Category: lifelong learning entitlement

  • Why the LLE may not radically reform tertiary education — and how it might still move the dial

    Why the LLE may not radically reform tertiary education — and how it might still move the dial

    Picture two people you probably know. Amira works in a GP surgery and wants to move into health data. Ben’s a video editor who keeps bumping into AI tools he doesn’t quite understand.

    The Lifelong Learning Entitlement (LLE) looks built for them: pay per credit, learn in chunks, fit study around life. It’s a real step forward. But a finance switch rarely rewires a whole system. Who recognises learning, who lets you progress, and who supports you while you study still decide who actually gets through the door.

    In simple terms, the LLE funds learning at levels 4–6 (from Higher Nationals up to bachelor’s) and lets people use an entitlement over time (currently up to age 60). Providers are paid per credit. Early emphasis is on areas with clear employer demand (for example computing, engineering, health) and on Higher Technical Qualifications. Funded modules typically need to be at least 30 credits, assessed, and housed inside an approved “parent course”. Subjects are tagged using a national list (HECoS), and modules are expected to align with the parent course’s main subject tag – a guard-rail that ties funding to real, quality-assured programmes.

    Money fix won’t deliver system fix

    Being able to pay isn’t the same as being able to progress. One university ultimately decides whether learning you did elsewhere counts towards its award, and practice varies. Modularity also isn’t cost-free: even short units need admissions checks, timetables, advice and assessment, so institutions may scale cautiously or stick to subjects with clear prerequisites. And performance metrics were built for whole degrees, not “step-on, step-off” study, so departments worry about being penalised when learners pause between modules.

    At the most selective end of the system, mid-course entry and external credit are rare. That’s not special pleading; it reflects how recognition works in England: one university confers the degree and decides what counts. The LLE can pay for learning in many places; it doesn’t compel acceptance.

    Colleges and universities can make progress quickly by acting as one system: align first-year expectations so college students aren’t starting cold; recognise T Levels and Higher Technical Qualifications clearly in admissions; share transition data so support follows the learner; co-deliver study-skills content; and publish simple maps showing which level-4 modules count towards which degrees. Otherwise, too many learners hit the boundary and bounce off it (see this practical bridging agenda from Imran Mir at Apex College Leicester).

    In countries where adult study is normal, systems don’t just fix tuition; they also help with the time cost of learning and make credit transfer routine. The pattern is tuition + time + transfer solved together. England’s LLE chiefly tackles tuition; the other two levers still need work.

    The wider growth story is that systems that reach more adult learners tend to do three things at scale: institution-wide digital delivery (not a side-project), employer-linked curricula and experiential learning, and a clear identity around inclusion and student success. The LLE can be the catalyst, but only if leaders build for lifelong learners across the whole institution rather than at the edges, with enterprise-level innovation in online and hybrid learning, partnerships, brand reach, and transfer-friendly design.

    Interdisciplinarity without contortions

    A live tension is the HECoS rule: a module’s main subject tag is expected to match its parent course. That keeps data tidy and protects students, but it can blunt genuinely cross-field learning just as employers ask for blended skill-sets (AI plus a domain like health or media; green and digital transitions).

    Createch – where creative practice, design, computing, data/AI and business models meet – is a good test case. There are two practical tracks. One is provider-led, inside today’s rules, and would involve setting up interdisciplinary parent programmes (for example, Createch and Digital Production) so the main tag stays compliant, and using secondary or proportional tags to reflect the mix. Institutions would co-deliver paired modules across departments with published progression maps and build employer-validated outcomes so transfer is easier to justify.

    A policy-led approach would require government and regulators to clarify guidance on proportional coding and run time-limited pilots allowing defined exceptions to the strict primary-code match where labour-market need is clear (Createch is a strong candidate). After consultation, there could be small, targeted tweaks so specified cross-disciplinary modules can be funded without awkward rebadging.

    Options for system development

    Portability needs to be easier to plan. A credit-transfer guarantee in a few defined subject areas, backed by shared learning-outcome descriptors and a standard digital transcript, would give learners and providers confidence. Publishing typical acceptance rules – and deciding transfer requests within indicative timeframes – would also help.

    Fund time as well as tuition, selectively. A wage-linked maintenance pilot for priority level 4–6 modules, with pro-rata childcare and disability support, could unlock participation for adults who can’t take a pay hit to study.

    Commission where demand is obvious. A small national fund could buy short university courses in shortage areas with colleges and local employers.

    Build planned pathways. Federated degrees and regional FE–HE compacts can publish simple maps from level 3/4 to degree entry (including any bridging) and show how 30-credit modules stack inside an approved parent course.

    Tune the measures. Outcome metrics that recognise pauses between modules would reduce the risk of doing the right thing for modular learners.

    Balance selective and inclusive levers. Any growth money might come with contextual admissions and targeted pathways at high-tariff universities, alongside serious student success investment where most low-income learners actually study and, crucially, institution-wide innovation rather than pilots at the margins.

