New regulatory requirements have strengthened expectations on how universities prevent and respond to harassment and sexual misconduct. Yet the success of the Office for Students' Condition E6 will depend not only on what institutions put in place, but on whether students trust those systems enough to use them. Samuel Lai, Tahlia Jurkovic, Tina Skinner and Lisa Ring at the University of Bath explore why E6's existing requirements should be operationalised and evaluated through a trust-centred lens.
In August 2025, the Office for Students (OFS) introduced Condition of Registration E6 (E6), providing an important regulatory foundation to help higher education institutions (HEIs) protect students from harassment and sexual misconduct. However, effective implementation will depend on more than meeting regulatory requirements. Condition E6 should be implemented and monitored as an outcomes-based regulation, with the OfS and HEIs assessing not only whether systems exist, but whether students understand, trust and can safely use them.
Sexual violence at HEIs
Sexual violence (SV) remains a prevalent issue across English higher education (HE), with serious consequences for students’ health, wellbeing and education. In the 2025 OfS Sexual Misconduct Survey, 24.5% of final-year undergraduates disclosed in their survey responses that they had experienced sexual harassment, and 14.1% disclosed that they had experienced unwanted sexual contact/sexual assault or violence since becoming a student.
How HEIs respond matters. The harm experienced by victim-survivors can extend well beyond the original incident, influencing students’ sense of safety, academic engagement and likelihood of continuing their studies. HEI responses can either support recovery or compound trauma through ‘institutional betrayal’, particularly where students perceive reporting processes and support systems as ineffective, inaccessible or unfair.
The introduction of E6 represents the most assertive regulatory intervention on harassment and sexual misconduct in the sector to date. It requires HEIs to take steps to protect students through measures including clear reporting mechanisms, accessible support services and appropriate staff training.
While E6 establishes an important regulatory framework, its introduction also raises wider questions. The very need for formal compulsion suggests that at least some HEIs have not adequately responded to longstanding evidence of harm. In this regard, the primary challenge is not overcoming the absence of formal policy, but addressing a pervasive “trust gap,” where victim-survivors report with scepticism or avoid institutional systems entirely.
Institutional responsibility
SV in HE should not be treated solely as a private matter between individuals. Its effects can affect academic participation, causing impaired concentration, withdrawal from campus spaces and reduced willingness to seek academic support. It can also reinforce marginalisation and restrict longer-term opportunities. HEIs must therefore shape the environment in which students disclose experiences, access support, navigate institutional procedures, and judge whether continuing their education remains safe and viable.
Institutional responsibility is reflected in wider legal and policy expectations, including equality and anti-harassment duties, and broader government commitments to preventing violence against women and girls. Yet E6 follows several earlier attempts to strengthen the sector’s response, potentially suggesting that the softer and non-binding policy approaches were insufficient, including Universities UK’s 2016 Changing the Culture framework and OfS's 2021 Statement of Expectations.
Although these initiatives recognised that structural policies alone were inadequate without cultural change, institutional autonomy and reputational protection have often taken precedence over meaningful responsiveness to students’ experiences, creating deep tensions between privacy, student safety and everyday implementation. Indeed, an evaluation of the 2021 Statement identified uneven progress across HEIs, including variation in implementation and staff training.
E6 begins to address the gap between policy and effective practice by introducing mandatory requirements and regulatory compulsion. A distinction remains, however, between having procedures in place and ensuring that students are willing and able to use them. Understanding and addressing that gap is essential if regulatory progress is to translate into meaningful improvements in student experiences.
Understanding barriers to help-seeking
Evidence suggests that improving responses to SV requires more than making services available or increasing awareness of them. The Integrated Behavioural Model of Mental Health Help-Seeking suggests that awareness primarily makes help-seeking possible, but does not actively drive it. Students may be aware that support services and reporting routes exist, while still choosing not to use them because they anticipate negative consequences, including not being believed, loss of control over decision-making, reputational concerns, or re-traumatising procedural experiences.
