Amid all the furore in England over the perceived unfairness of student loan debt repayment terms, it might be argued that this is the worst possible time to be launching a whole new species of courses for a whole new cadre of learners, to be funded by a big expansion in loan eligibility.

Yet the lifelong learning entitlement (LLE) has long been seen to be vital to address another pressure of modern working life: the likely need – particularly given the disruption being wrought by AI – for large numbers of people to retrain in order to remain employable.

will offer four years of undergraduate-level loan funding across a person’s lifetime, and, unlike under current loan terms, learners will be able to spend it on courses at the same level as or lower level than qualifications they have previously obtained. Indeed, the central idea is that students of all ages will be able to study as many stand-alone modules – potentially from a range of different institutions – as they feel they need to boost their skills; this will often fall far short, in credit terms, of a full degree.

The policy was first announced by Boris Johnson in 2020, after the Augar Review of post-18 education recommended a similar scheme the previous year. However, progress in implementing it was limited by the subsequent rapid turnover of prime ministers and the fiscal hole caused by Liz Truss’ disastrous “mini-budget” in 2022, leading to widespread doubts that the LLE would ever be implemented. Planned starting dates in September 2025 and January 2026 were pushed back again after Labour’s 2024 election victory to January 2027. But that date now appears to be set in stone – regardless of students’ and institutions’ readiness.

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That long implementation process should have given plenty of time for awareness and interest in the LLE to build among the mature and non-traditional learners at whom it is primarily aimed – and plenty of time for universities to rejig their teaching around the self-contained modules it is intended primarily to fund. Yet with less than nine months to go until its launch, and less than six months out from students being able to apply for LLE-eligible courses, large swathes of the higher education sector appear to be a long way from that position – if they are even trying to move towards it.

Polling released in February found that only 12 per cent of the general public was aware of the LLE. And while the sector, in theory, is supportive of shaking up a one-size-fits-all loan model aimed at three-year degrees pursued in early adulthood, the financial crisis that has left around half of English higher education institutions facing a financial deficit in the current academic year has made universities wary of investing significant amounts in adopting a new and largely untested teaching and business model.

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There appears to be a real risk that a landmark reform, designed to meet the clear and obvious national need for mass lifelong learning, will launch with something of a whimper.

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Christopher Furlong/Getty Images

In 2023, Universities UK chief executive Vivienne Stern to embrace the LLE, describing the policy as “more radical than I think many people realise – but the direction it sets is the right one”. That radicalism has since been rather watered down by Labour. The existing loan system will continue to run alongside the new one for a transition period, and most students are expected to continue studying three-year, full-time courses. In addition, stand-alone modules will only be eligible for LLE funding in specific subjects aligned with national skills needs and the industrial strategy, such as computing, engineering, physics, nursing and midwifery, economics and health and social care.

That restriction is only likely to further dampen universities’ enthusiasm, observers suggest.

“There are pockets of the sector that have absolutely no interest that I can [discern] in engaging with [the LLE], at least in its early [phase],” said Helena Vine, lead policy officer for England at the Quality Assurance Agency (QAA). However, there are also “pockets that are really quite keen”.

For those already in the business of offering flexible, stand-alone courses, engaging with the LLE is a no-brainer. Similarly, institutions that already take a more modular approach to degree provision are well placed to launch courses under the LLE with relatively limited disruption. Yet even for them, the “size” of existing modules – in terms of the number of credits they bestow – is an issue, according to Harriet Dunbar-Morris, visiting fellow at the University of Oxford’s department of continuing education. “Institutions that have got a whole wide range of different credit sizes are in a more difficult situation [than those with standardised modules],” she said.

Moreover, revamping and standardising existing modules is unlikely to be enough to appeal to non-traditional students or working adults without radical reforms to timetables too, commentators suggest.