    The LLE widens options but on its own it won’t rebalance outcomes. If England wants fair access and attainment, the system can combine portable recognition, realistic support for time out of work, and commissioned provision where need is greatest – and pair it with institution-wide innovation that treats adults as core learners, not extras. That’s how Amira and Ben actually get through the door, and how the sector grows again.

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  • Could the Lifelong Learning Entitlement usher in a new era of skills-based curriculum?

    Could the Lifelong Learning Entitlement usher in a new era of skills-based curriculum?

    As it stands the Lifelong Learning Entitlement mostly represents a reorganisation of higher education funding and systems for quite a lot of short term operational pain and very little payoff.

    But for institutions prepared to play the long game, it could represent a real shift in how higher education is configured and how it integrates with the labour market.

    That doesn’t just mean taking existing courses that were designed for three years of intensive study and breaking them up into constituent parts – though in some cases the ability to do that could offer a lifeline for students needing to earn before they can learn. The larger prize on offer is courses that are actively designed for the contemporary labour market, in which the building blocks of the curriculum are skills and work-related competences, rather than academic knowledge.

    Let’s acknowledge from the outset the false dichotomy – knowledge requires skills to acquire and apply it, and skills require a structured context of knowledge to be meaningful and applicable. But the “skills-based curriculum” is gaining traction around the world for a reason: primarily to address a perceived demand among students and employers for learning that is practical and applied, and that prepares students to succeed in the contemporary labour market, which requires a complex mix of technical and interpersonal skills. It promises more than the embedding of in-demand skills into a traditional academic curriculum; skills-based curriculum centres work-based skills as the primary learning outcome.

    Opportunities and risks

    One corollary is that the learning itself becomes more hands-on, project-based, active, and collaborative, in order to foster those skills. Students are very clear from the outset what they are learning to do and what the workplace application will be. As some employers turn to skills-based hiring practices, graduates can readily match their experience to employers’ expectations and demonstrate, with evidence, their competences, reducing the need for a long tail of additional experience to supplement the degree certificate in the name of “employability.”.The focus on authentic learning environments and assessments also goes some way towards AI-proofing the curriculum: AI can be deployed authentically in workplace-relevant ways, not used as a shortcut to evidencing thought.

    This all sounds fantastic and straightforward, even hyper-efficient. The relevance to the LLE’s intention of a more flexible, stackable HE model lies both in the notional desirability of education oriented towards work and employment, and in the efficiency and transparency of the relationship between skills developed through education, and work.

    But there are risks, too, for both providers and students. In the absence of any kind of agreed national (or global) taxonomy of skills, that could allow for a body of practice to develop around the pedagogies and environments that demonstrably allow students to develop them, any provider may claim to offer something “skills-based” with little in the way of evidence or robust quality assurance. In an open market, students may be drawn in by the promise of work-readiness, only to discover that their learning adds up to very little. Skills England has in the last few weeks published a new UK standard skills classification that addresses the first problem; the second remains open for solutions.

    The market for such provision in the UK remains untested; the current premise of the LLE rests on the assumption that existing programmes can be disaggregated meaningfully into modules that simultaneously offer something of value as a short course of study, while also contributing towards a larger qualification. While this may be true in some cases, it certainly will not readily apply to all. Introducing skills as a core outcome, while it may work quite well for a module or short course, opens up the question of which aggregated sets of skills can be said to be meaningful in a journey towards a substantive qualification. This is a significant challenge for higher education as it is currently configured, going far beyond the merely functional and operational, touching on the core purposes and processes of higher education and the need to manage carefully the consequences of bringing “skills” to the forefront of higher education pedagogy.

    More prosaically, all this active, authentic learning doesn’t come cheap, and it requires a strong relationship with employers to deliver, raising questions about whether it is possible to develop a high-quality skills-based offer at scale. And that’s before you start questioning what the regulatory implications might be.

    These risks are only risks, not insuperable obstacles – UK HE providers, such as the London Interdisciplinary School, have adopted a “skills first” model of higher education without incident. While appetite within the sector to develop a more skills-focused offer is variable, there are institutions – such as Kingston University – that have developed an explicitly skills-focused element to complement existing programmes, and others that are interested in the potential for reconfiguring or extending their offer around skills, especially in light of the creation of Skills England and the prospect of a more systematic approach to meeting national skills needs.

    What needs to be true

    But for this model to become more widely embedded across higher education providers, and to realise the potential of the LLE to facilitate innovation in curriculum content as well as delivery, some things that are not currently true will need to become so. At the Festival of Higher Education, together with Ellucian colleagues, we hosted a private round table discussion exploring what a student journey through a more skills-based, “stackable” offer might need to look like.

    Not everything needs to be done collaboratively all the time, but there are moments in which there can be greater strategic advantage in collective innovation than in being the first mover, and significant higher education innovation could be one of them. Working collectively creates greater security both for institutions and students that the offer is well thought through and robustly quality assured, and that it will be legible to prospective students seeking to explore their choices, and have credibility in the labour market. Pooling risks in this way could help to reduce the stakes in making the decision to roll out a novel kind of provision, and potentially allow for some sharing of start-up costs.

