Since the 1980s the marketisation of higher education has been profound in the United Kingdom. To assemble coherence that higher education can function as a market, students have been conceptualised as consumers in national higher education policy. As consumers they are rational, employment driven, economic agents who through choice, drive competition, sector behaviour and economic outcomes. Although the student consumer may be normalised in national policy rhetoric, corresponding to its rise is research that challenges the construct and offers a range of non-market-based alternatives for what a student should be. Actors beyond the State such as the National Union of Students (NUS) and Universities United Kingdom (UUK) have roles to play in influencing higher education policy and they offer alternative conceptualisations of students. Within the turbulence of the global pandemic there is a unique opportunity to examine these actors and how the crisis opened up opportunities for them to challenge the student consumer construct. This research engages the strategic-relational approach to understand how the strategic interplays of structure and agency challenged and created coherence around the student consumer. It employs critical policy analysis and discourse analysis to problematise policies and identify conceptualisation of students in the public facing consultations and statements made by these key actors. To conduct this research 105 documents including consultations, regulatory notices, press releases, letters, speeches and briefing notes produced by the actors between 11 March to 3 July 2020 have been identified and analysed. What is revealed is that in the earliest stages of the pandemic new opportunities to challenge and alter the student consumer construct did appear. However, the dynamic power struggles of the actors and the existing structure worked together to enable the reconstruction and re-institutionalisation of an even stronger student consumer. The seemingly paradoxical discourses of vulnerability and empowerment were the tools to create this coherence.