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.