    One area that is lacking is better market intelligence – the assumption that there is a sustainable demand for shorter and stackable higher education courses remains unproven, and some investment in exploring the nature of that demand would help institutions to tailor their offer more effectively rather than spinning up provision that is at high risk of failure either because it does not recruit or because it does not adequately meet the needs of the people who are attracted to it on principle.

    In the domain of core learning and teaching there is a need for exploration of the pedagogic frameworks and approaches that can support a high-quality and academically robust skills-based offer. Some degree of consistency in approach to building pathways through programmes designed around skills could offer an alternative to reliance on credit as the currency that notionally allows for portability between providers and in practice is very hard to implement. Retaining student choice and the possibility of personalisation is typically important to students and providers alike, so there is a flexibility imperative there that it would be hard to tackle as an individual provider.

    Accessing this type of higher education, in this way, opens up the question of reimagining the “student experience” and the underpinning systems that can enable institutions to manage it. Students will need clarity about access to work – through placement, internships or joint provision with employers – the relationship between work, learning and skills development, and ultimately who is responsible for their experience. Access to services will need to be tailored to the student, and both students and providers will need to accurately keep track of modules completed, and skills acquired, and when.

    Curriculum management systems will need to allow students to chart their way through a particular pathway and register for modules, while incorporating guardrails to avoid students choosing pathways that add up to, in the words of one attendee, a “smorgasbord of nonsense.” Support for students in mapping or curating their chosen pathways will need to be built in from their very first module, and they would need to be able to request and access a “transcript” that details their skills at the point of completion of any module.

    Skills-based curriculum needn’t be stackable and stackable higher education needn’t be skills-based, but there is clear potential for synergies between the two. Just as skills-based curriculum is unlikely to replace traditional knowledge-based curriculum wholesale, modular study is unlikely to replace the full-time experience. That doesn’t rule out the possibility of significant change though.

    Opinion is divided as to whether the LLE will enable higher education growth through innovation and access to new demand, function to create some ease and flex in a system that will enhance access to those who find engaging with the current system a struggle, or neither (or something else as-yet-unanticipated). But as higher education institutions consider the future, growth and access seem like the right targets to be aiming for. Skills-based curriculum, if developed strategically and thoughtfully, avoiding “innovation theatre,” could be helpful in both cases.

    This article is published in association with Ellucian. Take a glimpse at the technology supporting the future of lifelong learning here.

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  • What we still need to talk about when it comes to the LLE

    What we still need to talk about when it comes to the LLE

    The Lifelong Learning Entitlement (LLE) has been promoted as a transformational change that will broaden access to flexible education and training.

    Though there have been several delays to implementation, the recent Post-16 Education and Skills White Paper has solidified the government’s commitment to delivering the LLE as planned.

    In theory, the LLE could open the door for learners who never imagined higher study, while unlocking a pipeline of talent for the high-skill jobs our economy desperately needs.

    For most undergraduates, the student finance process will remain largely the same with new features added to their application portal. For providers, it is a major operational shift that will require new systems, administration processes and advice and guidance. And while the policy spotlight has been fixed on modular learning, there are other opportunities that could be easily missed.

    The appetite for modular learning

    Modular learning has been pitched as the new frontier of flexibility. In its latest publication, the OfS shared outcomes from their Call for Evidence on how to measure student outcomes in modular study. While the report offers guidance for curriculum designers and quality assurance teams, the policy agenda has shifted since 2023, and demand is still uncertain. The OfS’ own short course trial indicated that demand was limited and the Modular Acceleration Programme has yet to deliver clear lessons.

    A 30-credit bundle would cost around £2,383 (assuming a £9,535 fee is applied to the parent course), this rate for a single module looks questionable compared to cheaper, industry-recognised certificates. With a credit transfer consultation not due until spring 2026, a national framework remains distant, and it is still unclear whether there is broad sector support for such a framework. If a national framework were to be implemented, some HEIs may see this as a challenge to their institutional autonomy and academic distinctiveness.

    If interest in modularity grows, providers will still need to consider whether employers will value standalone modules as much as full qualifications, the duration it will take to stack credits (accumulation to a full award), and the validity of earlier modules when pursuing a professional qualification. These factors will determine whether development in modular learning is a worthwhile investment.

    The target audience

    The rhetoric often frames modular study as a boon for employers. But there’s a problem: if staff are encouraged to take out loans for training their employer needs, it could be seen as a pay cut because the loans will need to be paid back with interest by the employee.

    It is in our view that CPD should sit in the employer-funded training budget, or within the forthcoming Growth and Skills Levy. Employers are of course important – but in terms of helping providers ensure there is labour market currency in a course. The learner will be accountable for the loan and so it should ultimately be viewed in terms of its benefit to the learner and not the employer; any digression from this may risk employers using the LLE as a replacement for their CPD budget, with employees picking up the bill.