“The traditional 9-to-5 in-person teaching model isn’t going to work for this sort of student demographic, so if you’re not already delivering online, evening and weekend study, it’s going to be really challenging for you to quickly start delivering those things,” said Kate Wicklow, director of policy and strategy at GuildHE, which represents small and specialist providers.

Nor is anyone likely to try to make such a rapid pivot, she suggests: “With the state of sector finances that we’re in at the moment, there isn’t a great deal of risk-taking.”

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The QAA’s Vine agreed. “It’s very well known that parts of the sector are struggling financially; it takes resource and money to shift things,” she said. “And if you don’t know if you’re going to be bringing in students…it becomes much, much harder to justify doing so.”

That is particularly so given that universities will still be expected to offer wraparound support to students enrolled on LLE programmes even though they will stay for relatively short periods. “I think it will be a brave provider that launches in September,” Vine said.

Interest in the LLE from high-tariff universities founded on a boarding-school model of student life is likely to be particularly muted. After all, for the most part, these institutions have no problem attracting traditional undergraduates, each of whom guarantees their university more than £28,000 of income over three years. Why spend the time and money developing new courses in the hope that they may attract students who stay for less time and bring in significantly less income?

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Jon Super/Alamy

Even for the institutions that are engaging deeply with the LLE – typically, specialist providers, those already focused on flexible learning and those with a strong widening participation mission – there remains a large question mark about student demand.

A pilot scheme launched back in 2021 saw only 17 of the planned 96 short courses go ahead owing to insufficient demand. And similar challenges were faced more recently by a government-run “modular acceleration pilot” – intended to “accelerate supply and support delivery of individual modules of higher technical qualifications” ahead of the LLE’s launch: seven of the 25 providers selected for the scheme failed to launch their planned modules because of a lack of interest from students. An about the initiative, published in February, said that about half of the senior sector leaders involved “expressed some dissatisfaction with the number of learners” recruited to the programmes.

But David Phoenix, vice-chancellor of the Open University, suggests his institution’s record demonstrates that there is genuine demand for studying in a “more flexible way” that does not lead to a full degree. The LLE, he said, is a case of “the system catching up with the modern age” and he hopes it will “drive an environment where, over time, universities move to a more modular-based way of thinking, so that they end up creating more flexible pathways”.

Some institutions are exploring cross-sector models, with students able to enrol on modules from a variety of different providers in the same region or members of the same mission group. And when Dunbar-Morris’ Spinnaker Group, which brings together colleagues who lead on student experience and teaching and learning from across UK institutions, sent out invites to a recent meeting, “a lot of people engaged and said they’d be interested to come and talk about this topic. People do want to consider it, even though they might be in a more traditional university.” Nevertheless, it is “quite late in the day” to prepare relevant courses for September application, she conceded.

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Louise Heusinkveld/Alamy (edited)

As well as uncertainty around student demand, there are also reputational risks for universities that commit most of their eggs in the LLE basket, particularly given the ongoing uncertainties about how their performance will be assessed.

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“The whole way the Office for Students currently works is to assume everyone’s a full-time undergraduate student who gets done in three years,” said Diane Houston, deputy vice-chancellor for education and student experience at Birkbeck, University of London, which is a specialist in “providing education to people who want to study part-time, to fit study around their work and their personal lives”.

The regulator’s current measures of institutional quality include student completion and continuation metrics, which, according to Birkbeck’s vice-chancellor, Sally Wheeler, are the reason that her institution received only a bronze rating in the most recent Teaching Excellence Framework. When the government published new guidelines last year on how the LLE would work, it said providers with a silver or gold TEF rating would go through a “simpler and quicker approval process” than those without.

Accordingly, the LLE pilot programmes have been restricted to silver- and gold-rated institutions, Houston said. “We are bronze because of our flexibility, effectively, and then we’ve had to make a special application [to take part in] a pilot and make a case on a subject-by-subject basis. They basically decided that the sector can engage with the LLE pilot based on the progress of its full-time 18-year-old students, which is mad.”

