineering students spend the last two years of their five-year programme studying together with international Master’s students.[257]

4.8 HEIs’ efforts to promote admission of students who intend to study

HEIs’ remit does not include assessing students’ intention to study – it is the Swedish Migration Agency’s responsibility. On the other hand, it is in the HEIs’ interest for admitted students to register and not drop out of their studies. Our audit shows that HEIs adapt their activities to encourage students who are admitted to have study intentions.

4.8.1 HEIs take measures to attract students who intend to study

In our survey, several HEIs state that it is unusual for admitted students who have paid tuition fees not to show up for registration.[258] At the same time, several HEIs state that they have taken measures to promote the admission of students who intend to study. For example, they direct their student recruitment towards countries where there are students who they assess generally intend to study, they have introduced mandatory roll call at registration or have adapted their range of programmes and courses by discontinuing courses that have attracted students who do not intend to study.

In addition, our analyses indicate that there is a connection between competition for places and problems of study intention at the HEIs. Among HEIs in our survey that stated that it is very unusual for students to be admitted and pay the tuition fee but not to register, there is competition for 55% of the Master’s programmes. Among HEIs that stated that it is very common for students to be admitted but not to register, there is competition for only 26% of the programmes.[259]

5. Swedish Migration Agency’s procedure for processing residence permits for studies

Our findings in this chapter show that the Swedish Migration Agency’s procedure for processing student cases functions properly on the whole, but is lacking in terms of verification related to accompanying family members of students. The main problem is that case officers have limited documentation on which to assess the relationship.

We find that the responsibility for issuing residence permits involves a complex balance between striving for shorter processing times and managing a thorough examination of applications from students and their accompanying family members. The Swedish Migration Agency is shifting towards a more uniform approach to initiating a study intention investigation, which also aims to shorten processing times. Our interviews show that there are differing views regarding the new approach. However, we cannot comment on how the new approach affects the quality of the processing, as we have not yet seen the effect of the adjustments.

Furthermore, the Swedish Migration Agency relies on Swedish embassies to obtain an accurate and objective basis for an application. If this cooperation is inadequate, it makes it difficult for case officers at the Agency to make informed decisions. Our audit shows that there is a lack of efficient cooperation between the Swedish Migration Agency and Swedish embassies in student cases, in particular with regard to dialogue between case officers and local staff.

5.1 Operationalised assessment criteria

Based on the overall assessment criteria described in Chapter 1, we use the criteria described below to assess the effectiveness of the Swedish Migration Agency’s processing procedure[260] for residence permits for studies.

5.2 Increasing number of applicants do not receive a decision within 90 days

A majority of the Swedish Migration Agency’s cases are decided within the statutory time limit of 90 days.[262] Between 2013 and 2023, 15% of those who applied for a residence permit for studies did not receive a decision within 90 days. However, this proportion has increased over time; in 2013 the proportion was 8%, while in 2023 it was just over 30%.[263] On the other hand, the Swedish Migration Agency has presented statistics indicating that processing times might be shorter in 2024.[264]

5.2.1 Processing times are increasing

In 2023, the Swedish Migration Agency’s median processing time for first-time applications was 55 days.[265] In our neighbouring countries, the processing time is at similar levels as in Sweden. In Denmark, residence permits for studies take about 2 months to process and in Finland processing takes 1−3 months. In Australia, the Netherlands and the United Kingdom, processing is significantly shorter, averaging 2−3 weeks.[266]

Applications to extend a residence permit took considerably longer; the median processing time was 136 days in 2022.[267] According to some case officers whom we interviewed[268], this is because first-time cases must be given priority, so that students who want to start studying can enter Sweden and enroll. The fact that the processing of extension applications is given a lower priority means that students who want to continue their studies in Sweden find it more difficult to plan their studies and travel outside Sweden.[269]

Over the past ten years, processing times have increased for both first-time and extension applications, apart from 2017 and 2020. The decline in 2020 is likely due to a lower number of applicants during the COVID-19 pandemic.[270]

5.2.2 More cases are being dismissed

Whereas processing times have increased, our analyses show that a lower proportion of applicants have been granted a residence permit for studies (see Figure 9). An application may be granted, rejected or dismissed. When a case is not decided before studies begin, the student loses their place of study and the case is usually dismissed by the Swedish Migration Agency.[271]

Figure 9 Percentage of granted, rejected, dismissed residence permits, broken down by year the application was received (only includes freemover students with residence permits for higher education studies)

Source: Swedish National Audit Office processing of data from the Swedish Migration Agency.

One factor that may be relevant is that priority is given to processing cases in which the decision to grant a residence permit is clear cut, according to our interviews at the Swedish Migration Agency.[272] This means that case officers postpone dealing with cases that are likely to result in a rejection. This may involve, for example, individuals who have been investigated at an embassy and where the evidence suggests that the case will be rejected.[273] A rejection needs to be justified individually, which takes more time, and case officers consider favourable decisions more important to process before the start of the academic semester. Some interviewees point out that probable rejection decisions are thus obscured in the statistics on dismissed cases.[274]

The Swedish Migration Agency’s goal is for applicants to receive their application decision before the start of the semester.[275] However, producing a decision before the start of the semester is contingent on when the student applies for a residence permit and the applicant submitting any requested supplementary documentation from the Swedish Migration Agency in time.