These concerns often sit alongside wider barriers, including immediate safety concerns, the fear of disrupting relationships with peers, misconceptions surrounding sexual violence and the risk of academic disruption during critical periods, such as exam periods.
Together, these factors can discourage help-seeking even when formal support is available.
This has important implications for implementation. Measures focused primarily on visibility, signposting and awareness-raising may increase knowledge of available services, but they may not increase willingness to use them. HEIs may therefore meet formal requirements while still failing to create systems that students view as safe, credible and worthwhile to use.
The importance of trust
Research on procedural justice points to the importance of trust. People are more willing to engage with formal systems when they are perceived as fair, legitimate, respectful and non-arbitrary. In practice, students are more likely to seek support when they believe institutional processes will be handled competently, transparently and in ways that protect their interests.
Conversely, Institutional Betrayal Theory suggests that when HEIs are perceived to prioritise procedural defensibility and organisational interests over student wellbeing, trust may be undermined. In these circumstances, some victim-survivors may still approach HEI systems, engaging with them because they offer forms of support that external services cannot provide, such as access to academic adjustments, campus-based safety measures and internal disciplinary processes. But others may avoid HEI routes altogether, particularly where the procedural and emotional costs outweigh the perceived benefits.
The policy challenge is not merely one of access, but of institutional credibility. A HEI may comply with regulatory expectations regarding reporting systems, support services and information provision while still failing to create systems that students view as trustworthy and worthwhile to use.
Improving trust, fairness and institutional credibility
It is possible for a policy framework to specify what systems HEIs have in place yet remain less precise about what makes those systems feel safe, trustworthy and victim-survivor-centred in practice. Therefore, if implementation is treated mainly as a matter of procedural presence, HEIs may be compliant without being seen as approachable.
From a policy standpoint, the challenge is not only to widen formal provision but also to reduce secondary harm, and provide support and justice for victim-survivors.
To achieve this, HEI systems should preserve choice, minimise unwanted procedural escalation, and be delivered by people with the knowledge and capacity to respond safely. This requires HEIs to ensure both procedural justice, through transparent, objective and respectful processes, and kaleidoscopic justice, which recognises that victim-survivors’ needs are fluid, non-linear and may extend beyond formal disciplinary outcomes. Information, support, training and fairness should be understood as interacting conditions that shape whether students view the institution as a credible source of help.
The key question is what type of implementation model can translate E6’s broad requirements into responses that students trust and are willing to use.
E6: From compliance to confidence
To maximise the potential of E6, implementation should be guided by a trust-centred approach, rather than being solely compliance-centred.
While E6 establishes a regulatory baseline, HEIs retain considerable discretion over how support, reporting and casework are organised. Success should therefore be judged not only by whether procedures exist, but by whether students can understand, access and feel safe using them.
One practical reform is to distinguish more clearly between disclosure, support and formal reporting pathways. Under this approach, students could seek academic adjustments or information without automatically triggering a disciplinary investigation. Preserving choice in this matter is important because concerns about losing control can deter help-seeking. Support should therefore function as an entry point to safety and choice, rather than being the first stage of institutional procedure.
A second priority is to treat trauma-informed practice as the standard through which E6 is implemented. While E6 requires appropriate training and support, it does not define what safe, victim-survivor-centred practice should look like in operational terms. A trauma-informed approach could help fill that gap by ensuring that HEI staff understand the effects of trauma, promote safety, avoid re-traumatisation, and preserve victim-survivors’ choice and control.
In practice, this means clear communication, predictable procedures, transparent options and minimising the need for students to repeat their disclosure. Specialist trauma-informed training should be prioritised for staff who receive formal disclosures, conduct investigations or make casework decisions. Staff in wider student-facing roles, such as tutors, accommodation teams and security staff, should receive a basic level of training to support safe and informed responses. This is a more practical approach than expecting specialist expertise across the whole institution, while helping to reduce the risk that unsafe initial responses discourage students from seeking formal support. Minimising repeated retelling is particularly important as it can intensify secondary victimisation and contribute to longer-term harm. Trauma-informed practice should therefore be viewed not as an optional enhancement, but as the means through which E6’s broad duties are translated into safe and consistent support.