However, there may be some relief on the horizon in this regard. The OfS has confirmed that it will not use existing student outcome measures to rate modular offerings and won’t initially introduce a student outcome measure. It is “likely” to adopt the monitoring of a range of indicators, including growth in student numbers, withdrawal rates and the recruitment of students with no or very low entry qualifications, and it will begin to collect modular completion data from the 2027-28 academic year “to inform the development of student outcome measures”, which it will develop in tandem with the sector. For the most part, existing conditions of registration and minimum quality standards will continue to apply to providers and their modules.

An OfS spokesperson said that the body wants to ensure that its approach to modular regulation “supports institutions to deliver high-quality higher education, while continuing to safeguard public and student money. Over the coming months, we will be speaking directly with institutions who expect to offer LLE-fundable modules from January 2027.”

But the uncertainty about what regulation could look like in the future poses another risk for institutions. “You don’t know if you’re going to [find yourself] on the wrong side of the regulator a few years down the line,” said the QAA’s Vine.

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Andy Hallam/Alamy

More generally, the sense that the policy sands around the LLE are constantly shifting is contributing to a certain exasperation even among enthusiasts.

Given all the changes and postponements that have already occurred, “It’s been quite difficult to get to grips with what exactly is going to happen,” said Dunbar-Morris. “Staff on the ground…have been through quite a lot of different things over the last few years, so there’s an awful lot of fatigue in relation to having to make [further] changes.”

James Newby, chief executive of NMITE, says the whole “reason for being” of the engineering-focused institution that opened in Hereford in 2021 is “built around modular provision. We look at our courses as a structure of stackable skills [and] there are some people who would be able to engage with engineering if it’s taught in a modular way, through an LLE-type regime, that would otherwise not be able to engage with higher education. That has to be a good thing.”

However, he added, the delays in rolling out policy details and the continued lack of information remain a significant barrier for institutions. “I think provider confidence in a smooth delivery is pretty strained,” Newby said.

Policy detail is slowly dripping out. Last week, for instance, that in determining an individual’s LLE eligibility, previous degree-level study will be totted up according to today’s prices, regardless of what tuition fees were actually paid – leaving those who already have a three-year degree just a year’s extra funding, except for some priority courses. But Newby said institutions would benefit from “much greater clarity” on other issues too, such as tuition fees, course credit levels and credit transfer arrangements.

The OU is similarly waiting for some “quite important technical information”, according to Phoenix. In some cases, the guidance is changing “by the day”, making it difficult to give students accurate information.

Providers are also united in their view that the low public awareness must be urgently addressed. “There needs to be some kind of national communication marketing piece that makes these qualifications legitimate,” said GuildHE’s Wicklow. A national advertising campaign has been discussed by the Department for Education, but it’s unclear when or if this will happen, even as the clock ticks down towards the September opening of applications.

Any marketing campaign will have to push back against the chorus of voices claiming that the repayment conditions of student loans are unfair – and the government’s admission that despite the replacement of the high-interest Plan 2 loans several years ago, the existing student finance system remains “broken” and needs to be made fairer.

But many in the sector believe the LLE could provide an antidote to concerns about student debt. Wicklow said the LLE “de-risks” student borrowing “to a certain extent because if you aren’t sure about whether higher education is for you, doing one module…is lower risk because you’re only doing a small bit [of a full degree]”.

The LLE “might actually be the positive shift that we need on…the student loan stuff”, agreed Vine. And, more generally, she believes that it is “the right step to take. Trying to make everything much more flexible, trying to open up higher education – I think all the vision is there. It’s just…the kind of more boring, technical, nitty-gritty underpinning stuff…doesn’t feel like it’s there yet to underpin the vision.”

Hence, whatever the long-term success – or otherwise – of the LLE, it seems likely that its initial cohorts will be relatively small.

“This is a slow burn,” reflected Wicklow. “We’re not going to come to January 2027 and have hundreds of thousands of learners.”

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