In our interviews and the survey responses, several universities state that their admitted students are not granted a residence permit in time and that this pattern has accelerated in recent years.[276] For example, at one university, 223 out of 871 students had not received a decision from the Swedish Migration Agency before the semester began in autumn 2023.[277] According to the universities, problems concerning students not being granted a residence permit in time vary between years and between units at the Swedish Migration Agency.[278]

5.2.3 Differing explanations for increasing processing times

In our audit, the Swedish Migration Agency offers various explanations for the increasing processing times and proportion of dismissals. According to the Digitalisation and Development Department, there are tendencies towards excessive investigation during processing. For example, more applicants are referred for a study intention investigation than would have been necessary.[279] Their assessment of excessive investigation is mainly based on a report in which the Legal Affairs Department at the Swedish Migration Agency examined cases concerning students from Sri Lanka. Unnecessary requests for additional documentation and orders for embassy investigations were identified as circumstances that prolonged processing times.[280] The report concluded that less time- and resource-consuming measures should be taken before resorting to an embassy investigation.[281] However, other employees at the Swedish Migration Agency highlight other reasons, such as poorly resourced processing units at the Agency.[282]

The collaboration group for the Swedish Migration Agency and the SUHF has identified a number of measures to shorten processing times for residence permits.[283] One measure involves reorganising how HEIs are classified at the Swedish Migration Agency, to allow more units to process a case. Another problem that was raised in the collaboration group is that the residence permit cards are delivered to Swedish embassies too infrequently during the summer months, prolonging the process.[284] Students from countries from which visas are required need this card to enter Sweden.[285] The Ministry for Foreign Affairs decides how often they are to be delivered.[286] Measures to shorten the time for applicants to receive their residence permit card are also given priority in the collaboration group.[287] We cannot comment on whether these measures are sufficient to shorten the processing times. At the same time, we see the advantages of HEIs and the Swedish Migration Agency jointly identifying where the process can be streamlined.

5.3 Swedish Migration Agency’s processing procedure functions properly for students, but could be improved for accompanying family members

Our audit shows that the Swedish Migration Agency’s procedure for processing residence permits for studies is, in general, comprehensive and functions properly in distinguishing serious from unscrupulous students. However, we note that the Agency’s checks of students’ accompanying family members are insufficient.

5.3.1 Processing procedure for students overall is comprehensive

The procedure for processing cases involving students and their accompanying family members is described mainly in two handbooks that are available on the Agency’s intranet.[288] Interview templates used in study intention and family affiliation investigations held at the embassies are also included in the procedure.[289]

Our interviews with case officers at the Swedish Migration Agency show that the procedure concerning student applications functions properly. The procedure is regarded as being sufficiently comprehensive. At the same time, not everything can be covered in a handbook. There are many individual, regional and study-related circumstances that a case officer must consider.[290] This places demands on the case officer’s experience and expertise.

Local staff at Swedish embassies follow the Swedish Migration Agency’s interview template and assert that it is both comprehensive and functions properly. The interview template is regarded as an open interview guide, in which local staff can add questions based on the local context in the country.[291] During the actual interview, there is also a great deal of leeway for local staff to ask follow-up questions tailored to the circumstances.[292] Local staff can comment on their perception of the interview, but do not make any assessment of their own.[293]

5.3.2 Swedish Migration Agency’s control of accompanying family members of students is insufficient

Over time, the number of accompanying family members of students who apply for and have been granted a residence permit has increased.[294] The proportion of accompanying family members per student increased sharply during the period 2013−2023. In 2013, approximately one accompanying family member per eight students applied for and was granted a residence permit. In 2023, the corresponding figure was approximately one accompanying family member per five students.[295]

The Swedish National Audit Office considers that there are incentives for people to use the system for purposes other than those intended. In some countries, for example, Sweden is marketed as a ‘come-two-pay-for-one’ country, because family members are exempt from tuition fees if they choose to study.[296] When a student has had their residence permit revoked, it has not been possible for the Swedish Migration Agency to revoke the permit for accompanying family members who have entered Sweden.[297] Human trafficking is also widespread in some regions.[298] This makes it particularly important for the Swedish Migration Agency to carry out effective controls.

The Swedish Migration Agency’s procedure contains scant information on how to process accompanying family members of students.[299] Case officers are referred to procedure handbooks used in affiliation cases for legal assessments of marriage and cohabitation, as well as guidance on when to consider additional face-to-face interviews.[300] However, we find that these handbooks are not applicable to student cases. Much of the material needed to investigate a relationship is not available, and several of the indicators described are not possible for the Swedish Migration Agency to verify, based on the content of a student case.[301]

Case officers at the Swedish Migration Agency have limited documentation on which to base their initial assessment of a relationship and determine whether there are grounds to further investigate a relationship. Case officers only have access to answers to a few questions in the application form concerning the relationship of cohabiting partners and the applicant’s copy of a marriage certificate or supporting documents proving cohabitation.[302]

Our interviews with case officers confirm this picture. They call for more information in the application form about the relationship and about accompanying family members’ background, such as questions about education and work experience. This would make it easier to investigate whether the person poses a security risk.[303] Case officers whom we have interviewed state that the main indication for requesting a face-to-face interview is that the couple has married shortly before the application.[304]

We note that the Swedish Migration Agency asks the student few questions about their relationship to accompanying family members. Students subjected to a study intention investigation are asked a few questions about their family background. However, other students, who only present their passport at a Swedish embassy, are not questioned at all about their relationship beyond the questions in the application form. On the other hand, if accompanying family members apply at a later date than the student, the Swedish Migration Agency contacts the student in Sweden and asks a verifying question.[305] When family affiliation is investigated at a Swedish embassy, the student answers questions about their affiliation.[306] However, few accompanying family members are investigated − about two per cent in recent years.[307]

Students and their accompanying family members usually apply together.[308] However, some Swedish embassies do not have time to investigate accompanying family members during the peak season for student applications.[309] An interview is then scheduled after the summer. This may have adverse consequences, as the student will need to be separated from their accompanying family members, including underage children, for a longer period of time.

5.4 Initiating an investigation is more uniform, but does not necessarily lead to better quality

In 2023, the Swedish Migration Agency amended its procedure for initiating a study intention investigation, aimed at more uniform processing. Previously, case officers had more flexibility to assess whether there was reason to question the study intention. Views on these procedural amendments differ among the case officers. However, we have not been able to evaluate their impact as they were not fully implemented at the time of this audit.