    If you take out employer-driven training from this, there are three main group of learners that may be attracted to modular learning:

    • Top-uppers – employees whose employers have funded some modules and who now want to complete a qualification.
    • Passionate learners – individuals happy to pay for a module to support their career or for the joy of learning.
    • Mature learners – carers, full-time workers, and others who need smaller, flexible entry points into HE.

    The bigger opportunities hiding in plain sight

    While modularity dominates discussion, two quieter reforms within the LLE could prove even more transformative.

    Priority additional entitlement (PAE) will expand to include areas such as teaching, social work, and healthcare – vital for sustaining public services. Learners who have already used up their entitlement will still be able to access loans in these areas for full degrees.

    And the removal of the equivalent and lower qualification (ELQ) rule means graduates with residual funding and/or those that use PAE can now retrain at the same or lower level (up to level 6, at least). This opens retraining and reskilling opportunities that were previously out of reach.

    Together, these changes could unlock the mature learner market – carers, career-changers, full-time workers, those who exhausted loan entitlement on a previous degree, or NEET graduates looking for a route back into the labour market.

    It also raises another question on whether the LLE should have been capped at age 60 as many in their sixties could still make meaningful contributions in teaching, health, and social care if they had the funding to retrain.

    Our recommendations

    For the sector to take full advantage of the LLE, we recommend that providers plan for continuity – ensure there is a seamless transition from higher education student finance (HESF) to LLE for mainstream undergraduates. Operational teams should have a firm understanding of the in service changes detailed in key guidelines such as the Course Service Management Definition. This is important in distinguishing the differences between technical requirements and aspirational aspects of the policy.

    Within this technical preparation, there is a need to treat modular learning as an evolving opportunity – demand, delivery, and impact are still emerging. The Post-16 Education and Skills White Paper confirmed there will be some interaction between the LLE with the forthcoming Growth and Skills Levy, likely initially through “apprenticeship units” and Higher Technical Qualification modules beingt tied to occupational standards. Providers should anticipate how this might unfold in priority areas such as artificial intelligence, digital skills, and engineering, and plan strategically for early implementation.

    Within all of this we need to make it clear that the LLE is for the learner – the LLE should be a learner entitlement, not a subsidy for corporate upskilling. Mapping how different funding streams (e.g. LLE, Growth and Skills Levy, Skills Bootcamps, Adult Skills Fund) interact will be vital. Institutions must ensure that learners receive clear advice and that funding follows the purpose of study, whether employer-driven or learner-led. There’s an opportunity to radically expand access – the expanded entitlement and ELQ reform present major opportunities for retraining and second-chance learning. To unlock this market, provision must be genuinely flexible, accessible, and clearly explained. Institutions should design modular and part-time routes that accommodate work and caring responsibilities while demystifying the complex funding landscape through transparent guidance.

    Further considerations for long-term success

    The sector has been encouraged to explore modular learning, however, for many HEIs modularity is best viewed as an enabler rather than a standalone offer. The real prize of the LLE lies in the funding flexibilities in widening access to learning, retraining pathways, and mature learner opportunities sitting just beneath the headlines.

    If we want the LLE to deliver on its promise, we need to first ensure that all HEIs feel confident in transitioning to a new funding system to minimise disruptions to students. Following this, to truly achieve long-term transformation, we need to ask the hard questions about the purpose of modularity, the dichotomy between learner- and market-driven education, and the cultural shift required to draw more people into different higher-level learning, no matter where they are in life.

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  • Falling mature student numbers requires policy action

    Falling mature student numbers requires policy action

    With the clutch of traditional higher education flashpoints accounted for – A level and SQA results days, and a clearing season reported to be particularly fraught in some quarters – the summer is drawing to a close, and a new academic year is upon us.

    Eighteen year olds are set to attend universities in record numbers, up 5 per cent year on year and up 27 per cent since 2016. This is unquestionably a great thing. However, it masks a troublingly stubborn decline in mature students numbers.

    In recent years, the number of these students – those aged 21 and over (or 25 and over for postgraduate study) – entering UK universities has been falling at an alarming rate, down by 26 per cent since 2016 according to UCAS. This decline may sound like a niche concern, but it carries big implications for the wider economy, for skills shortages, and for the prospects of people who want to reskill later in life.

    As the government prepares to roll out the Lifelong Learning Entitlement (LLE), there’s an urgent opportunity to rethink how the sector and society support adult learners and to ensure that lifelong education becomes a central pillar of our skills system.

    The current picture

    While the signs from clearing so far offer some encouragement, due perhaps to a sluggish economy, the data remains stark. Over the past decade or more, the number of mature students entering higher education has steadily declined, down 43 per cent since 2012.

    The causes are multifaceted, but a shift began with the introduction of higher fees in 2012 and has persisted – it is well established that mature students tend to be more debt-averse, so this coupled with the rising cost of living and the upfront financial commitment of a degree will no doubt put off many.

