Section 8 – Code of Practice guidance

Overview

A Code of Practice (CoP) is a requirement for REF 2029. It sets a minimum standard for participation. Higher Education Institutions (HEIs) wishing to make a submission to the exercise must have a CoP approved by the funding bodies. The four UK funding bodies have provided their definitions of an HEI for the purposes of the REF in section 1 of the Overview of the assessment framework.

The REF 2029 CoP are a set of guidelines and procedures that HEIs must develop and implement. The CoP outline how HEIs will make key decisions about their submission to the exercise. These decisions concern identifying contracts that contribute to the REF volume measure, and selecting research outputs for submission to the REF. More information about the REF volume measure can be found in the Volume Measure guidance.

The CoP go beyond procedural and legislative compliance and aim to embed a framework of principles in the key decisions made by HEIs that shape their REF 2029 submissions. The REF 2029 CoP supports the following principles:

• Robustness: submissions should be an accurate reflection of the sector. This supports confidence in the outcomes of the REF and related funding.
• Transparency: people should understand how decisions about submissions are made and that fair process is followed. Transparent processes help reassure the sector that the same rules are being followed everywhere.
• Equity and inclusion: decisions about submissions should be fair and impartial, supporting a diversity of people and research. The CoP promotes inclusive research environments where diverse individuals and research contributions are valued and supported and recognises the wide range of research, roles and people that are essential to promoting an inclusive research environment and ensuring the vitality of the UK’s vibrant research system.

The guidance for CoP will be published in two modules:

• January 2025 – Volume Measure guidance: provides guidance for developing material in the Code of Practice relating to the identification of contracts with significant responsibility for research (SRR) and determining research independence (RI).
• Spring/Summer 2025 – Output selection module: provides guidance for developing material in the Code of Practice relating to the selection of outputs.

While the policy modules will be published separately, HEIs must submit their CoP once as a complete document, for approval by the UK funding bodies. There are four points at which your CoP may be submitted for approval. This is intended to cater for different timing needs in the sector. We aim for approvals to take a maximum of 3 months from receipt, dependent upon speed of response to feedback from the funding bodies. The four points at which a CoP may be submitted for approval are listed below. Click here for full details of the submission windows and deadline dates/times.

• 1 August 2025: aiming for approved CoPs by November 2025
• 3 October 2025: aiming for approved CoPs by January 2026
• 5 December 2025: aiming for approved CoPs by March 2026
• 6 February 2026: aiming for approved CoPs by May 2026

More information will be provided about how CoP should be submitted to the funding bodies. We will confirm a named contact with submitting HEIs.

As an approved CoP is a condition of participation in REF 2029, institutions that are created later in the process (particularly if after 6 February 2026) should contact the REF team as soon as possible to discuss how to proceed. 

Policy context

REF 2029 Initial Decisions set out the key developments for the exercise. These include:

• the move to calculate the volume measure for REF 2029 using data held in the HESA Staff record and the longer term aim to move to continuous data collection
• breaking the link between individual staff members and submitted outputs
• the introduction of the REF 2029 People, Culture and Environment (PCE) assessment element
• the retention of REF 2021 criteria for volume-contributing staff contracts and definitions of research independence and significant responsibility for research

Breaking the link between individuals and the REF submission and focussing on assessment in each disciplinary area means that REF 2029 has changed from previous exercises. The volume measure for REF 2029 will be based upon data held in the Higher Education Statistics Agency (HESA) Staff record, rather than the submission of staff lists with attributed outputs.

The longer-term aim is that for future research assessment, volume will be calculated continuously across an assessment cycle. This near-automatic calculation will be hardwired into existing processes and will reduce burden for the sector. HEIs will maintain an ongoing, accurate reflection of contracts with significant responsibility for research. Reliable and consistent data about the research and innovation sector has value beyond research assessment, contributing to evidence-based policy development and decision-making.

The move to continuous volume calculation, will change the nature of REF CoP, which will become living documents. More information about future maintenance and approval of CoP will be published in due course.