5.4.1 More investigations of study intentions

The proportion of study intention investigations increased between 2020 and 2023. In 2020, 10% of freemover students were investigated, while the corresponding proportion was just over 33% in 2023.[310] In 2022 and 2023, the Swedish Migration Agency carried out two operations in Islamabad and Abuja, in which all applicants’ intentions to study were investigated at the Swedish embassies. The rise in the number of investigations is likely explained by the fact that these embassies generally account for a large number of applicants.[311] In addition, the Swedish Migration Agency’s own statistics indicate that there will be fewer investigations in 2024.[312]

Our analyses show that the proportion of study intention investigations varies greatly based on the applicant’s citizenship. Applicants from Nigeria, Pakistan and Sri Lanka are overrepresented, which is likely partly due to the operations in Islamabad and Abuja.[313] Among all applications referred for study intention investigation, 54% resulted in a rejection decision, while 32% were granted a residence permit. The remaining 15% were dismissed.[314]

5.4.2 An indicator-based approach

The Swedish Migration Agency’s handbook lists a number of indicators that indicate either a lack of intention to study or an intention to study. The indicators have been formulated as examples. One example of a lack of intention to study involves an application containing a broad range of academic subjects that are unrelated to the student’s previous education, whereas an applicant’s receipt of a scholarship from recognised scholarship providers in Sweden indicates an intention to study.[315]

Despite the presence of established indicators, our audit shows that the Swedish Migration Agency’s case officers have had considerable scope to gauge applicants’ intention to study on the basis of their application. Case officers whom we have interviewed state that they base their assessment on previous patterns in similar cases, for example if a person applies to an academic programme with a high drop-out rate. They also explain that they take into account information about previous employment and studies, as well as the reason for their choice of academic programme or course as stated in their application.[316]

In line with the Swedish Migration Agency’s procedure, no risk assessment of intention to study is made based on the applicant’s country of previous studies.[317] Nevertheless, the Swedish Migration Agency considers the risk to be greater if the person is applying from a country that requires a visa for entry to Sweden compared to applicants from visa-free countries. In their assessment, case officers have also been able to take into account country-specific information relating to the risk of falsified documents and risks linked to human trafficking.[318]

5.4.3 New procedure for initiating a study intention investigation

In 2023, the Swedish Migration Agency updated its processing procedure for initiating a study intention investigation. The aim is to reduce the number of cases that are excessively investigated, in other words, cases in which the case officer has taken more measures than necessary to make a decision on the case. This update should reduce the burden on Swedish embassies and shorten processing times.[319]

One clarification in the procedure requires that verification of document authenticity be completed before any study intention investigation is carried out.[320] At one unit, this approach is already being used and is being said to function well.[321] Some case officers whom we interviewed state that verifying document authenticity before initiating an investigation, including bank statement verification, will entail a major adjustment in how they process cases. Waiting for Swedish embassies to help verify bank statements, or check other documents, may take time, and it is more efficient to order an investigation while the documents are being verified.[322]

A review has also been performed by the Swedish Migration Agency on the indicators, pointing to a lack of intention to study. On the whole, the indicators in the updated procedure are the same as in the old procedure.[323] The major difference is that the updated procedure stipulates that only the specified indicators are to be used as a basis for deciding whether to initiate an investigation, unlike previous wordings, which instead exemplified weak points in the intention to study.[324]

The case officers have differing views on the amendments related to the indicators. Some of our respondents believe that the change is too controlling. They state that, to obtain an overall view of a case, it may be important to consider circumstances other than the indicators.[325] In other interviews, case officers state that it is too early to determine the effects of the amendments because they have not yet been fully implemented.[326]

5.5 Staffing is adequate but effective cooperation with missions abroad is lacking

Case officers at the Swedish Migration Agency and local staff at Swedish embassies whom we interviewed consider that staffing is currently adequate. However, there are challenges for the missions abroad to keep up with the study intention investigations since they lack premises for conducting interviews.

Our audit shows that the Swedish Migration Agency’s case officers do not receive training about circumstances in different countries that they may need in order to assess the study intention and the relationship to possible co-applicant family members. This means that they are reliant on Swedish embassies’ local knowledge. The Swedish National Audit Office considers that local knowledge at Swedish embassies can be utilised more effectively. For example, we consider that cooperation between case officers at the Swedish Migration Agency and local staff at Swedish embassies can be developed.

5.5.1 Staffing is currently adequate but has not been so before

All case officers at the Swedish Migration Agency that we interviewed only process residence permits for studies, although they have previously worked with other types of cases.[327] The number of case officers working with residence permits for studies has increased over a longer period, as more people apply to study in Sweden.[328] Case officers in all four units whom we interviewed state that they currently have adequate number of staff.[329] Staffing has varied over the years and several of the interviewees state that they have previously had a heavy workload.[330] At one unit, case officers describe that the workload was affected by the fact that they previously worked with several different types of cases at the same time.[331]

The admission process for higher education is designed so that the embassies have a short window of around two to three months to process all applicants. In addition, locally employed migration assistants process visas, affiliation cases and other tasks. They carry out these tasks in parallel with residence permits for studies, although during the peak season, their main focus is on students in order to process the applications before the start of the semester.[332]

Our interviews at the embassies show that the local staff also believe that staffing is currently sufficient. Some of them consider that there have been periods in the past when the work situation was more strained.[333] According to the interviews, the problems are rather a lack of premises. At two of the embassies, for example, there are only two rooms available for conducting interviews. This situation becomes particularly challenging if many investigations are initiated towards the end of the season.[334] Under such circumstances, it may also have an adverse effect on the quality of the investigations.[335]

5.5.2 Training on conditions in different countries is lacking

There are no centrally produced training courses by the Swedish Migration Agency that focus on processing student cases.[336] Each permit unit produces its own training material and introduction programmes, held by decision-makers or experienced case officers.[337] It is also common for new case officers to work alongside a more experienced colleague to learn how to process different types of permits.[338]

There is also a lack of training on the circumstances of different countries that case officers may need to be familiar with in order to assess the study intention and the relationship with possible co-applicants. Case officers can search for some country information in the Swedish Migration Agency’s LIFOS database[339], but the Swedish National Audit Office considers that knowledge is also needed on matters such as how education systems operate in different countries, the presence of recruitment agents, manipulated documents and relationship patterns.

