Almost three quarters of universities in England which have declared their tuition fee plans want to charge £9,000 a year for some or all courses.
The plans of 70 institutions suggest maximum fees will not be "exceptional" as the government had claimed.
The deadline has now been reached for universities to submit their fee plans to the Office for Fair Access.
The government argues that fee waivers and cheaper degree courses in further education will lower the average cost.
So far about 70 higher education institutions have revealed their plans - with about three quarters wanting to charge £9,000 fees for at least of their courses.
All of the leading Russell Group and 1994 Group research-intensive universities have so far proposed maximum fees.
But many of the new universities in the Million+ group and specialists in Guild HE want to charge £9,000 fees or close to the maximum. Only a small proportion propose fees below £8,000.
Aaron Porter, the outgoing president of the National Union of Students, accused the government of causing "costly chaos" with its university reforms.
"When the government forced these ill-considered plans through Parliament, they claimed that fees above £6,000 would be the exception rather than rule, but that was quite clearly a pipe dream," said Mr Porter.
Universities have now reached the point at which they have to submit their plans for tuition fees and for protecting access for poorer students when the upper limit on fees is increased in 2012.
But the full picture of tuition fees will not be known publicly until July, when the Office for Fair Access confirms the fees that it has approved for each university.
A higher level of tuition fee from its current capped level of £3,290 per year will mean a higher level of public funding for the up-front student loans.
And since the government had based its funding plans on an average fee of £7,500, there have been warnings of a "black hole" in the university budget.
But ministers have been confident that the average loan will be much lower than the headline figure for fees - and they reject any suggestion of a financial crisis.
Many universities are offering discounts for poorer students, in the form of fee waivers, and there are likely to be degree courses available from further education colleges which will be much cheaper.
Students at private universities will also be able to obtain loans, up to £6,000 per year, further pushing down the likely average student loan.
However, universities are still concerned about the possibility of further cuts and a reduction in the number of university places for students.
A White Paper setting out how higher education will be reformed in England is expected in the summer.