WEEKEND READING: The LLE has its legal framework. Now it needs a readiness test

This blog was kindly authored by Adam Child, Registrar, University of Warwick, and Chair, ARC Quality Practitioners Group and Dr Helena Lim, PFHEA, Academic Lead, evasys and Educational Excellence Lead, Queen Mary University of London.

In most UK universities, a student who successfully finishes a module and leaves a programme is considered a non-completer. Current approaches see this as a negative outcome, without considering the possibility that they had left because they had succeeded rather than failed. Our systems were never built to recognise partial study as successful study. From January 2027, thousands of Lifelong Learning Entitlement (LLE) learners will walk through our doors. Unless something changes, they will leave as ghosts in our data.

In May, the government published the draft Lifelong Learning (Fee Limits) Regulations 2026, the first of three statutory instruments that make the LLE a legal reality. Writing in HEPI in April, Professor Harriet Dunbar-Morris made the case that the LLE is a pedagogical challenge as much as a funding reform. She is right. But underneath the pedagogy sits an infrastructure layer the sector has barely begun to discuss: the quality assurance and student feedback systems that will determine whether any of it works in practice. Neither was built for a learner who is with an institution for a single module. This risks undermining the success of new forms of provision, disincentivising both students and providers from active participation in this emerging opportunity.

The data problem hiding in plain sight

The regulatory picture is incomplete. The OfS confirmed in March that B3 outcomes measures will not be in place for 2027. Neither the National Student Survey nor Graduate Outcomes was designed for a learner with an uncertain end date who may never complete a named award. The flexibility and pace of the LLE makes these things almost impossible to predict.

This challenge already exists with continuing professional development provision. A learner who completes a CPD module successfully is routinely logged as a non-completer, where they had enrolled for a full award. LLE learners will inherit exactly this problem unless it is resolved before January 2027. The result is not just a data anomaly; it is an equity issue. A learner investing part of their lifetime entitlement in a single module deserves to be counted, heard, and responded to. Right now, most institutions have no reliable mechanism to do any of those three things.

The quality assurance gap

The same visibility problem exists at an institutional level. Quality assurance tends to be framed as an annual cycle, with programmes or departments as the primary units of analysis. Many institutions have built tools to track module-level performance – pass rates, mark profiles, student feedback – but these tend to feed into wider programme conversations rather than standing on their own. The LLE shifts the importance of this analysis significantly. For a student taking a single module as a standalone investment, that module is the entire experience. It deserves its own quality conversation, not a footnote in someone else’s annual review. Most of these learners will be mature students or those fitting study around work and life commitments, people for whom getting this wrong is not a minor inconvenience but a significant personal and financial setback.

What the regulator needs to address

The Office for Students (OfS) has yet to establish a comprehensive regulatory approach for standalone LLE modules. That gap is not simply a technical inconvenience. It means the first cohort of LLE learners will have studied and been assessed with no adequate mechanism in place to know what has happened and whether it meets the sector’s overarching expectations for quality.

The OfS’s work with the sector on modular data is in progress, but progress takes time the LLE does not now have. January 2027 is not a soft deadline. The OfS should set out, before that date, how it will regulate the quality of modular provision – including what data providers must collect on learner experience, how student feedback will be gathered on a timeline that works for a single module and how quality monitoring will operate for cohorts that do not persist beyond one term.

The policy ask

The OfS faces a genuine challenge here. No single metric will capture what success looks like for a modular learner. Credits accumulated, modules completed, learners who remain active over time, salary outcomes for those returning to work – each of these tell part of the story. The risk is that, under pressure to produce something measurable before 2027, the sector settles for a proxy that fits the old model rather than one designed for the new. There is also the danger that institutions are discouraged from offering flexible provision when ambiguity remains over how it will be regulated. The OfS would find providers as willing partners in addressing these gaps at an early stage, to establish appropriate benchmarks and proportionate regulatory approaches.

Providers can assist by demonstrating to the OfS that they have workable mechanisms for monitoring and improving modular provision, and by making that a normal part of how they talk about quality, not a special case. That would reassure prospective LLE learners that someone is paying attention to their experience and give the regulator a baseline from which to build. The legal framework is now in place. The quality infrastructure needs to follow before the first learner arrives, not after – as an important step in building the credibility of what could be a genuinely transformative form of provision.