Some employees at the Swedish Migration Agency have also stated that local knowledge is needed to interpret the content of interviews held at the Swedish embassies. Local knowledge is also required to be able to interpret the documentation in the applications and to identify which students need to be subjected to investigation.[340]

5.5.3 Local staff competence and local knowledge is an important prerequisite for making correct assessments

The Swedish National Audit Office notes that the competence of local staff at Swedish embassies is important for ensuring that case officers at the Swedish Migration Agency have sufficient information to make correct decisions. The Swedish Migration Agency does not examine original documents and does not interview applicants.

According to the embassy staff, it is difficult, but possible, to identify and distinguish serious students from unscrupulous ones. It can be a matter of reading body language to determine whether a person is speaking haltingly because they are nervous or for some other reason. If applicants’ answers appear rehearsed and unrelated to the interview questions, it may also be an indication of an unscrupulous student.[341] In some countries, the questions need to be regularly reordered or rephrased because they have been leaked on social media or to recruitment agents.[342]

Although we cannot speak for the skills supply at every Swedish embassy, many of those whom we interviewed were long-term employees at the embassy. They are also experienced in conducting investigations and demonstrate an awareness of quality aspects in interview techniques.

The Swedish Migration Agency is responsible for providing training on migration issues to local and posted staff.[343] Local staff whom we interviewed state that they receive training by the Swedish Migration Agency and that they also participate in training courses held by other parties, such as in collaboration with other countries’ embassies or with the border police in the country.[344] The embassies also sometimes use co-listening during interviews.[345] The local staff state that they receive adequate training, although some of our interviewees would like to see further in-depth training of interview techniques.[346]

5.5.4 Too little dialogue between local staff and case officers

Our audit shows that there are no organised forms of dialogue between the Swedish Migration Agency and the missions abroad in individual cases. If cooperation is lacking, this makes it difficult for the Swedish Migration Agency’s case officers to make informed decisions, as they do not meet the student themselves and therefore do not have the opportunity to ask critical and investigative questions. In addition, we consider that it is important for the Swedish Migration Agency to take advantage of the Swedish embassies’ local knowledge, as they themselves lack training on the circumstances of different countries.

There are no regular meetings between case officers at the Swedish Migration Agency and local staff at Swedish embassies. Previously, meetings were held, attended by representatives of a range of the major missions abroad, representatives of the permit units, representatives of the Units for Foreign Operations[347] and the Swedish Migration Agency’s headquarters. However, these meetings no longer take place.[348]

Furthermore, the Swedish Migration Agency’s case officers can provide feedback on individual interviews about the study intention, but our audit shows that this is done without any contact with the local staff. Feedback is provided via the Digitalisation and Development Department at the Swedish Migration Agency’s head office to the posted staff at each embassy.[349] Based on our interviews, we find that feedback on interviews takes place a few times a year, often towards the end of the season. The Swedish National Audit Office considers it important that local staff receive feedback so that they may know whether the information they submit to the Swedish Migration Agency is useful for assessing the study intention.[350]

Some of the interviewees highlight that they would like to see more communication and cooperation with the permit units at the Swedish Migration Agency. They believe that a better understanding of each other’s activities is needed to avoid misunderstandings as to what is possible to investigate at an embassy.[351] Furthermore, they point out that they need to meet in order to plan their activities better and discuss current issues.[352] A couple of embassies also wish to receive more feedback from the Swedish Migration Agency on their interviews.[353]

Some of the interviews reveal that it can be difficult for local staff to know how much scope they have to deviate from the interview template and ask follow-up questions in a study intention investigation.[354] Some staff may also be apprehensive of making mistakes.[355] Even if they have a mandate to ask follow-up questions, the case officer at the Swedish Migration Agency may wonder why they spent a lot of time asking questions about a particular area.[356] This is an example of issues that could be discussed if there was more communication between case officers at the Swedish Migration Agency and local staff.

6. HEIs’ work related to tuition fees and reimbursements

In this chapter, our findings show that HEIs seldom identify the actual costs of their activities funded by tuition fees. Our audit also shows that HEIs apply the Ordinance on application fees and tuition fees at higher education institutions differently regarding the conditions for repayment of tuition fees.

6.1 Operationalised assessment criteria

Based on the overall assessment criteria described in Chapter 1, we use the criteria described below to assess whether HEIs set their tuition fees for third-country students to provide for full coverage of costs and how HEIs handle reimbursement of tuition fees.

6.2 Challenges in setting tuition fees and variations in student volume can lead to imbalances

Our audit shows that HEIs rarely identify the actual costs of third-country students, and that there are challenges linked to balancing surpluses or deficits over time. The Swedish National Audit Office has not examined in detail how the costs are reported. However, we see no indication that universities are using revenue from the fee-funded activities to finance other parts of the organisation. On the other hand, departments with many fee-paying students may have more extensive activities and, for example, employ more researchers to teach than they would otherwise have done.

6.2.1 Flat-rate tuition fees are common

HEIs use two different types of costs when determining tuition fees. One cost refers to the cost of the education itself. The second cost, a ‘specific cost’, includes an administrative surcharge intended to cover costs specifically incurred by fee-paying students within the central administration of the university. Examples of such costs include international student recruitment and administration linked to the management and reimbursement of the tuition fee.[358] This specific cost may also include services specifically aimed at that student group, such as housing services or language support.[359] The cost of education accounts for the largest share of the tuition fee, while the specific cost accounts for a smaller share.[360]

Our audit shows that HEIs often determine the cost of education based on the reimbursement for Swedish students in different fields of education. They then add a flat rate for the specific cost.[361] Some HEIs use more advanced calculations to determine tuition fees, based on estimates of actual costs and forecasts of the number of students. However, this is uncommon.[362] A couple of the universities that we interviewed state that calculating the cost of each third-country student would be very administratively burdensome.[363]