    Others may well be put off by a lack of flexibility. While real strides have been made in this area, particularly at modern universities, the structures of funding and regulation mean a lot of courses are still designed for school-leavers with the time and freedom to study full-time. Family responsibilities, limited employer support for training and the still-dominant perception that universities are designed for 18-year-olds will also play a role.

    The pandemic briefly nudged some adults back into learning, but the overall trend remains downward. Without targeted action, these numbers are unlikely to recover on their own.

    A price to pay

    Why does this matter beyond the university sector? Because a thriving economy depends on people being able to learn, retrain, and adapt throughout their lives. Mature students often bring real-world experience into classrooms and tend to choose courses that fill urgent skills shortages – in health and social care, teaching, engineering, IT, and other high-demand sectors.

    When these pathways dry up, industries suffer. Skills gaps are prevalent across key sectors and have been estimated by the Recruitment and Employment Confederation to cost the economy almost £40bn per year. Without a pipeline of retrained workers, employers struggle to fill gaps, productivity growth stalls, and regional economies miss opportunities to regenerate.

    It’s also an issue of social mobility. For people whose school results closed off higher education the first time around, mature study offers a second chance to change careers, boost their earnings, and improve their families’ prospects. If that route disappears, inequality widens – and our economy pays the price.

    A new hope?

    The LLE, due to launch in 2026, aims to reshape post-18 education in England by enabling a move away from the traditional three- or four-year degree as the default model. Instead, individuals will be able to draw on a single pot of funding – equivalent to four years of study, or around £38,000 – and use it flexibly over their lifetimes, taking courses in smaller, more targeted chunks.

    In principle, this modular approach could open the door for adults with work and family commitments, allowing them to pursue short courses when needed and return later for further study without losing access to funding. By making learning more flexible, affordable, and tied to labour market needs, the LLE is pitched as a way to lower barriers that currently deter many mature learners, particularly in an economy being reshaped by AI, automation, and the green transition.

    Yet the promise of the scheme is far from guaranteed. The rollout is proving complex, with uncertainties over how funding will be administered, whether universities and colleges will be equipped to redesign courses in modular formats, and how easily learners will be able to navigate the system. Awareness is another challenge: adults with established careers and busy lives may not know the scheme exists, or may find the process of accessing funding too bureaucratic to be worth the effort. Employers, meanwhile, will need to support staff in using the entitlement – something that cannot be assumed.

    There are also cultural and practical reasons to doubt whether large numbers of mature learners will take up the LLE. Adults may be reluctant to re-enter formal education, particularly if they are anxious about returning to study, lack confidence with digital learning, or doubt the value of small qualifications in the job market. Others may weigh the potential benefits against the costs – not only financial, but also in time and disruption to family or work responsibilities – and decide against it.

    In short, while the LLE represents a bold attempt to modernise lifelong education, its success will depend on whether the system can overcome significant implementation hurdles and whether mature learners themselves see it as accessible, relevant, and worthwhile.

    The role of modern universities

    Universities are at the heart of this challenge. They too cannot rest on their laurels and must continue to consider how they design, market, and deliver their courses if they are to serve lifelong learners as effectively as they serve 18-year-olds fresh from colleges. Modern universities, which traditionally teach the majority of mature undergraduates, must continue to lead this agenda from the front.

    Partnerships with local employers, another area in which modern universities lead, are key. By aligning courses with regional economic needs – for example, creating pathways into green technologies, health and care, or digital sectors – universities can help ensure that adults return to education with a clear line of sight to better jobs.

    But a cultural shift is just as important. Universities need to be hubs for lifelong learning, not just finishing schools for young adults, and the government has significant work to do in getting the word out to the general public that the opportunity to study or re-train is there to be taken.

    The decline in mature students is more than a higher education story. It’s a warning sign for our economy and for our ability to adapt to change. The LLE offers a chance to reverse the trend – but only if universities, employers, and policymakers work together to make lifelong learning a reality.

    In a fast-changing world, education cannot stop at 21. The people of Britain need a system that allows people to keep learning, keep adapting, and keep contributing to the economy throughout their lives.

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  • The LLE finally gets a Labour overhaul

    The LLE finally gets a Labour overhaul

    If you still imagined that the Lifelong Learning Entitlement (LLE) would mean that a student studying any module from any course would be eligible for 30 credits of funding, it’s long past time to disabuse yourself of that notion.

    Under the latest plans, eligibility only extends to short courses dealing with those subjects identified as national priorities – via a somewhat tenuous link to the industrial strategy – along with HTQ modules. Everything else in higher education will be funded by year of study, as is currently the case.

    If you were thinking that this latest round of changes – taking us even further away from the initial dreams of Boris Johnson (or even Philip Augar) – completes the long gestation of the LLE in full detail you will be disappointed. For instance, the credit transfer nettle has yet to be grasped – with a consultation due in early 2026, not far in advance of the September 2026 soft launch. And there are, as we shall see, a number of other issues still dangling.

