Part Two of The Platform and the Regulator
The gap that capital fills
India’s National Education Policy 2020 contains a quiet paradox. It aspires to a Gross Enrolment Ratio of 50% by 2035, champions internationalisation as a route to quality, and opens the door – for the first time – to foreign universities establishing campuses on Indian soil. But the Policy offers no theory of how this internationalisation is to be operationalised, financed, or governed at the level of daily institutional practice. It names the destination without mapping the road.
That gap – between regulatory ambition and operational capacity – is precisely where private capital moves fastest. Eruditus has positioned itself as the infrastructure layer of India’s transnational education moment: not a university, not a regulator, but the entity that makes it possible for Aberdeen, York, Victoria, Bristol, Liverpool, UNSW, and Illinois Tech to plant flags in Mumbai, Bengaluru, and Gurugram without building an India strategy entirely from scratch. It absorbs campus logistics, student recruitment, FEMA-compliant JV structuring, SEZ navigation, and marketing – the operational burden that most mid-tier global universities cannot or will not bear alone.
The question this essay poses is not whether Eruditus intended to commercialise India’s higher education system. Intent is the wrong frame. The stronger – and more defensible – argument is this: the structural incentives of Eruditus’s business model systematically produce commercialisation effects regardless of intent. A private intermediary that captures platform rents, shields itself from regulatory liability, and becomes indispensable to both foreign universities and Indian regulators is not a Trojan horse by design. It is something more structurally significant: a commercialisation engine that operates through the logic of efficiency.
The efficiency case, stated fairly
Any honest reckoning with Eruditus must begin by taking the efficiency argument seriously, because it is not trivially wrong.
India’s domestic public university system, however admirable in scale, cannot alone deliver the GER-50 target by 2035. The IITs and IIMs remain globally competitive but narrowly elite. The broader public university ecosystem is under-resourced, over-enrolled, and unevenly distributed geographically. Against this backdrop, the entry of internationally ranked foreign HEIs – even mid-tier ones – genuinely expands the diversity and reach of higher education supply.
But most of these universities would not enter India without an operational partner. Building a campus from scratch in a new regulatory environment – navigating UGC’s Foreign Higher Educational Institution regulations, FEMA compliance, local recruitment pipelines, and India’s accreditation landscape – is a formidable undertaking for a university whose core competence is academic, not logistical. Eruditus lowers these barriers. It brings IIT/IIM credibility, India market intelligence, and a decade of executive-education relationships. On this reading, it is a legitimate market-maker: it creates TNE supply that would not otherwise exist.
The risk/revenue structure of these partnerships reflects this division of labour. Foreign HEIs bear academic risk – curricula, quality assurance, UGC compliance, degree reputation – and the majority of tuition revenue. Eruditus bears operational and marketing risk, capturing an estimated revenue share of 20–40%, based on precedents in its executive-education model, alongside operational fees. This is not an unusual arrangement in the broader landscape of pathway partnerships and third-party campus operators. Navitas, Shorelight, and Oxford International run structurally similar models in other markets.
The efficiency case deserves its due: Eruditus may be expanding the frontier of accessible international education in India in ways that benefit students who would otherwise spend considerably more on outbound mobility.
The regulatory architecture and its gaps
The efficiency case, however, is told entirely within a regulatory vacuum. The moment you examine what UGC’s FHEI regulations actually require – and what the Eruditus model actually delivers – the interstitial space in which the company operates becomes visible, and it is that space which constitutes the structural problem.
UGC’s 2023 FHEI regulations were designed around a single-entity accountability model. The foreign HEI applies for a Letter of Intent, receives approval, sets up campus operations, awards degrees under its own seal, and bears full compliance responsibility. Academic control must remain with the foreign parent; curricula and assessments must mirror the home campus; online delivery is capped at 10%. The regulatory logic is clear: UGC holds one accountable party – the foreign HEI – for everything that happens on the campus.
The Eruditus model introduces a second structural actor that the regulations do not cleanly govern. Eruditus is not the degree-awarding institution – it is neither an IBC operator subject to FHEI rules nor a passive technology vendor subject to standard IT regulations. It occupies an unregulated interstitial category: a private operational backbone that controls campus setup, student recruitment, marketing pipelines, and industry linkages, while the foreign HEI retains nominal academic and regulatory accountability. The JV or service-contract structure through which this relationship is formalised is FEMA-compliant, but FEMA governs foreign investment flows, not educational quality or governance accountability.