One university points out that the academic departments risk having higher education costs for third-country students than they actually receive revenue for, as students from different backgrounds may have different needs for support in their education.[364] At the same time, most third-country students study alongside Swedish students, suggesting that the cost of education should not differ significantly.[365] Moreover, the marginal cost for additional students is likely to decrease, which may compensate for any additional costs for third-country students.[366] Furthermore, our survey and interviews show that HEIs have varying approaches to revising their tuition fees. Some HEIs state that they review tuition fees annually, while others review them less frequently. Several HEIs review tuition fees at the same time as public reimbursements for Swedish students are being updated.[367] In their overview of tuition fees, some HEIs take into account the pricing of other HEIs, both at the national and international level.[368]

6.2.2 Uncertainty in reported results

When reporting the education costs of activities funded by fees, HEIs often apply flat rates. The academic departments report the cost as corresponding to the revenue they receive for their fee-paying students, which in turn has been calculated based on the reimbursement amounts for Swedish students in the corresponding field of education. As a consequence, the reported surpluses and deficits arise only in the activities that are itemised in the central administration. Consequently, it is not possible to assess whether the activities, in their entirety, achieve full coverage of costs, since accounting on a flat-rate basis may involve uncertainty in the reported profit. However, there are exceptions. For example, one of the interviewed universities performs a post-calculation and distributes the actual costs of the education proportionally based on the number of fee-paying students at the departments.[369]

6.2.3 The challenges of balancing surpluses and deficits over time

Under the Fees Ordinance, government agencies that may use income from activities subject to fees must submit a proposal to the Government on how the accumulated surplus from activities subject to fees will be allocated when it amounts to more than 10% of turnover. When a deficit arises that is not covered by a balanced surplus from previous years, government agencies must submit a proposal to the Government on how the deficit will be covered.[370] Universities and other higher education institutions must submit proposals in their annual report on how any surpluses and deficits will be used or covered.[371]

In 2023, 12 of the HEIs included in our audit reported an accumulated deficit or surplus in their tuition fee-funded activities that exceeded 10%. Among these, eight HEIs had an accumulated surplus of 20−70% of revenue. Two HEIs had an accumulated deficit exceeding 20% of turnover.[372]

In our interviews, HEIs state that although they try to balance their activities, there are challenges. For example, there is uncertainty concerning the development of the number of students subject to tuition fees.[373] HEIs state that the number of third-country students varies both from year to year and within different academic programmes. Circumstances in the rest of the world and the COVID-19 pandemic have affected the number of people who have started studies at Swedish HEIs. The Swedish Migration Agency’s processing times also add to the difficulties in estimating how many students can start their education in a given year.[374] All the same, HEIs have fixed costs for functions such as recruitment and marketing, so when revenues fluctuate with the number of students, it can lead to a surplus or deficit.

A couple of the universities that have a surplus explain that it has arisen due to an increase in the number of students, and they have not had time to fully reinvest in their activities.[375] Universities with an accumulated deficit that we interviewed have cited empty student housing as a contributing factor. The universities have entered into agreements with landlords to offer housing to students, and when there are not enough students, the university bears the cost.[376]

To achieve a balance, the tuition fee can be adjusted. However, it takes time for adjustments to the tuition fee to have an impact, as they apply to future students. In the long term, the number of students may also have changed compared to when the review of fees was initiated.[377]

6.3 Local regulations for tuition-fee activities

There have been no major amendments to the Ordinance on application fees and tuition fees at higher education institutions since its introduction.[378] However, in 2018, the SUHF adopted recommendations on the management of certain fee-paying students and fee-paying education. The recommendations state that there must be a local regulatory framework for handling students subject to tuition fees, the deadline for paying tuition fees and fees that are to be paid in connection with a deferment of studies.[379]

All HEIs included in the audit have guidelines or decisions on tuition fee activities, including the reimbursement of the tuition fee.[380]

6.3.1 Reimbursement cases drain administrative resources

Under the Ordinance on application fees and tuition fees at higher education institutions, HEIs may reimburse all or part of the tuition fee if a student is prevented from attending the academic programme or course for special reasons.[381] Our survey shows that almost all (97%) universities have introduced central guidelines for repayment of tuition fees. One university stated that repayment matters are decided locally by its faculties or departments. In the survey and in interviews, universities state that the most common reason for repaying tuition fees is that the student’s application for a residence permit has been rejected, or they did not receive it in time. Other common reasons for reimbursement are a change of residence permit for studies to another type of residence permit, cancellation of a programme or course, or illness.[382]

According to the universities, cases concerning repayment are very resource-intensive. In our survey and in interviews, the universities state that they need to process numerous cases of repayment because many admitted students are not notified about their residence permit in time. Each individual case takes time. For example, processing international banking transactions may require a lot of administration. It can also take a long time for students to receive their reimbursement.[383]

6.3.2 HEIs apply different reimbursement rules

The conditions for reimbursement are not clearly regulated in the Ordinance on application fees and tuition fees at higher education institutions. The universities that we interviewed apply the conditions for repayment in various ways. For example, one HEI accepts all applications for reimbursement up to the time of registration, regardless of the grounds, while other HEIs are more restrictive about the grounds they accept.[384] For example, the student may be ill with a doctor’s certificate or may withdraw their application to the Swedish Migration Agency for a residence permit when they do not receive a decision.[385]

Another circumstance in which HEIs’ conditions vary is when a student has not registered, but has entered the country and wants a refund. In one university’s interpretation of the legal framework, they could not deny a refund, since the student had not confirmed their place at roll call, regardless of whether or not they have entered the country.[386] Another university determined that the student needs to return their residence permit card at the embassy to receive a refund.[387]

In 2018, there were legal proceedings before the Supreme Court on whether a third-country student should be reimbursed their tuition fee due to a lack of quality in the education. The Supreme Court decided that the student would be reimbursed a large share of the fee by the HEI. The justification was that the programme of study was issued a poor-quality assessment in an evaluation by UKÄ and furthermore, the Agency questioned the university’s authority to issue a degree.[388] We have not found any indication in our audit to suggest that the judgment has had any significant impact on HEIs’ conditions for reimbursement.