    It’s a continuation of DfE’s gradual retreat from a universal system of funding that was supposed to transform the higher education landscape. No variable intensity, a vast reduction in modular availability – it just allows some of the short courses that universities and colleges already offer to be funded via the loan system (a measure, lest we forget, of dubious attractiveness to learners).

    A bridge to nowhere

    The Lifelong Learning Entitlement (originally known as the Lifelong Loan Entitlement) was announced by Prime Minister Boris Johnson on 29 September 2020, as a part of the government’s lifetime skills guarantee:

    we’ll expand and transform the funding system so it’s as easy to get a loan for a higher technical course as for a university degree, and we’ll enable FE colleges to access funding on the same terms as our most famous universities; and we’ll give everyone a flexible lifelong loan entitlement to four years of post-18 education – so adults will be able to retrain with high level technical courses, instead of being trapped in unemployment.

    Like most of Boris’ wheezes it was originally somebody else’s idea – in this case Philip Augar. He had a few more specifics:

    The government should introduce a single lifelong learning loan allowance for tuition loans at Levels 4, 5 and 6, available for adults aged 18 or over, without a publicly funded degree. This should be set, as it is now, as a financial amount equivalent to four years’ fulltime undergraduate degree funding. Learners should be able to access student finance for tuition fee and maintenance support for modules of credit-based Level 4, 5 and 6 qualifications. ELQ rules should be scrapped for those taking out loans for Levels 4, 5 and 6.

    But it makes more sense to think of the idea as being 100 per cent Boris in that it was a massive infrastructure initiative that he had no clue how to actually deliver (in all honesty, not much of Augar was deliverable either – perhaps that was the attraction). As has proved to be the case.

    As you were

    Let’s start by looking at what’s unchanged, following the latest revisions. The timeline for getting started remains as was: applications from September 2026 for courses and modules starting in January 2027. This still feels extremely optimistic. Plus – as has been the case for a while – a staggered rollout of standalone modules is planned, rather than an enormous platter of bitesize options spread out to pick from come next September.

    The use of the current plan 5 student loan model, with its 40-year term and nine per cent repayment rate above what is currently around minimum wage, is still there – with all the peculiarities this will inevitably engender. If anyone was expecting a large scale shake-up of the student finance system any time soon, this should serve as an enormous hint that no radically new model is arriving in the short to medium term.

    Also retained from DfE’s planning under the Conservatives is the system of “residual eligibility”, meaning how much loan is available to those who have already, for example, studied one undergraduate degree. You still get the equivalent of four years overall, though with lots of wrinkles.

    The aspiration for each member of the public to have an LLE personal account continues – this will still include, in theory, information on one’s loan balances, an application tracker, and advice and guidance on career planning.

    And in broad strokes the government’s rationale for the LLE persists: more flexible routes through tertiary education, support for upskilling and retraining throughout one’s career, and the promise of more learner mobility between institutions.

    Picking winners

    The LLE is replacing England’s entire student funding system, and so funding for full years of study at levels 4 to 6 – such as degrees or higher technical qualifications – will flow through it. In many cases, though, this is just a shift on paper.

    What’s always been the more significant change is how it will bring the funding of individual modules into scope, along with the resulting interplay between single modular courses and larger programmes of study in a learner’s lifelong journey.

    Modular provision that would be eligible had previously been defined as “modules of technical courses of clear value to employers” – this is now rejigged to:

    modules of higher technical qualifications, and level 4, 5 and 6 modules from full level 6 qualifications, in subject groups that address priority skills gaps and align with the government’s industrial strategy.

    We flagged this link between the LLE and the industrial strategy priority areas when the latter was published last month – and the updated LLE policy paper does say that DfE has worked with Skills England to assess skills priorities, though there is no detail on this.

    What we very much don’t get is a mapping between LLE subjects and the industrial strategy sectors (the IS-8), or the priority sub-sectors and their corresponding links to certain regions or clusters which is, y’know, what the industrial strategy is all about. Arguably the main bone thrown to the industrial strategy is the concept of the government “picking winners” – but note there is no stumping up of public funds to support this.

    So we get a list of which subject groups will be in scope for modular study:

    • computing
    • engineering
    • architecture, building and planning, excluding the landscape gardening subgroup
    • physics and astronomy
    • mathematical sciences
    • nursing and midwifery
    • allied health
    • chemistry
    • economics
    • health and social care.

    Common Academic Hierarchy (CAH) fans will be delighted to spot that this appears to have been done (with the curious landscape gardening exception) at the very top level. These are very broad subject groups, which will contain multiple subjects with questionable relevance to the industrial strategy.

    While on the face of it there is some ambiguity about whether this subject list refers to only level 6 qualifications, or to these and higher technical qualifications (HTQs), the accompanying provider preparation guide makes clear that the subject groups here are for level 6 qualifications only – and provision via HTQ modules covers many other subject areas, which in some cases overlap. This currently includes subjects such as business and administration, education and early years, legal and accounting, and many others – but these will need to go through the HTQ approval route.

