Corporate report

Independent Assessors’ Annual Report 2024-25

Updated 19 September 2025

Applies to England and Wales

1. Introduction

The Independent Assessors (IAs) are appointed by the UK and Welsh Governments to consider appeals and complaints by customers who are not satisfied with the responses they have received from the Student Loans Company Limited (SLC).  This is our annual report for the financial year 2024-25 and covers cases on which we have reported in the twelve months to 31 March 2025.  It sets out the background to our work and the role we play, describes our caseload during the year and draws out some themes from it.  The report then refers to the role of Ombudsmen in considering SLC cases and concludes with some recommendations.

2. Background

At the end of last year there were nine IAs. One IA did not seek re-appointment during the course of the year and six new IAs were appointed commencing their roles in January 2025. Thus, there are currently fourteen IAs. Our appointments are statutory and are made under section 23(6) of the Teaching and Higher Education Act 1998.  Student finance customers are able to escalate to an IA if they remain dissatisfied after a single stage appeal or complaint process within the SLC.  Customers with mortgage-style loans, which have now been transferred to the private sector, have to seek redress through the debt owner to the Financial Ombudsman Service (FOS).

Responsibility for the SLC and for our appointments lies with the Department for Education (DfE) within the UK Government and the Department for Education, Culture Social Justice and Welsh Language within the Welsh Government (DECSJWL). Our recommendations are binding on the SLC unless it is otherwise directed by or on behalf of the Secretary of State for Education or the Cabinet Secretary of Education Welsh Ministers for Wales.

Each report is the responsibility of an individual IA, but we operate a system of peer review to provide comments on emerging findings and encourage a broad consistency of approach.  If the relevant Departmental official disagrees with our recommendations to the SLC, they advise Ministers accordingly.  In England, the Director General for Skills Group (who has delegated authority) makes the decision whether to accept a recommendation from an IA.  Complex cases are passed up for Ministerial approval.   As far as Welsh cases are concerned the Higher Education Division will decide whether those recommendations should be implemented, with complex cases being passed to the Minister for Further and Higher Education (MFHE).

We routinely explain the provisional status of our recommendations in our reports.  During 2024-25 recommendations by IAs were rejected in this way by the DfE on 6 occasions.  No Welsh recommendations were rejected. 

In our reports we may make recommendations to address the specific circumstances of the case and may highlight more general issues arising from our analysis.  We meet regularly with departmental staff at the SLC, DfE and DECSJWL to review the complaints and appeals caseload and how our reports have been managed.  We are briefed on relevant administrative developments, policy proposals and legislative updates. Our remit does not extend to the policy behind the regulations.  In deciding appeals, we are bound to accept the provisions of the regulations as they stand.  However, our reports may sometimes lead to reconsideration of the wording of the regulations or accompanying guidance, if for example, a particular case highlights some ambiguity.

As in previous years we have continued to receive excellent support throughout the year from the SLC’s IA Liaison Office Manager, her team and SLC colleagues.  We wish to express our thanks for their input and help. 

3. Caseload

SLC has separate channels for handling appeals and complaints involving different teams of staff although these teams are being increasingly integrated. An appeal is a formal request for a review of a decision in relation to entitlement to and/or eligibility for student finance or regarding the level of funding awarded. It will usually involve a contention that the student support regulations have not been applied correctly.  A complaint is any expression of dissatisfaction with the service the SLC has provided.  On occasion we review matters that consist of both an appeal and complaint relating to the same matter.

The time taken for appeals and complaints to be escalated to IAs and considered by us has varied over time with the number of IAs in post and the SLC’s capacity to collate cases for us.  As this is an area of concern for us we will address this in more detail below.

4. Appeals

During the year we reviewed 156 appeals.  A comparison with the preceding four years may be seen in the table below in relation to Student Finance England (SFE) and Student Finance Wales (SFW):

Year SLC Decision Upheld SLC Decision Upheld Appeal upheld Appeal upheld Total
  SFE SFW SFE SFW  
2024-25 140 3 13 0 156
2023-24 101 5 16 0 122
2022-23 72 4 8 0 84
2021-22 55   5   60
2020-21 58   2   60
2019-20 86   19   105

*It is worth noting three of the SFE appeals were reviewed as part of a complaint case.

