What AI policies in UK universities actually do: A study of 96 institutions

HEPI Number: Policy Note 71

Author:Professor Sam Illingworth

Posted: May 21, 2026

Many universities still do not have easily accessible AI policies.

According to What UK University AI Policies Actual Do: A Study of 96 Institutions (HEPI Policy Note 71), written by Professor Sam Illingworth, two in five UK universities do not have AI policies that students, parents or regulators can easily find online.

The paper also argues that although most of the 96 publicly accessible policies use learning language, they actually operate as detection and discipline frameworks.

Counting the 77 keywords across the 96 policies, we see that 86% of the policies were education-focused. However, close to half (8) of the policies found were closely read by a subset (19) of the authors’ detailed readings, and training terminology was used to dress up the detection and discipline architecture.

Key findings: 41% of UK degree-granting institutions do not have a publicly accessible AI policy. Some are behind login walls, some return corrupted URLs, while most cannot be found through search engines at all. There is no shared approach in this sector. 163 separate organizations have issued 163 separate responses to the same issue, with framing ranging from “educational, not punitive,” to language that treats non-declaration of AI use as evidence of a cover-up. Students transferring from one educational institution to another may find policies that differ not only in detail but also in fundamental direction. The location of a policy is a more accurate predictor of its function than the language in which it is used. Policies hosted within the Academic Misconduct Framework are enforced. Policies hosted within the Learning and Teaching framework provide training. Vocabulary alone cannot move the needle. There is no policy in our sample that states ‘We trust our students’. The dominant model is conditional trust. Students are trusted only if they declare use, maintain evidence, and submit verification.

Professor Sam Illingworth, author of the new policy note, said:

Colleges must develop critical thinking skills. If an institution’s own AI policy cannot model critical thinking about AI, then if it relies on compliance while claiming education, the policy contradicts its mission. The deficit model does not require punitive language to reproduce itself. All that is required is the assumption that we cannot trust what students think.

Nick Hillman OBE, CEO of the Higher Education Policy Institute, said:

Universities all over the world are considering how to respond to AI. Technological advancements over the past few years have brought major changes to academics, students, and administrators.

This report assesses the state of instruction for students, with almost all students now using AI on a regular basis. Some universities still argue that they need to hone their responses to AI in ways that are pedagogically sound and truly helpful to students.

The report identifies four best practices in the AI ​​policies of the University of Stirling, Canterbury Christ Church University, Plymouth College of Art and the University of Durham (recipients of the Common Award Partnership). This includes all four major agency types (Russell Group, Other Pre-92, Post-92, and Professional). They show that AI policies can expand trust, develop critical literacy, and address risk by focusing on evaluation design rather than detection.

This report presents five principles for student-centered AI policies.

Location determines framing, trust must be the default, student voices must shape policy, and critical literacy must replace tool proficiency. Policies must be publicly accessible.

HEPI’s recent output on AI includes the HEPI/Kortext Student Generative AI Survey 2026 (HEPI Report 199) by Rose Stephenson and Charlotte Armstrong, Being indispensable: Capability for a human-AI world, the ‘FUTURES’ framework by Dr Doug Specht and Professor Gunter Saunders (HEPI Report 198), and the collection of essays organized by Dr Giles Carden and Josh Freeman (eds), AI and the Future. of the University (HEPI Report 193).

NoteProfessor Sam Illingworth is Professor of Creative Pedagogy at Edinburgh Napier University and co-author with Rachel Forsyth of GenAI in Higher Education (2026). He writes the Slow AI newsletter on important AI capabilities at https://theslowai.substack.com/. All 96 scraped policies, keyword vocabularies, qualitative coding framework and framing ratios for each institution can be found at https://github.com/sam-illingworth/uk-university-ai-policies. HEPI was founded in 2002 to influence higher education debate through evidence. We are independent and non-partisan across the UK. We receive funding from organizations and higher education institutions who wish to support us through active policy debate as well as their own events. HEPI is a company limited by guarantee and a registered charity.

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