    The provider preparation guide suggests that institutions should be looking at their current degree provision, working out where it aligns to the priority skills gaps areas that DfE has identified, and then proceeding from there in thinking about what could be modularised. All modular study, remember, needs to form part of an existing designated full course which the provider delivers – we’re a long way from some of the previous visions of universities coming up with new stand-alone bitesize offers.

    All the other funding eligibility rules for modular provision remain – they must have a single qualification level at level 4, 5 or 6, they must be at least 30 credits (though bundling up modules to meet that minimum is allowed), and a standardised transcript of some form to be determined must be delivered upon completion, to facilitate credit transfer.

    But there is one change to eligibility rules – modular provision must not be delivered through franchised arrangements. This had always sounded like a recipe for disaster. The government has been gradually setting its face against a lot of existing franchising activity, given concerns about quality and reports of fraud.

    Getting approved

    The previous plan for approving modules (outside of HTQs) for LLE eligibility was what was being labelled a “qualifications gateway”, which the Institute for Apprenticeships and Technical Education consulted on last January. This terminology has been scrubbed entirely out of the policy paper now, with just a note that “we will set out details on how level 4 to 6 Ofqual regulated qualifications could enter the market and access LLE funding.”

    But there’s a new approval process in town – providers who are interested in delivering modular provision from January 2027 will need to submit an expression of interest, from this month.

    This process will involve an “assurance check” – seemingly run centrally by DfE, rather than Skills England as might have previously been expected. There’s a wonderful flowchart in the provider guide, which you may or may not be able to read depending on how enormous your screen is:

    That’s right – TEF! Providers with gold or silver will have access to a “simpler and quicker approval process” for modular provision. Those who do not will be asked to provide additional information around “readiness, capability and successful delivery of the parent course.”

    Hang on, you cry, doesn’t the fact a provider is registered with the Office for Students demonstrate that it has “readiness” and “capability” to deliver courses of any type? Well, yes, it does. It is possible that DfE simply doesn’t trust OfS to make this kind of judgement – which would point to a rather larger issue with higher education regulation – or it could be that this is a last gasp attempt to give TEF awards some regulatory relevance.

    This is also the case for those rated “good” or “outstanding” for Ofsted provision – and if Ofsted inspects your skills provision and you have a TEF award, they both need to make the grade. Now headline Ofsted assessments were supposed to disappear from September 2025, which makes this all a bit confusing.

    If you don’t deliver HTQs or appropriate level 6 qualifications, it’s noted that modular provision is anticipated to “gradually expand when appropriate to do so” and so you may, one day, come in line for eligibility.

    Regulatory issues

    One of the areas the previous version of the policy paper promised was further information on the regulation of modular funding. This, rather oddly, is no longer listed under “next steps”, given that the update we do get is relatively slim.

    What we might have expected was a follow-up to the Office for Students’ call for evidence on positive outcomes for students studying on a modular basis – a call for evidence which closed in November 2023, and we’ve heard little of since. As DK set out at the time, the quasi-consultation asked how things like the B3 conditions could apply to individual modules, and the regulator’s initial thinking seemed to be that completion would still be a valuable metric for regulation, as would progression – though exactly how progression was assessed would need to be refined.

    There’s still no news on this complicated issue. The new section of regulation focuses more on registration categories, while noting that DfE “will refine the existing regulatory framework to ensure it is proportionate, is targeted [and] supports a high quality, flexible system.” If you were thinking that a whole new approach to learning would need a new oversight framework, the direction of travel suggests not.

    The bigger regulatory news is that, likely to the surprise of few, the idea of having a third registration category for smaller providers offering level 4 and 5 qualifications has been scrapped. Instead the government will extend the current system of advanced learner loan funding for levels 4 to 6 until the end of summer 2030. This will give unregistered providers more time to apply for OfS registration in one of the two existing categories, though OfS is scheduled to consult in autumn 2025 on proposals to disapply some conditions of registration for providers in the further education statutory sector (which already has a regulator looking after most of this stuff).

    Maintenance chunks

    As expected, student maintenance support will be available on a pro-rata basis (depending on course, location, and personal circumstances) in an equivalent way to the existing undergraduate offer. Because this support is intended to deal with “living costs”, DfE has decided to continue to restrict availability to students attending in person – there’s nothing for online or distance learning.

    Additional targeted grants (most likely this just refers to existing disabled students’ allowance and such like) will still be available – but there’s more to come on this later this year, alongside more guidance on maintenance generally. We can perhaps hope that a forthcoming announcement modifying the decades-old system (or even just the parental income thresholds) is playing a part in this delay.

    That feeling of entitlements

    Another area where things have mostly stayed the same is the personal entitlement for tuition fee funding equivalent to four full-time years (480 credits, currently £38,140) of traditional study – with the welcome clarification that where a provider charges less than the maximum the cash value rather than the credit value will be deducted from the total. Maximum borrowing is for 180 credits a year (which would just about cover a year of an accelerated degree). And for existing graduates (with the frankly wild caveats as before) there will be an entitlement to funding equivalent to unused residual credits.