REF 2029 CoP requirements reflect the transition to a framework that separates individuals and outputs through:

• A greater reliance on existing HEI governance and processes to make key decisions for REF 2029, thereby minimising additional requirements and administrative burden.
• Equality impact assessments that consider the definitions of significant responsibility for research (SRR) and research independence (RI) and the selection of outputs.
• Removal of processes around individual staff circumstances. Breaking the link between individuals and outputs negates the need for processes around staff circumstances and saves substantial administrative burden for institutions.

Please read the REF 2029 guidance on eligibility and the legislative context in the Overview of the assessment framework. Codes of Practice (CoPs) form a key part of the funding bodies’ mechanisms for discharging the Public Sector Equality Duty (PSED) in this area, by supporting Higher Education Institutions (HEIs) in ensuring their REF 2029 participation and processes are compliant with equality legislation, promoting fair, transparent, and inclusive processes for all staff regardless of protected characteristics or language preferences.

Codes of practice and the People, Culture and Environment assessment element

The CoP and the People, Culture and Environment (PCE) element of REF 2029 are distinct but complementary aspects of the exercise. While they share a common goal of promoting positive and inclusive cultures, they have a different focus and serve different purposes within the REF.

CoP set a minimum standard for participation in the exercise, while excellence in PCE is expected to extend beyond the minimum standard. While some aspects of the CoP may relate to and complement PCE submissions, PCE covers a wider range of indicators and subject matter.

The full guidance on PCE will be published in 2025.

CoP guidance publication and approval schedule

This CoP guidance will be published in modules, making it available as soon as possible. The publication and approval schedule is:

• CoP Volume Measure guidance – published January 2025
• CoP Output Selection guidance – to be published Spring/Summer 2025
• CoP submission points:
  • 28 July 2025 to midday 1 Aug 2025
  • 29 Sep 2025 to midday 3 Oct 2025
  • 1 Dec 2025 to midday 5 Dec 2025
  • 2 Feb 2026 to midday 6 Feb 2026
• Final approvals: 29 May 2026

More information will be provided about how the CoP should be submitted to the funding bodies. We will confirm a named contact with submitting HEIs.

CoP should be submitted in a clear and concise format and must use the CoP template at the bottom of this page.

An up-to-date CoP must be made publicly available for unrestricted access. All final CoP will be published on the REF website.

Approval

The primary responsibility for approval lies with the funding bodies, with input from the REF 2029 People and Diversity Advisory Panel (PDAP) and Research Diversity Advisory Panel (RDAP).

Submitted CoP may be returned with required amendments or clarifications. A clear process for submitting revised CoP will be provided, with opportunities for further dialogue and clarification if needed.

We anticipate that the overall approval process will take a maximum of 3 months. However, in most cases this is likely to be quicker.

Further information on the approval process will be published closer to the approval window.

Approach

The funding bodies understand that HEIs may need to begin implementing aspects of their CoP, particularly those related to staff identification and data collection, for the 2025 to 2026 academic year before receiving formal approval. To address potential misalignment between early implementation and final CoP approval, the following measures will be taken.

Extended submission window

Long submission and approval windows with multiple submission deadlines, are designed to accommodate the diverse needs of HEIs in preparing their CoP.

Flexibility in HESA data

Continued collaboration with HESA to explore the potential for a process which enables HEIs to amend REF-related fields in the HESA staff record after the 2025-26 data collection period, if necessary.

Proportionate approvals

CoP approval outcomes will be proportionate, considering burden on HEIs, potential impact on individuals, and the scale of impact on submissions.

Informal support

The funding bodies will provide further guidance on expectations before formal submission.

Audit and assurance

This section (Section 7, Audit and assurance) will be updated as the REF exercise continues.

The full audit guidance for REF 2029 is under development and may be subject to change. It will provide full details of measures employed to assure adherence to CoP.

Proportionate audits

Such as targeted audits, focussed on areas of concern or risk, random sampling, data analytics.

Complaints and investigations process

The funding bodies will provide a complaints and investigations process for when individuals believe CoP have not been followed. The complaints and investigations process will have scope to take corrective actions on submissions.

Queries

Please send any queries to info@ref.ac.uk with the title ‘Query on Codes of Practice’.

Guidance for volume measure elements of CoP

This CoP volume measure guidance supports HEIs to develop a REF 2029 CoP outlining how decisions will be made for determining which contracts contribute to the REF volume measure.

