Corporate report

Independent Assessors’ Annual Report 2024-25

Published 18 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