The table below sets out the broad categories of appeal with comparable figures for previous years:

Subject matter 2020-21 2020-21 2021-22 2021-22 2022-23 2022-23 2023-24 2023-24 2024-25 2024-25
  SFE SFW SFE SFW SFE SFW SFE SFW SFE SFW
Unfitted (Fraud) 6   9   13   16 1 53  
Previous study/ ELQ 7   11   11 1 21 1 7  
Residency 26   28   29 1 48 1 48 2
Overpayment/Repayment 4   1   4 1 3   2  
Funding entitlement 4   3   4 1 13   9  
Migrant Worker 4   2   4   2   8  
Postgraduate loan 1   2   1   8 2 10  
Other 8   4   14   7   16 1
Total 60   60   80 4 118 5 153 3

In considering an appeal IAs will sometimes also address service issues which have arisen in the handling of a case.  During 2024-25 recommendations of an ex-gratia payment were made in 18 cases, (15 SFE and 3 SFW). The total amount recommended for payment in these cases was £4025 (SFE - £3975 and SFW £50).

5. Complaints

This year we reported on 193 complaints. The table below shows the comparative numbers of complaints reported on each year:

Year SFE SFW Total
2024-25 179 14 193
2023-24 177 12 189
2022-23 171 14 185
2021-22 148   148
2020-21 124   124
2019-20 142   142

Many complaints contain a range of issues.  A report in such cases will therefore review a number of issues and may contain findings adverse to the SLC on only some of them. For this reason, it is difficult to describe complaints as being upheld, either in full or in part.  The table below shows the complaints by categories used by the SLC when the complaint is first registered:

Subject matter 2020-21 2020-21 2021-22 2021-22 2022-23 2022-23 2023-24 2023-24 2024-25 2024-25
  SFE SFW SFE SFW SFE SFW SFE SFW SFE SFW
Processing 35   83   78 7 89 7 86 9
Systems*                 16  
Grant overpayment 2   3   1   0   1  
Advice given 29   20   33 4 33 2 28 3
ICR 20   16   23 1 23 1 28 1
Other 38   26   36 2 32 2 20 1
Total 124   148   171 14 177 12 179 14

*New category

It is worth noting that 7 of the complaints (5 SFE and 2 SFW) were reviewed as part of an appeal case.

In 2024-25 recommendations were made in 128 cases (SFE 123 and SFW 5) for the offer of an ex-gratia payment. The total amount recommended for payment in these cases was £22850 (SFE £22250 and SFW £600).

As IAs we are conscious that we see an unrepresentative sample of some of the most difficult cases. Many millions of customers will have received a satisfactory service from the SLC. This obviously limits our ability to draw any general conclusions about customer experience.  Having said that we acknowledge that even within the range of cases which we see there are often encouraging examples which in general show the SLC are committed to continually delivering for their customers and to improve the customer’s journey. Given that this is at the heart of the SLC’s vision and strategic goals it should be the case that the SLC treat its customers fairly and impartially and interact with customers with professionalism.

We are satisfied that the SLC are moving in the right direction, and the dedication of many staff to help remains unquestioned.  However, our review of cases has identified some issues which we would like to highlight:

Delays in escalation to an IA

In response to our comments in our 2021-22 Annual Report the SLC told us they were keen to reduce the wait time for escalation of cases to an IA. They anticipated the consolidation of their appeal and complaint functions in 2021-22 would reduce wait times.

We noted in our 2022-23 Annual Report that the benefits of the organisational review and any other approaches to reducing case escalation had not yet been realised. We said we would wish to see the SLC reduce the waiting time to no longer than eight weeks from request for escalation to the case reaching an IA. As each IA completes their report within four weeks of receipt of instruction this would result in the overall waiting time for both appeals and complaints to no more than three months.

In our 2023-24 Annual Report we noted that there did not appear to have been any improvement in the average wait times for escalation to an IA. We included a table to demonstrate how waiting times had increased since March 2021 and we have updated that table below to include the wait times this year:

Year Appeals Complaints
As at 31/3/2025 6 months 6 months
As at 31/3/2024 3 months 4 months
As at 31/3/2023 2 months 4 months
As at 31/3/2022 4 months 3 months
As at 31/3/2021 6 weeks 3 months

As at the end of March 2023 there were 17 appeals and 45 complaints awaiting allocation to an IA. At the end of March 2024, the figures were 40 appeals and 47 complaints awaiting allocation to an IA. One year later at the end of March 2025 there were 79 appeals and 96 complaints awaiting escalation to an IA. Thus, this year there has again been an increase in both the backlog of cases awaiting allocation and, in the time taken to compile a case before sending it to an IA for review. 