6.3.3 Lack of national guidance on reimbursement

The universities that we interviewed are calling for a national guidance on matters relating to the reimbursement of tuition fees since it is not covered by the Ordinance on application fees and tuition fees at higher education institutions.[389]

Our audit finds that there is no legal guidance on the interpretation of special reasons for the repayment of tuition fees. Under the Ordinance, each HEI may choose to repay the tuition fee and thus determine what constitutes a special reason. A representative of one HEI explains a call for national guidelines to prevent HEIs from competing with generous reimbursement rules.[390] The Swedish National Audit Office notes the importance of transparent and clear information to the student on the circumstances under which their tuition fee can be refunded. In addition, the timing of an application for a refund is not regulated. The UKÄ has noted that there is no authorisation in any law or regulation for an HEI to determine that an application for reimbursement must be received by the HEI within a given timeframe.[391]

According to the SUHF, additional costs may arise in connection with repayment for which the HEI can charge the student.[392] This could lead HEIs to charge an administrative fee, thereby not refunding the full tuition fee. Among the interviewed universities, whether or not they charge an administrative fee varies.[393] Some representatives of interviewed universities also call for regulation on whether administrative fees should be charged when requesting reimbursement, as the universities have different interpretations of the legal framework.[394]

7. Conclusions and recommendations

The Swedish National Audit Office’s audit shows that third-country students perform well academically and constitute an important pool for recruitment for continued research and work in Sweden. Students from different parts of the world are enrolled in the majority of courses and programmes which, according to the Riksdag, contributes to the quality of the education. At the same time, the Swedish National Audit Office considers that there are shortcomings in the system which prevent the objectives of internationalisation from being fully met. Therefore, the overall conclusion of the Swedish National Audit Office is that the education system for third-country students in higher education is not fully effective.

The lengthy admission and migration processes make it difficult for Swedish higher education institutions to compete for qualified students. Likewise, insufficient information to applicants is a competitive disadvantage as students, in the meantime, may be admitted to universities in other countries.

Our audit shows shortcomings in HEIs’ ability to follow up third-country students’ academic achievements. In addition, the Government has not prioritised national follow-up of academic achievements. As a consequence, it is difficult for relevant actors to know how third-country students are performing in their studies and to what extent they are contributing to the quality of education.

The Government has recently focused on curbing the potential misuse of residence permits for studies. The Swedish National Audit Office finds no clear support for the existence of extensive abuse. However, there is a grey area in which it is difficult to determine whether the system is being misused; the small number of third-country nationals who drop out of their studies at an early stage and start to work in unskilled occupations may be motivated either by a lack of intention to study when applying to Swedish universities or by difficulties in completing their studies.

7.1 Challenges in recruiting qualified students

The Swedish National Audit Office considers that the admission of third-country students functions properly, but that several shortcomings in the system make it difficult to recruit qualified students.

7.1.1 Several obstacles in the global competition for students

Our audit has identified shortcomings in the system that impede the recruitment of third-country students. The admission process as a whole is long, and the information provided to applicants is inadequate. There is a risk that Sweden is losing qualified students to competing universities in other countries where the process is more expedient and transparent. To strengthen Sweden’s ability to attract students, the 2018 Inquiry on the internationalisation of Swedish higher education institutions proposed a cross-agency website for the relevant government agencies, which would make it easier for students to follow the progress of their application. The Swedish National Audit Office shares the Inquiry’s assessment that the entire process – from application to a course or programme to receipt of a decision from the Swedish Migration Agency – needs to become more transparent and applicant-friendly.

The centralised assessment of foreign qualifications performed by the VO is an efficient approach. However, in the long term the VO should consider further streamlining its tasks by automating parts of its manual processing, for example through computational reading of documentation from well-known universities. This could reduce processing times and help speed up the process. To ensure that qualified students come to Sweden, the UHR should also consider establishing a database of examples of falsified academic documents, as there is a risk that falsified documents will be accepted.

The early application period in the current system, aimed at third-country students, is a key condition to allow students to receive an admission decision and apply for a residence permit in time. Nevertheless, the period between the admission decision and the final tuition fee payment date is unnecessarily long; up to two and a half months for students applying to HEIs that follow the SUHF’s recommendation on a final payment date. During this period, the process does not advance, unless the student chooses to make their payment before the final payment date. By bringing forward the final payment date, HEIs can speed up the process, with the aim of ensuring that more applications for residence permits can be submitted within a reasonable time before the start of the semester.

7.1.2 Swedish Migration Agency’s processing times prolong the process and complicate matters for students

The Swedish Migration Agency’s processing times for applications for residence permits for studies is the single most important reason for the lengthy process. Moreover, processing times have increased over a ten-year period, even more so in recent years. The Swedish National Audit Office notes that processing times in extension cases have also been lengthy, which may adversely affect students, making it difficult for them to enter Sweden after, for example, returning home during the summer break. The Swedish National Audit Office has not been able to identify any clear-cut reason for the longer processing times, as various explanations have been put forward within the Agency.

The proportion of student cases dismissed by the Swedish Migration Agency has increased in recent years. When a case is not resolved before the start of the semester, the student loses their place of study and the case is then usually dismissed by the Swedish Migration Agency. Regardless of the outcome of the decision, it raises difficulties for students in planning their future and constitutes a financial burden for them before the tuition fee has been reimbursed.

It is the assessment of the Swedish National Audit Office that some of the measures developed within the cooperation between the Swedish Migration Agency and the SUHF have the potential to reduce processing times, and the Swedish Migration Agency’s statistics for 2024 seem to point in that direction. Two-year residence permits should free up resources for case officers at the Swedish Migration Agency and thus help speed up processing times. Students who are granted two-year permits could more easily plan their stay in Sweden. Both factors help to strengthen Sweden’s ability to compete globally for third-country students. At the same time, longer residence permits mean that students need to have a higher amount of funds in their bank account to meet the maintenance requirement for a longer period.