This guidance should be read in conjunction with the Volume Measure guidance.

There are two tests that will identify whether a contract is eligible for inclusion in the volume measure:

• significant responsibility for research for ‘teaching and research’ contracts
• research independence for ‘research only’ contracts

Contracts which meet one of these two tests should be included in the volume measure.

Implications of calculating the volume measure across multiple years

The move to calculate the volume measure across academic year 2025-26 and academic year 2026-27 removes the unwanted incentives created by a single census date. Averaging volume across multiple years, takes a view over time that is less susceptible to variation and will reduce burden in the longer term. This move requires that decisions made about determining which contracts contribute to the REF volume measure must be accurate in each year’s HESA return.

HEIs will determine the most appropriate way to achieve this requirement, typically tying review into work planning and annual appraisals.

Institutions should plan for this requirement to remain in place on an ongoing basis, for research assessment and funding. More information about future maintenance and approval of CoP will be published later.

CoP structure

REF 2029 has largely retained the CoP structure from REF 2021, updated in line with the key changes to REF 2029.

As set out above, a subsequent policy module will set out guidance in relation to output selection. The key requirements below will not be changed. There will be additional requirements specific to output selection.

REF 2029 CoP must include the sections listed below. A CoP template with embedded guidance can be downloaded here.

CoP introduction

The introduction should discuss the CoP in the context of the following principles:

• Robustness: explain how the policies and processes set out in the CoP ensure that contracts identified as contributing to the volume measure reliably reflect the responsibilities of staff.
• Transparency: explain how policies and processes set out in the CoP will be communicated and available to all staff and made available in accessible formats. CoP should be published on HEIs external website.
• Equity and inclusion: explain how decisions about submissions are fair and impartial supporting a diversity of people and research, where diverse contributions are valued and supported.

The HEI’s challenges for an inclusive research community and other institutional policies concerning equality and diversity and inclusion, responsible research assessment and people culture and environment.

An update on any relevant impact or outcomes of actions taken to improve inclusivity of their research community by the submitting institution since REF 2021, with reference to their 2014 and 2021 Equality Impact Assessment (EIA), where appropriate.

Policies and procedures for identifying Significant Responsibility for Research

These are the policies and procedures for identifying Significant Responsibility for Research (SRR) for ‘teaching and research’ (ACEMPFUN 3) contracts, in accordance with the Volume Measure guidance.

All participating institutions are required to complete this section.

If an institution’s ‘teaching and research’ (ACEMPFUN 3) contracts in their HESA Staff record precisely identify all contracts with significant responsibility for research (SRR), this should be simply stated in the CoP. No further elaboration is needed in this section.

Where an institution has more than one process for identifying contracts with a significant responsibility for research in the REF (for example, where employment practices vary at the submitting unit level due to disciplinary differences), this should be reflected in the CoP.

SRR criteria must be based upon job role expectations, not past performance.

Processes established to identify significant responsibility for research must be consulted on with staff, using appropriate staff representation mechanisms. Codes of practice do not need to describe the processes used.

Policies and procedures for identifying research independence

These are the policies and procedures for identifying research independence (RI) for ‘Research only’ (ACEMPFUN 2) contracts, in accordance with the REF guidance.

All participating institutions are required to complete this section.

The code of practice should describe the fair and transparent processes for determining research independence.

Referenced appendices

Any appendices referenced in the CoP may be included in this section.

Key requirements for REF 2029 Code of Practice

Policies and procedures

The CoP must outline the policies and procedures that the HEI will follow for identifying significant responsibility for research and research independence.

Where policies and procedures are shared across the CoP sections (for example committees, EIAs), the CoP should state that this is the case rather than duplicating text.

Processes established to identify significant responsibility for research must be consulted on with staff, with appropriate staff representation mechanisms, but HEIs are not required to describe the processes used.

The CoP should include a statement about how the institution supports its fixed-term and part-time staff, including contract research staff, in relation to equality and diversity.

Staff, committees and training

Detailing staff and committees

• List the staff and committees involved in all CoP-covered processes, referencing their roles within the HEI and their place in the institutional management structure.
• Specify whether involved staff and committees have advisory or decision-making responsibilities.
• Consider using timelines or diagrams to illustrate committee/group structures, interdependencies, and processes.

