More than a fifth of England's universities have applied to change their fee packages, just weeks before the application deadline.
The Office for Fair Access said 27 of England's universities had sought to lower fees to make use of new measures that could allow them to expand.
Universities blame the late announcement of these measures by the government.
Ministers say changes should not disadvantage any student.
But the National Unions of Students said tens of thousands of students now faced weeks of uncertainty because of the changes.
Maximum tuition fees will rise to as much as £9,000 a year next autumn.
Universities were required to submit their plans for higher charges, bursaries and fee-waivers for certain groups of students back in April. These were then assessed by the fair access regulator, Offa.
This was before the government published its proposals in the Higher Education White Paper, which was delayed by several months.
The plans included allowing universities charging less than £7,500 a year in fees to expand by bidding for 20,000 degree places.
This was widely seen as a last-minute measure to bring the overall cost of higher fees down for the government after it became clear that more universities than expected were planning to charge maximum fees.
Offa said it had received applications from 27 institutions wishing to reduce their average fees to £7,500 or below in order to bid for the 20,000 places set aside for this purpose.
It also said it had received new access agreements from seven publicly funded further education institutions wishing to bid for some of these places.
The watchdog says it will assess the revised agreements and inform universities and colleges of its decisions by November 30.
In the meantime, institutions must contact applicants affected by the changes and let them know. Would-be students will then have the chance to reconsider their options.
Offa also said it would consider any further changes from universities still wishing to change their access agreements.
Nicola Dandridge, head of umbrella group Universities UK, said: "This has come about because universities were asked to set their 2012-13 fee levels and financial support by April this year, before the details of student number controls had been decided.
"The delayed publication in June of the government's White Paper then shifted the goal posts [of student number controls]."
The Office for Fair Access said 27 of England's universities had sought to lower fees to make use of new measures that could allow them to expand.
Universities blame the late announcement of these measures by the government.
Ministers say changes should not disadvantage any student.
But the National Unions of Students said tens of thousands of students now faced weeks of uncertainty because of the changes.
Maximum tuition fees will rise to as much as £9,000 a year next autumn.
Universities were required to submit their plans for higher charges, bursaries and fee-waivers for certain groups of students back in April. These were then assessed by the fair access regulator, Offa.
This was before the government published its proposals in the Higher Education White Paper, which was delayed by several months.
The plans included allowing universities charging less than £7,500 a year in fees to expand by bidding for 20,000 degree places.
This was widely seen as a last-minute measure to bring the overall cost of higher fees down for the government after it became clear that more universities than expected were planning to charge maximum fees.
Offa said it had received applications from 27 institutions wishing to reduce their average fees to £7,500 or below in order to bid for the 20,000 places set aside for this purpose.
It also said it had received new access agreements from seven publicly funded further education institutions wishing to bid for some of these places.
The watchdog says it will assess the revised agreements and inform universities and colleges of its decisions by November 30.
In the meantime, institutions must contact applicants affected by the changes and let them know. Would-be students will then have the chance to reconsider their options.
Offa also said it would consider any further changes from universities still wishing to change their access agreements.
Nicola Dandridge, head of umbrella group Universities UK, said: "This has come about because universities were asked to set their 2012-13 fee levels and financial support by April this year, before the details of student number controls had been decided.
"The delayed publication in June of the government's White Paper then shifted the goal posts [of student number controls]."
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