We bear in mind that there has been an increase in the number of both appeals and complaints this year (2023-24 122 appeals and 189 complaints compared with 2024-25 156 appeals and 192 complaints), However, it can be seen there has been a deterioration in the wait time for escalation to an IA for both appeals and complaints. It is disappointing that despite the SLC’s efforts the wait time has in fact increased again this year. It is important that the SLC continues to explore opportunities to reduce the time taken to escalate a case.  We stressed last year and we re-iterate this year that not escalating appeals or complaints in accordance with process and within target timescales impacts the customer’s experience and results in disappointment and dissatisfaction. The SLC tell us they are in the process of recruiting an additional member of staff to the IA Liaison Office and we very much hope that will positively impact the wait times and backlog of cases awaiting allocation in the near future. We see the current delays in referring cases to an IA to be a service failure and will continue to recommend ex-gratia awards in the worst cases of delay.

In our 2023-24 Annual Report we noted an inconsistency in how long customers are told the matter will take to reach an IA, some are told up to two months and others up to approximately six months. The same inconsistencies have persisted this year. Whatever length of time a customer is told the estimate should be realistic and consistent. If a customer is told escalation to an IA will take up to three months and that transpires not to be achievable we would like to see updates being provided to customers to keep them informed and manage their expectations.

The change of approach by the complaints team to non-complaints

When a customer emails the complaints team the team evaluate the email to determine whether, in their view, the customer has raised a complaint. We have become aware of a change of practice by the complaints team to emails they consider do not raise a complaint. The practice used to be that any email not considered to be a complaint would be forwarded to the general correspondence team to respond to with the customer being advised accordingly. We are aware that the complaints team no longer adopt that approach. Instead, if they determine that the customer has not raised a complaint, they simply respond to the customer’s email with a standard email containing links to webpages “where you can find additional help and support”. In our view this is an unsatisfactory approach by the complaints team which leaves the customer’s enquiry unanswered. We would like to see the former practice re-instated and we will make a recommendation to that effect. 

Appeals involving large scale fraud investigations

As can be seen from the figures above there has been a significant increase in appeals this year. Many of these appeals are as a result of investigations by the Economic Crime Unit (formerly known as the Financial Crime Prevention Unit and prior to that the Customer Compliance Unit) into suspicious Childcare Grant claims. We recognise the inherent difficulties in any fraud investigation whether conducted by the SLC or any other body.

We feel we should emphasise that in reaching any decision on such appeals, we will as with any other appeal, weigh all the evidence presented to us to assess its credibility, relevance, and probative value. Evidence which is corroborated naturally will carry more weight than unsubstantiated allegations, or bald assertions as to potential criminality or involvement therein.

6. Parliamentary and Health Service Ombudsman (PHSO), Public Services Ombudsman for Wales (PSOW), Scottish Public Services Ombudsman (SPSO) and Northern Ireland Public Services Ombudsman (NIPSO)

PHSO, PSOW, SPSO and NIPSO provide an opportunity for customers who are dissatisfied with the outcome of the SLC’s internal appeals or complaints process to seek a review via the Ombudsman scheme.  The PHSO require that the referral is made via the customer’s Member of Parliament.  It is worth noting, contrary to some customers’ expectations, that the FOS does not have jurisdiction in relation to the SLC’s caseload, save with respect to a narrow area of complaints relating to matters arising between 01/4/2007 and 30/3/2015 in relation to mortgage-style loans.

At the start of the financial year there were 26 PHSO cases that remained open. Of these, 3 progressed to investigation, 22 were closed without investigation and the outcome is awaited in 1 case. Of the 3 that progressed to investigation, 1 was upheld in full, 1 was upheld in part and 1 complaint is still being considered.

During the year the PHSO requested information from the SLC in 19 cases, of which 11 were closed without investigation, 4 are being investigated, and the SLC awaits the outcome of the remaining 4.

The PSOW requested information from the SLC in 6 cases in 2024-25, of which 5 were closed without further investigation and SLC awaits the outcome of the remaining 1. 

The SPSO has requested information from the SLC in 2 cases during the year, both were closed without investigation. 

7. Recommendations

Based on our experience this year, our recommendations are as follows:

  • We recommend that the SLC address the issue of delay in escalation to an IA and every effort is made to achieve and maintain a waiting time of no more than eight weeks from request for escalation to the case reaching an IA.

  • We recommend the SLC re-consider the current approach of the complaints team in responding to customers who they do not consider are raising a complaint. We recommend the complaints team revert to their former practice where any email they do not consider to be a complaint is forwarded to the general correspondence team for response with the customer being notified accordingly.