7.2 Third-country students successfully complete their studies, but various quality components of the system are inadequate

Our audit shows that, overall, third-country students do well in their studies and, to a large extent, either continue to doctoral studies in Sweden or join the Swedish labour market. At the same time, certain quality components of the education system for third-country students are inadequate.

7.2.1 Third-country students manage their studies well and many proceed to doctoral studies or work

While students from third countries perform at least as well as Swedish students in their studies, there are major differences within that group. Students from Pakistan and Bangladesh do not pass and complete their studies to the same extent as other third-country students.

Nearly 45% of third-country students remain in Sweden five years after starting their studies; by then, a large proportion of them have either begun doctoral studies or joined the labour market. Many third-country students who start doctoral studies do so in the subject area of technology, while many of those who start working do so in professions that require a higher education in natural sciences, technology or IT. In line with the intentions of the Riksdag, third-country students thus constitute an important recruitment pool for further research and work in Sweden in the field of technology.

7.2.2 Student composition reflects diversity

In the majority of international programmes, the student body includes students from a number of different regions, as well as Sweden. Even though the student body in some programmes is relatively homogeneous, the overall picture is that students of different nationalities and experiences can meet and learn from each other, thus fulfilling the Riksdag’s intention to create international educational environments.

7.2.3 Equal treatment of qualifications requires a quality-based volume of education

The Swedish National Audit Office’s assessment is that, overall, programmes and courses offered in English are sought after by qualified students who pass and complete their studies. However, there may be problems concerning insufficient prior academic skills in certain student groups and in certain programmes of study. For students coming to Sweden, who have often invested significant resources in their education, their failure will have consequences. This is why it is important for students who are admitted to have the conditions necessary to succeed in their studies.

The Swedish National Audit Office considers that the range and volume of international courses and programmes should be linked more clearly than at present to the HEIs’ objectives for international student education. A quality-based range and volume of education should take into account both the needs of the labour market and the demand among qualified applicants with good potential to complete their studies.

Competition varies between HEIs, courses and programmes. At new HEIs, in particular, it is common for all eligible applicants to be admitted. Since Swedish universities accept qualifications from all recognised HEIs in the world, regardless of the quality of their education, students with very diverse educational backgrounds may be admitted. Based on the current application of the Higher Education Ordinance, universities can only mitigate this circumstance by offering fewer educational places to create competition and a selection situation. The Swedish National Audit Office considers that universities and other HEIs should strive to increase competition for places to a greater extent than today and that this requires a comprehensive approach. Universities should also take advantage of their autonomous status and deviate from the NBA’s recommendations on recognised HEIs if they regularly admit students who have an inadequate educational background.

7.2.4 Shortcomings in follow-up of results impedes quality-enhancing efforts

Comprehensive follow-up at national level is important to gain an understanding of third-country students’ academic achievements and whether the internationalisation objectives are being met. In addition to the Swedish National Audit Office’s audit, UKÄ recently published a self-initiated study, which is the only study that follows up, in some depth, third-country students’ academic achievements at national level. Furthermore, universities and other HEIs do not report any information to the Government about third-country students’ academic performance. The Swedish National Audit Office assesses that the Government has not prioritised this matter, even though it is important for evaluating whether the student group contributes to quality in higher education.

It is also important for each university and other HEIs to follow up academic achievements, for example by analysing performance based on degree programme and country of previous education. The results of such a follow-up could be used to adjust entry requirements and improve recruitment strategies with a view to ensuring that third-country students will contribute to the quality of Swedish higher education. However, universities lack technical support for their own follow-up of academic achievements based on students’ country of previous education, and no government agency has a mandate to assist universities in this task.

Despite shortcomings in the follow-up, universities and other HEIs have taken action when shortcomings in students’ prior knowledge of English have been identified. It is important that this type of quality-based follow-up is carried out continuously, and that measures are taken when necessary.

7.3 No clear indications of widespread misuse, although a few shortcomings in the processing procedure

In its audit, the Swedish National Audit Office finds no evidence of extensive abuse of residence permits for studies. However, compared to Swedish students, the proportion of third-country students who work in unskilled occupations is relatively large. Furthermore, the Swedish National Audit Office considers that the Swedish Migration Agency’s procedure, which aims to investigate the intention to study, functions properly overall in processing students’ applications in a legally secure manner. On the other hand, there are shortcomings in the Agency’s control of accompanying family members of students and in the cooperation between case officers at the Swedish Migration Agency and local staff at Swedish embassies.

7.3.1 No clear indications of widespread misuse of residence permits

The audit indicates that abuse of residence permits for studies is not widespread. The results show minor differences between the number of students who were granted a residence permit for studies and the total number of first-time registered third-country students in the same year. The Swedish National Audit Office estimates that each year, up to 250−350 third-country nationals enter the country with a residence permit for studies and register as residents, but do not register for studies.

Although our audit does not indicate that misuse is widespread, the prevalence of misuse is problematic. For example, some universities have experienced that students who lack an intention to study have systematically applied to certain programmes. The Swedish Migration Agency has also pointed out that problems of lack of intention to study are common in some regions and countries where there are unscrupulous recruitment agents. It is therefore important to continue the cooperation between the Swedish Migration Agency and the SUHF to curb abuse and make it easier for serious students to enter Sweden.

7.3.2 Some students work in unskilled occupations

Among third-country students who stay and work in Sweden, a relatively large proportion, compared to Swedish students, work in unskilled occupations. This group consists largely of students who dropped out early from their studies and never graduated. They may have had different reasons for dropping out, for example their studies were too difficult or they worked alongside their studies, which in turn made it difficult for them to complete their studies. However, this does not necessarily indicate a lack of study intent. Even if everyone in this group did not intend to study, the misuse is not as extensive as described in previous reports. In recent years, about 100 people per year have worked in unskilled occupations. Although this is not a large number of people, it can be a matter of serious concern due to the risk of exploitation.

