This article examines the factors influencing the development of widening participation policy in 16 higher education institutions (HEIs). It utilises documentary research, followed by interviews with key policy makers in three of the institutions: an ‘old’ university, a ‘new’ university and a college of higher education. The paper demonstrates that HEIs have some agency, but this is bounded by the need to take account of the external environment within which they operate. The article argues against overly simplistic assumptions about the rationale underpinning HEI policy on widening participation. Instead it contends that policy develops out of a complex combination of economic and political influences, mediated by the organisational culture of HEIs. As such, both agency and structure influence the policy‐making process. The paper discusses the complexities involved in the development of HEI policy on widening participation. It also highlights some of the problems involved in disentangling institutional rhetoric or ‘spin’ from the values that actually underpin institutional policy. The paper concludes by arguing for more institutional autonomy in the determination of widening participation policy.