Abdul Elghedafi                 Luke Bennett          Hannah Bows          Susan Bradford

Helen Flynn                      Michaela Jones       Naseem Malik         Mandy Nepal

Mel Palmer                       Joanne Smith          Victoria Smith          Georgia Taylor

Jonathan Willis                  Peter Wrench

Independent Assessors

April 2025

8. SLC response to IA annual report recommendations

1. Background and context

SLC’s Framework Document requires SLC to establish and maintain processes for handling customer complaints and appeals (as summarised in the Complaints and Appeals report, presented by Stephen Baker):  Following consideration by Board the IAs’ Annual Report, and the response, will be published on Gov.UK.

Complaints and Appeals

1.1 SLC shall ensure it has in place appropriate processes to manage complaints about its services. SLC shall also ensure it has an appeal process to review decisions of SLC in relation to entitlement and/or eligibility to student finance based on its interpretation of relevant law, regulations and policy. This includes the process for referral to an external Independent Assessor (IA) whose task is to review complaints and appeals. External Independent Assessors shall be appointed by, and will report annually to, the Responsible Minister and the Welsh Ministers on behalf of all the Departments.

1.2 The resulting processes for handling complaints and appeals and the detailed Terms of Reference for external Independent Assessors should be made publicly available on gov.uk. SLC is responsible for ensuring effective liaison with Independent Assessors, and that recommendations made by them are followed unless otherwise directed by the Departments.

1.3 The IAs Annual Report will be made publicly available on gov.uk, alongside SLC’s response.

1.4 The IAs are appointed by the Secretary of State to deal with Higher and Further Education Student Finance complaints and appeals. There are currently thirteen IAs, however please note at the time the IA report was written, fourteen IAs were in place.

1.5 As part of their role, in May each year, the IAs submit an Annual Report, in respect of their activity in the previous financial year, to SLC and Ministers. Recommendations made within the IAs’ Annual Report relate not only to SLC but also, potentially, to DfE and the Devolved Administrations (DAs).  The IAs’ Annual Report for FY2024-25 is attached as Appendix 1. SLC have considered the recommendations made in the report and our response to each recommendation can be found at point 3 of this paper.

1.6 Over the course of the year, the IAs may make recommendations on individual cases. In FY2024-25, the IAs reviewed a total of 349 cases, an increase of 12.2% compared to the previous year where 311 cases were reviewed. The below table illustrates the volume of recommendations this year in comparison to last year.

FY 2023-24 FY 2024-25
Number of cases reviewed 311 349
Number of recommendations 278 246

1.7 Of the 246 recommendations made in FY2024-25, 232 have been fully implemented; 8 recommendations, made in 3 cases, are being considered by DfE, 1 is in the process of being implemented; and 5 are still under consideration.           

1.8 The IAs may make recommendations for an Ex-Gratia payment to be offered to the customer. In FY2024-25, despite the increase in cases reports, the total recommended reduced to £26,875 (from £29,642)

1.9 In some cases, the recommendations in individual cases may have a wider impact on SLC’s ways of working. Implementation of these recommendations is aligned to our Customer Experience Service Owner model. During FY2024-25 the IAs made 25 such recommendations, of which 14 have been implemented, 1 is being tracked to ensure the proposed solution is implemented and 10 remain open.

2 Executive Summary

Case numbers

2.1 In FY2024-25, the IAs reviewed 349 cases, comprising 193 complaints and 156 appeals. This represents a small proportion of the total 8,801 formal complaints and 2,522 appeals handled by SLC, equating to 2.19% of complaints and 6.18% of appeals being escalated to an IA. The rise in appeal referrals is largely due to more focused activity by the Economic Crime Unit (ECU), on areas where public money is at greatest risk, which led to a higher volume of appeals, as set out in the Complaints and Appeals Annual Report.

2.2 Should a customer remain dissatisfied with the outcome of their independent review; they can choose to escalate their complaint to the relevant Ombudsman. The table below demonstrates the small volume of complaints that were raised to the Ombudsman in FY 2024-25.

Open cases as at 1 April 2024 Cases referred in year No further investigations Progressed to further investigation Still being considered as at 31 March 2025
PHSO 26 19 33 7 5
PSOW 0 6 5 0 1
NIPSO 0 0 0 0 0
SPSO 0 2 2 0 0
TOTAL 26 27 40 7 6

Outcome of those referred for further investigation

Completed and not upheld Completed and complaint partially upheld Upheld in full Await outcome
0 1 1 5
0 0 0 0
0 0 0 0
0 0 0 0
0 1 1 5

Board will note the particularly strong performance from our appeals function for the fourth year in a row, wherein SLC’s position was upheld in 143 (91%) of the 156 appeals cases that went to an IA for review. The two most common drivers for appeal cases being escalated to the IA are Residency and Fraud. Residency remains a key area of focus for DfE and Welsh Government to simplify via our policy work and Protecting Public Money will continue to be a strategic priority for SLC.