The fact that third-country students are allowed to work an unlimited number of hours alongside their studies means that the legal framework for work permits can be circumvented, and third-country nationals can use student permits in order to work. It can also lead students to spend less time on their studies. The Government Offices have appointed an inquiry to address this issue.

In addition, to obtain a work permit in Sweden the monthly salary must now amount to at least 80% of the median salary. The number of third-country students who switch to a work permit and enter unskilled occupations will likely decrease as a result. At the same time, there is a risk that more people who want to work in Sweden will apply for a residence permit for studies.

7.3.3 Risks related to the Swedish Migration Agency’s new procedure

The Swedish National Audit Office considers that the Swedish Migration Agency’s processing, on the whole, functions properly. The procedure for processing student cases is clear and comprehensive. The Swedish National Audit Office sees a need among case officers at the Swedish Migration Agency for more local knowledge on how education systems function in different countries, the prevalence of recruitment agents, manipulated documents and relationship patterns. This is particularly important since the Agency does not use a risk-based approach and thus does not adapt its procedure based on the extent of misuse in different student groups.

In parallel with the Swedish National Audit Office’s audit, the Swedish Migration Agency has carried out a review of its processing procedure for residence permits for studies. This review has clarified that only specific criteria should be applied to initiate an investigation of intention to study. Previously, case officers had more scope to take into account other circumstances in order to initiate an investigation. It is therefore likely that the number of investigations will drop as a result of the amendments to their procedure.

The Swedish National Audit Office notes that it is difficult for the Swedish Migration Agency’s case officers to assess an applicant’s intention to study when they have not met the applicant in person. The new procedure, which leads to fewer investigations, and thus fewer interviews with applicants, requires that the documentation submitted in connection with the application be sufficient to be able to assess the applicant’s study intention. In other words, there are certain risks associated with the new procedure and it is important that the Agency follow up on the changes.

7.3.4 Shortcomings in the Swedish Migration Agency’s processing of accompanying family members

Neither the Swedish National Audit Office nor any other party has examined the misuse of residence permits for accompanying family members and the extent is therefore unknown. However, we have identified shortcomings in the process. The Swedish Migration Agency’s processing procedure of students’ applications for residence permits is clearer and more thorough than that of co-applicant accompanying family members. The Agency’s procedures also differ if the co-applicant is a student’s accompanying family member compared to if they are an accompanying family member of a person living in Sweden, an ‘affiliation case’. In such cases, a more thorough examination of the relationship is carried out.

Our audit shows that case officers have a poor basis for making an initial assessment of a relationship in cases involving accompanying family members of students. This makes it difficult for case officers to assess the need to investigate a relationship or possible security risks.

However, the Swedish National Audit Office assesses that parts of the procedure for processing affiliation cases could be applied to the processing of accompanying family members of students. For instance, they could include more questions to the student about their relationship with the accompanying family member. This is particularly important, as there are incentives to misuse the possibility of bringing accompanying family members along via a residence permit for studies. Accompanying family members are allowed to study without paying tuition fees, and can work without fulfilling the requirements of a residence permit for work.

7.3.5 Cooperation between local staff at Swedish embassies and case officers at the Swedish Migration Agency is insufficient

Our audit shows that there are no organised forms of dialogue between the Swedish Migration Agency and Swedish embassies in individual cases. This is despite the fact that the Swedish Migration Agency relies on the embassies to check documents and investigate students’ intention to study or their relationship to accompanying family members. Well-functioning cooperation is necessary to ensure that the right information is conveyed in each case and that the quality of the decision-making documentation is high. Furthermore, the knowledge of local staff at the embassies can be better utilised through more communication and cooperation with the Swedish Migration Agency’s case officers.

7.4 Difficult to assess whether full cost coverage has been achieved

HEIs often set tuition fees at a flat rate based on allocation for Swedish students. They also often apply flat rates when reporting the cost of education in their tuition fee-funded activity. Surpluses and deficits that arise in the accounts can therefore be seen as an approximation of the financial results of the organisation. However, there is a risk that the flat rates are not up-to-date or accurate. This makes it difficult for the Swedish National Audit Office to assess whether full cost coverage has been achieved. The Swedish National Audit Office notes that the HEIs have a responsibility to ensure a fair account of the results of the tuition fee-funded activities.

7.4.1 Conditions for reimbursement of tuition fees vary

The conditions for tuition fee reimbursement should be clear to the students. These principles should not differ significantly between HEIs, and a clear and coherent regulatory framework is desirable. However, some flexibility may be needed to allow HEIs to take individual circumstances into account. However, some flexibility may be needed to allow higher education institutions to take individual circumstances into account.

The audit shows that HEIs have invested resources independently to interpret a common regulatory framework and have arrived at different outcomes. UKÄ’s 2017 survey on tuition fees found that neither the Ordinance on application fees and tuition fees at higher education institutions nor the legislative history provided the HEIs with any support in applying the regulations. UKÄ pointed out that there was an obvious need to clarify the rules on reimbursement. The Swedish National Audit Office also considers that there is a need for a clearer regulatory framework.

7.5 Recommendations

The Swedish National Audit Office makes the following recommendations.

To the Government

• Review the Ordinance on application fees and tuition fees at higher education institutions to clarify the rules on reimbursements of tuition fees.

To the Swedish Council for Higher Education

• Investigate the possibility of providing third-country students’ country of previous education to higher education institutions which they can use in their follow-up of students’ academic achievements.

For example, the Ladok Consortium could be involved in linking academic achievement to the country of previous education.

To higher education institutions

• Ensure that the subject composition and volume of international courses and programmes are in line with the objectives of international student education. A review should also consider possible problems concerning students’ intent to study specific courses and programmes.
• Follow up third-country students’ academic achievements regularly.

To the Swedish Migration Agency

• Ensure that the Agency has sufficient documentation to assess the relationship between a student and their accompanying family member.
• Promote organised forms of dialogue between case officers and decision makers at the Swedish Migration Agency and local staff at embassies abroad.

Reference list