    But what happens when your balance reaches £0? No more learning for you? Not quite – a “priority additional entitlement” may be available (fees plus maintenance) in order to complete a full course in a small number of subjects (medicine, dentistry, nursing and midwifery, allied health professions, initial teacher training, social work).

    For those who follow career paths that require five years or more of study (veterinary surgery, architecture part 2, an integrated masters in Scotland) there will be a “special additional entitlement” of up to two years, again covering fees and maintenance. There’s also additional entitlements for those who take foundation years, placement years, or study abroad years. It’s by-and-large a smoothing-out of some of the unintended consequences with existing provision where representations had been made.

    Plus, importantly, the government will now play a part in mitigating circumstances – if you are resitting a year because of “compelling personal reasons” (illness, bereavement) you will have the costs of your study covered. And resits on longer courses will be covered anyway.

    The credit transfer question

    “The LLE and modular provision will provide a pathway to strengthen opportunities for credit transfer and learner mobility,” the new version of the paper states. While no-one would deny that the LLE could be a “pathway to strengthen opportunities,” especially given how tepid the phrasing is, there has still been essentially no progress on the thorny question of credit transfer.

    The largely new section on “recognition of prior learning, credit transfer, and record of learning” sets out aspirational areas where the government thinks it can work collaboratively with the sector – to promote pathways between providers, to improve guidance for both incoming and outgoing learners, and to generally square the recognition of prior learning circle despite all the intractable problems therein.

    Interestingly, DfE also wants institutions to embed all this into “broader strategies for widening access”. It’s not immediately clear how this will come off – but we get the note that this year will bring an update on “proposed changes that will start to embed this flexibility and greater learner mobility across LLE funded provision.” This might be a reference to the post-16 education and skills white paper.

    To facilitate all this flexibility, DfE had previously said it would be introducing a “standardised transcript template.” Tellingly, this has now been revised down to “a standardised transcript as part of modular funding designation.” So it appears the plan is now to look at enforcing this standardisation for the (potentially scant) modular provision that the LLE will generate, while sidestepping the much bigger question of how portability between modules and larger qualifications including degrees will work. This is a substantial scaling down in ambition – and yet it’s still a complicated thing to get agreed implemented in little over a year.

    What’s next

    As is probably coming across, there is still an awful lot yet to be confirmed. Secondary legislation to implement the LLE fee limits and funding system still needs to be laid. Fee loan limits for non-fee capped provision are pending confirmation. The Student Loans Company needs to get its systems ready.

    There will be another consultation too, in addition to OfS’ further education one. While it’s not mentioned in the updated policy paper, the accompanying provider preparation guide reveals that the Department for Education will consult on “learner mobility across LLE-funded provision in early 2026” (maybe this will be the moment when credit transfer finally gets sorted out once and for all). Opening a consultation in early 2026 when big chunks of the whole shebang are supposed to be ready to go that September does not necessarily inspire confidence.

    And the drip-by-drip announcements about the policy plumbing of the LLE mean that it’s a long time since the government has really restated its belief that there is demand out there for modular provision, or committed to working to drum some up. Really it’s baffling why this week’s announcements haven’t been packaged up with the skills white paper, as surely they must form part of a wider vision. Some clarity within this about overlaps and interplay with the apprenticeship levy would have been welcome too.

    The provider preparation guide entreats institutions to start thinking about how they will market modular provision, which is a tricky question given the absence of demand that pilots have demonstrated. But one of the examples given is particularly problematic:

    if you seek to target mature students, do you need to start building relationships with local employers and/or recruitment agents, rather than only relying on existing recruitment channels?

    This isn’t a new addition to the guidance – but since the last update, Bridget Phillipson has told Parliament that the government will “take immediate action on the use of agents to recruit students,” adding that “the government can see no legitimate role for domestic agents in the recruitment of UK students,” following the Sunday Times franchising investigation fallout. So DfE is at the same time banning the use of domestic agents – or at least it said it would – while acknowledging that recruitment to modular provision might be tricky without them.

    It’s of a piece with much of the preparation guide – the responsibility to iron out the holes in the LLE’s business case is being passed onto providers. Supposedly over the rest of the year universities and colleges should be reviewing everything from accommodation to wrap-around support, while building up relationships with employers and potentially rewriting their academic regulations. All while plenty remains unclear at the sector level. It would be unsurprising to see providers reluctant to leap into the approvals process right away, and instead assess how others fare.

    Given all this, it’s perhaps unsurprising that the ambition of the LLE has diminished a little bit each time the policies around it have been updated. We’re a long way from where we started.

    Probably the most damning assessment you could make is that, were Labour to have opted to cancel the whole LLE and just allow students to take out loans for a handful of higher education short courses tenuously linked to industrial strategy priorities, the sector would be in a very similar situation to the one it is in now. And – given clear indications of lack of student demand, and common sense assessments of the general public’s appetite for more tuition fee debt wrapped up in confusing bitesize-but-lifelong repayment obligations – few would think it was a good idea.

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