Increasingly, Artificial Intelligence (AI) is having an impact on distance-based higher education, where it is revealing multiple ethical issues. However, to date, there has been limited research addressing the perspectives of key stakeholders about these developments. The study presented in this paper sought to address this gap by investigating the perspectives of three key groups of stakeholders in distance-based higher education: students, teachers, and institutions. Empirical data collected in two workshops and a survey helped identify what concerns these stakeholders had about the ethics of AI in distance-based higher education. A theoretical framework for the ethics of AI in education was used to analyse that data and helped identify what was missing. In this exploratory study, there was no attempt to prioritise issues as more, or less, important. Instead, the value of the study reported in this paper derives from: (1) the breadth and detail of the issues that have been identified; and (2) their categorisation in a unifying framework. Together these provide a foundation for future research and may also usefully inform future institutional implementation and practice.