This blog was kindly authored by Rachel Reeds, higher education admissions expert and consultant.
If you have yet to read yesterday’s part one blog on the LLE click here.
There’s an uncomfortable truth about institutional readiness that needs addressing: most universities fundamentally underestimate what the LLE will demand of them.
Senior leaders know the LLE is coming. But there is a dangerous assumption that this is primarily a finance and student funding issue – something for finance teams to monitor and student services to communicate. The reality is that the LLE will require fundamental operational transformation across every function of the university.
The scale of the challenge reveals itself through uncomfortable questions that institutions are still avoiding:
- Can student record systems actually track credit accumulation over decades? Most were designed for three-year degree programmes with cohort-based progression, not learners who might take a single Level 6 module this year, return in 2029, and eventually piece together a qualification over a decade, quite possibly at more than one institution.
- Are modules properly specified at credit level with clear prerequisites? Many institutions have curriculum structures built around programme-level frameworks, not the granular building blocks that modular learning demands.
- Can admissions teams handle continuous year-round applications? After successive rounds of staffing cuts and efficiency programmes, current teams are already stretched managing UCAS cycles. The prospect of rolling recruitment for individual modules, with no additional resource, is simply unrealistic.
The operational questions multiply: Are terms and conditions compliant with the Competition and Markets Authority (CMA) for students accumulating credits over multiple years? What happens when someone wants just one module with no intention of completing a degree? How do you handle credit transfer at scale when you have never done meaningful Recognition of Prior Learning volumes?
The misconception that the LLE is primarily about funding mechanisms is perhaps the most dangerous assumption of all. Yes, finance teams need to understand new funding flows. But this misses the fundamental point. If the LLE is to work as policymakers from across the policial spectrum envisage, then it will LLE represent a shift from programme-based to credit-based provision that touches curriculum design, quality assurance, academic regulations, timetabling, student support, data reporting and every operational system universities rely on.
When senior leadership frames this as a finance workstream, the necessary operational transformation does not get the executive attention or resources it requires. If senior leaders are presenting LLE to Council as a finance and student funding matter, governors have no basis to understand the scale of either the opportunity or the risk. They can’t help shape strategic direction on serving new learner markets, nor can they provide proper oversight of the operational transformation and resource investment required to deliver it. Meanwhile, registry, admissions, IT, and academic departments are left trying to solve systemic challenges without the authority or budget to make the fundamental changes needed.
Professional services teams have been systematically reduced through years of efficiency drives and cost-saving programmes. The people who need to operationalise the LLE are already managing increased workloads with fewer colleagues and creaking systems and processes.
The assumption seems to be that these teams will simply absorb the LLE as ‘business as usual’. Redesigning processes, implementing new systems, rewriting regulations, all whilst maintaining current operations is not realistic. It is a recipe for implementation failure.
Registry teams cannot redesign credit accumulation processes in their spare time. Admissions teams cannot develop year-round recruitment models on top of existing multi-intake cycles without additional staff and/or tools. IT teams cannot rebuild student record systems while maintaining business-critical services without investment. Academic departments cannot restructure entire curricula to credit-level specification without time and resource.
The question is not whether teams understand what needs doing – it is whether anyone realistically has the capacity to do it at a time of financial strain.
This combination of misunderstood scope and absent resource leads to dangerous diffusion of responsibility. Registry assumes it is an IT systems issue. IT believes it is curriculum design. Academic departments expect professional services to handle operational details. Finance thinks it is about loan administration.
The LLE is an opportunity, yes, but it’s also a morass of vital operational issues requiring genuine resourcing to meet a compliance deadline. When leadership does not grasp the full scope, and teams lack capacity for transformation, nothing meaningful happens until it is too late.
Effective implementation requires executive recognition of what it involves:
- Honest capability assessments. Most institutions will discover significant gaps between current systems and LLE requirements – but only if they’re looking beyond finance processes.
- Real budget and dedicated people across multiple functions. This cannot be delivered through ‘efficiency’ or by already-overstretched teams finding ‘extra capacity’. It requires investment, backfill, or explicit decisions to stop doing other work.
- Realistic scope decisions. Should institutions phase introduction?
- Critical path prioritisation. Curriculum design must come first, followed by systems capability, then policy frameworks. This is a multi-year transformation programme requiring dedicated resource, not a finance adjustment to be absorbed by existing teams.
Applications open September 2026. The institutions that will navigate this successfully are those whose senior leaders truly understand both the scale of operational change required and the resource investment needed to deliver it.
The LLE represents a genuine opportunity to serve learners differently and reach new audiences. But opportunities require investment to realise. The operational transformation needed is substantial, but it is achievable – if institutions are honest about what it will take, realistic about timelines, and willing to resource it properly.
Right now, too many institutions are underestimating the challenge. But there is still time to get this right – if the difficult conversations happen now.