Responsibilities of committees

For each committee with designated REF responsibilities (at any level – departmental, faculty, UoA, or central), you must detail in the CoP:

• the roles of committee members
• responsibilities (advisory or decision-making) regarding SRR or research independence determination
• steps taken to ensure members understand their legal obligations regarding equality, including any relevant training

Training on Equality, Diversity and Inclusion

• Staff involved in CoP processes must receive training on equality, diversity and inclusion, ideally tailored to REF processes. HEIs are not required to provide detail on how this training will be implemented.

Equality Impact Assessment (EIA)

Mandatory EIA

• Funding bodies require all HEIs to conduct EIAs on their policies and practices for:
  • identifying staff contracts with significant responsibility for research (where applicable)
  • determining research independence
• EIAs should be informed through engaging, consulting, or involving staff from protected groups.
• EIAs will be required for the selection of outputs. More information about EIAs for the selection of outputs will be published in a subsequent policy module.

Analysis

• The EIA must be a systematic analysis to determine if policies/practices might have a different impact on groups based on protected characteristics. EIAs may also cover non-protected characteristics where particularly appropriate to its context for improving research inclusivity.
• EIAs should analyse data for all protected characteristics where available and compare between volume contributing and non-volume contributing populations.
• When dealing with small numbers that can significantly affect percentages in statistical data, EIAs should acknowledge this and highlight instances with a notable impact on specific groups.
• Consider the overall combined impact of policies/practices related to identifying volume contributing contracts.
• HEIs can use mock exercises and information from previous REFs to inform their EIA, identifying potential barriers and opportunities.
• Institutions in Wales must ensure that the EIA considers how the Welsh language is not treated any less favourably than the English language.

EIAs should inform the CoP, therefore

• EIAs should be reviewed during submission preparation.
• The CoP should clearly state the EIA findings and how the analysis shaped the final policies and procedures.
• Completed EIAs should be included in the CoP appendices. Care should be taken to ensure that the identities of individuals are not inadvertently disclosed.

Identifying discrimination and opportunities

• EIAs help HEIs identify potential inadvertent discrimination in REF processes and pinpoint policies/practices with a positive impact or opportunities to advance equality.
• If potential discrimination is found, HEIs must take action to change the policy/practice or justify retaining it within legal constraints.
• If a policy/practice has a positive impact, HEIs can consider applying it to other REF areas.
• Identified opportunities to advance equality should be seriously considered for implementation.

Submission and publication

• HEIs must submit a final EIA after the submission deadline, including final data analysis, actions taken, and outcomes. More information will be provided about this requirement.
• HEIs are expected to publish these final EIAs, including outcomes of actions taken. Full information should be published where significant impact is identified. Publication is a legal requirement in some regions if a policy/practice has a significant impact. Please see Section 1 – Overview of the assessment framework for further guidance.
• EIAs will be used by funding bodies and PDAP to evaluate the overall effectiveness of REF’s equality and diversity aspects and identify lessons for the future. PDAP will not formally review individual EIAs.

Feedback and appeals

Institutions should provide sufficient opportunity for staff to appeal decisions about significant responsibility for research and research independence. Appeal mechanisms should be independent of the original decisions and be made clearly available to staff in a timely fashion.

The funding bodies generally expect this to be through existing mechanisms tied into workload allocation and appraisals, where those mechanisms meet these requirements.  

Joint submissions

Sharing CoPs: institutions making joint submissions may share parts of their CoP across collaborating institutions.

Maintaining adherence: joint decision-making across institutions must not compromise adherence to each institution’s CoP.

Shared approach (optional): collaborating institutions can agree on a shared approach, with one CoP approved and used on behalf of the other for managing the joint submitting unit. Where there are differences at a UoA level, HEIs are required to reflect this in the CoP. Joint submissions may be an example of this.

Complaints

Formal complaint mechanism: the funding bodies will establish a process for individuals to make formal complaints if they believe an institution is not following its approved CoP. Complaints cannot challenge the adequacy of the approved CoP itself. Remedial action will be taken for upheld complaints.

CoP review

More information about future maintenance and approval of CoP will be published later in the REF cycle.

CoP template

The downloadable CoP template, below, summarises the layout and content required for the CoP.