In an email seen by Times Higher Education, Stephen Marston, the university's vice-chancellor, has told staff that the university has 1,611 "firm applicants" so far, a long way off its target of 2,330 full-time home undergraduates.
The vice-chancellor, who is a former director-general of higher education funding and reform at the Department for Business, Innovation and Skills, says that "some other universities in our benchmark group seem to be in a similar position".
He outlines a strategy to step up marketing and boost student numbers in clearing.
"Clearly this is a challenging position," Mr Marston adds.
"We need to do everything we can to achieve our target intake, because many of our plans for investing in the future success and development of the university depend on that."
Gloucestershire, which set annual undergraduate tuition fees for 2012-13 at £8,250, is recovering from a historic debt that currently stands at around £22 million.
Some in the sector believe that universities such as Gloucestershire may be experiencing the effects of the government's AAB policy.
A number of high-demand Russell Group universities are taking advantage of the policy, which allows unlimited recruitment of students with the highest A-level grades. The University of Bristol plans to recruit an extra 600 students.
This extra recruitment could potentially draw in students who would otherwise have applied elsewhere.
But post-1992 universities reject any suggestion that they are experiencing a pronounced shortfall.
Matthew Andrews, chair of the admissions practitioner group at the Academic Registrars Council, said: "There is concern about whether [some] institutions are going to achieve their numbers this year...I don't think Gloucestershire is unique in that."
The most recent data from the Universities and Colleges Admissions Service, published in April, show a 9 per cent decline in undergraduate applications by UK students for 2012.
But Mr Andrews said that fewer applicants are accepting the places they are offered.
He added that current data point to a 23 per cent decline in unconditional firm acceptances from students who already have their A-level grades from a previous year - including those who took a gap year, and mature students.
Some students were making applications and then being deterred from taking up a place when they "learned more about the finances" and the details of the new student loans system, he suggested.
Mr Andrews said that changing patterns in admissions were "to do with uncertainty generated by both institutions and students being in a completely unknown situation".
In the email to Gloucestershire staff, sent on 25 May, Mr Marston says that four subject clusters are at or near 50 per cent of their student number targets: business and management, leisure, computing and public services.
In a statement to THE, Mr Marston said that Gloucestershire had been granted additional student numbers for 2012 and "with that growth in mind has currently achieved 76 per cent of its target, with a buoyant late recruitment round anticipated over the summer".
He added: "Clearly, the whole sector is as yet uncertain how the market environment will respond post-A-level results and in subsequent recruitment cycles, as the higher education environment becomes more exposed to the market and as the market itself matures."