Time action for case collation

2.3 The IAs’ Annual Report, once again, notes that over the year FY2024-25 there was an increase in the backlog of cases awaiting an IA review and, in the time taken to compile a case to send it to an IA for review. The compilation is carried out by the relevant team i.e. the Complaints team for complaints cases and the Appeals team for appeals cases.

2.4 In our response to the IAs comments in their FY2023-24 report, we confirmed our intention to continue to explore opportunities to reduce the time for escalation within existing budget constraints. A proposal for additional resource was submitted as part of the FY2023-24 budgeting exercise but ultimately this was not funded due to budget prioritisation. A further proposal was submitted, and approved, at the start of FY2025-26 resulting in the recruitment of two additional Independent Assessor Liaison Officers to assist with the escalation of cases to an IA. This increase effectively doubles the size of the team, and we are confident the benefits of this will be realised and anticipate a reduction in wait times over the next 6 months. Progress towards this will be continually monitored and reported on a regular basis to the board via our Corporate Performance Dashboard.

Appeals involving ECU investigations

2.5 The IAs’ Annual Report highlights the challenges involved in potential fraud investigations. SLC recognises the complexity of these cases and the need to safeguard public funds while also considering student circumstances. In FY2024–25, the IAs reviewed 53 ECU-related cases, upholding SLC’s position in 51, demonstrating our commitment to making fair and robust decisions.

3. IA Annual Report recommendations and SLC’s response

3.1 As noted, the IAs’ annual report sets out the background to the work of the IA, their caseload and any recommendations for SLC. In FY2024-25 the IA have made 2 recommendations:

1) We recommend that the SLC address the issue of delay in escalation to an IA and every effort is made to achieve and maintain a waiting time of no more than eight weeks from request for escalation to the case reaching an IA.

SLC response:

  • A) SLC remain committed to reducing the wait times for escalation to an IA. As noted in para 2.4, we have recently increased the capacity of the Independent Assessor Liaison Office and are already seeing the positive impact of this. Time to escalate has reduced by 2 months for both complaints and appeals following the implementation of additional resource.
  • B) In light of the positive impact of the additional resource and subject to the capacity to maintain or increase current capacity (assuming we can drive a greater number of cases to them), we are optimistic about achieving the recommended escalation timeframe of eight weeks.

2) We recommend the SLC re-consider the current approach of the complaints team in responding to customers who SLC do not consider are raising a complaint. We recommend the complaints team revert to their former practice where any email they do not consider to be a complaint is forwarded to the general correspondence team for response with the customer being notified accordingly.

SLC response:

  • A) SLC note that over the past 2 years, the complaints team have identified 7,000 to 7,500 complaints each year. In terms of non-complaint correspondence being received into the Complaints inbox, historically there have been 17,000 to 24,000.
  • B) Given SLC have historically struggled to meet SLAs in responding to both complaints and formal appeals, an action plan was agreed internally (and shared with the Board) on how we might address this through better triage - distinguishing quickly between complaints and general correspondence (non-complaints).  This involved introducing more automation (including in responding to those non-complaints) and has had a material impact on improving complaint and appeal processing timescales and bringing us back comfortably within SLA.
  • C) This change has been introduced over the last year, with, as noted above, response times meeting SLA across the board for the first time in many years. By way of comparison: in January 2024 formal appeals could be taking 57 days to be addressed; in January 2025, it was 10. For Repayments complaints, in January 2024, it was 44 days; in Jan 2025 it was 11.
  • D) Our administration team have been triaging correspondence not deemed a complaint and sending standardised links to further information. We are aware of a very small number of cases where that triage process has failed, which has led to staff training being identified. In considering the IA’s recommendation, we have considered reverting to the previous system however, we believe triage is still the right approach and are committed to learning from any shortcomings to ensure that triage is being done properly.
  • E) To address the IA’s concerns, we will, however be introducing a webform for the submission of complaints and formal appeals, which should help, as we can be clearer at this early stage – prior to actual submission – where customers should go for other queries, and it will be clearer to our triage team whether the correspondence is actually a complaint, an appeal or i.e. more of a request for help/further information. Maintaining the triage process is important as not having to address the 20,000 or so pieces of correspondence a year (that are not complaints) is critical to us continuing to meet the improved timescales and SLAs that have been reached over the last year.