Effective implementation also requires specialist support. While HEIs may adopt different delivery models, support should reflect a number of core principles, including specialist expertise, continuity of care, victim-survivor-led engagement, and a clear separation from disciplinary decision-making. One example is the Sexual Violence Liaison Officer (SVLO) model. SVLOs provide a single point of contact, helping students navigate support and reporting options while reducing the need to repeat experiences across multiple departments. By offering continuity, specialist knowledge and victim-survivor-led support, the model demonstrates how HEIs can make administrative systems more accessible to victim-survivors, enabling them to navigate institutional processes safely while restoring a sense of agency.
Specialist support should also be complemented by stronger accountability mechanisms. HEIs need to assess whether students view reporting and support pathways as accessible, trusted and effective. Annual anonymised impact reporting, service standards, data on support uptake and climate surveys comparing anonymous prevalence with formal reporting patterns can help HEIs understand whether gaps exist. Used carefully, these measures can improve transparency while protecting confidentiality and victim-survivors’ safety.
Challenges for implementation
Delivering these reforms is not without challenges. Separating support from formal disciplinary processes can help preserve student choice, but it also places greater emphasis on providing ongoing welfare support. HEIs may face difficulties maintaining continuity of care as HEI-led support is typically bounded by student enrolment status and external specialist services frequently operate under significant capacity pressures and long waiting lists.
Embedding trauma-informed practice across a HEI presents a further challenge. Levels of awareness and experience vary considerably between departments, meaning that training and good practice are unlikely to become embedded through compliance requirements alone. Achieving consistent standards requires sustained investment, leadership and organisational commitment over time.
Taken together, clearer distinctions between disclosure, support and reporting pathways, trauma-informed practice, specialist support models such as SVLOs, and stronger accountability mechanisms offer a more trust-centred approach to implementing E6. These measures are unlikely to eliminate SV in HE, but they can help create systems that are more accessible and more responsive to victim-survivors’ needs. In particular, flexible and victim-survivor-led pathways can reduce the risk of secondary harm, while specialist support, transparency and greater scrutiny can strengthen confidence that HEI processes are fair, safe and effective.
The additional financial and time investments required to achieve this should therefore be viewed not as an optional enhancement, but as a necessary condition for the long-term effectiveness and credibility of HEI responses to SV. Implementation will require more than new procedures alone. HEIs must address organisational silos, uneven levels of training, resource constraints and gaps in specialist provision that can limit access to support and undermine continuity of care. They must also ensure that accountability focuses not only on procedural compliance, but on whether students are able to access, trust and benefit from the support available.
More fundamentally, the successful implementation of E6 depends on a shift in institutional culture. Condition E6 should be implemented and monitored as an outcomes-based regulation. Responses to SV should be designed around student safety, autonomy and procedural fairness. The challenge, therefore, is to translate E6’s broad duties into transparent, predictable and trusted systems that victim-survivors can confidently engage with. Ultimately, the measure of success should be whether students experience institutional responses as safe, credible and supportive in practice, not merely whether the required policies and procedures are in place.
Support: Anyone affected by sexual violence, harassment, or related harm is encouraged to seek support through their HEI, specialist support services, and/or the police. At the University of Bath, students can access confidential, trauma-informed and person-centred support through the Sexual Violence and Domestic Abuse Response Service.
About the authors: Shun Yin Lai (Samuel) is a University of Bath psychology graduate. Tahlia Jurkovic is a Specialist Practitioner at the University of Bath. Tina Skinner is a Senior Lecturer in the Department of Social and Policy Sciences at the University of Bath. Lisa Ring is the Sexual Violence and Domestic Abuse Service Manager in the University’s Student Support and Safeguarding department at the University of Bath.
All articles posted on this blog give the views of the author(s), and not the position of the IPR, nor of the University of Bath.
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