The analytical crux is this: UGC holds the foreign HEI liable for what happens in the classroom. It has no direct regulatory relationship with Eruditus. But Eruditus controls the conditions under which the classroom is filled – who is recruited, how they are marketed to, what the campus’s financial viability looks like, and how the partnership’s commercial logic shapes institutional decisions. The regulator sees the front of house. The intermediary controls the back.
This is not simply regulatory creativity. It potentially hollows out the regulatory intent of the FHEI framework. A model designed to ensure that foreign universities bring genuine quality, accountability, and long-term commitment to India can be operationalised in ways that transfer the operational substance of the enterprise to a private actor whose primary fiduciary obligation is to its own investors, not to India’s higher education goals.
Platform rents, equity, and the dependency problem
Three deeper critiques emerge from this structural observation.
The platform rent argument. Eruditus’s structural position – low academic risk, shielded regulatory exposure, but significant revenue share across seven or more university partnerships – means it captures rents from India’s higher education system while externalising the reputational and compliance liabilities onto its partners. This maps directly onto the platform economics critique. The platform captures value; the partners bear exposure. The public good – higher education – is reframed as a logistics problem, and the logistics company takes the commercial premium.
The equity paradox. UG degrees at Eruditus-facilitated IBCs are priced at ₹20–30 lakhs – positioned, plausibly, as 50–70% cheaper than equivalent study abroad. But this efficiency claim only holds if outbound mobility is the relevant counterfactual. Against India’s domestic higher education baseline – where quality public university education remains available at a fraction of this cost – these IBCs are stratospherically priced. The GER-50 target implies mass enrolment, not premium niches. Eruditus’s model serves an upper-middle-class segment with the resources and aspiration to consider foreign degrees: a real and legitimate market, but not the population for whom India’s internationalisation rhetoric is ostensibly designed.
The indispensable intermediary problem. Perhaps the most structurally significant risk is the least visible. As Eruditus deepens relationships across seven or more partnerships simultaneously, it accrues what might be called relational rents – influence over India market access that individual foreign HEIs cannot replicate independently. Over time, its negotiating leverage over foreign universities grows: those universities increasingly depend on Eruditus not just to enter India, but to remain viable there. Public oversight mechanisms, focused on the HEI partner, cannot see or tax these relational rents. UGC audits the curriculum of Aberdeen’s India campus. It has no visibility into the renegotiation of Eruditus’s revenue share. This is not a Trojan horse mechanism – it requires no deception. It is the structural logic of platform intermediation applied to higher education governance.
Governance for the interstitial
The argument here is not that Eruditus should not exist, or that its partnerships are illegitimate. The efficiency case for TNE intermediaries is real, and regulatory hostility to private operators in higher education has historically produced worse outcomes than regulatory naivety about them. The argument is narrower and more precise: the current regulatory architecture creates a structural asymmetry in which Eruditus captures commercial value while UGC’s accountability mechanisms remain focused on its university partners. This asymmetry was not designed – it emerged from regulations written for a single-entity model that the market has already superseded.
What would governance for this interstitial look like? Several mechanisms suggest themselves.
UGC could require disclosure of all operational partnership agreements as part of FHEI applications, making the Eruditus-type relationship visible to the regulator rather than invisible within it. Revenue-sharing arrangements could be subject to an equity cap, analogous to norms in public-private partnership models in infrastructure. A register of approved TNE intermediaries – distinct from HEIs, but regulated in their own right – would allow UGC to impose basic accountability standards on the operational layer without requiring it to govern academic content.
None of these are radical interventions. They are the kinds of governance closures that mature regulatory systems develop when market innovation outruns regulatory design.
India’s NEP imagines an internationalisation that enriches without colonising, that expands access without entrenching privilege. Whether Eruditus’s model serves or subverts that imagination depends less on its founders’ intentions than on whether India’s regulatory institutions develop the vocabulary to govern what has already arrived.
