Student Loans Company (SLC)

4. Mrs A complains about the Student Loans Company (SLC). She complains about its decision to class her transfer between universities as a ‘withdrawal’, rather than a ‘study transfer’.

5. The result of this categorisation is that she lost her eligibility for a maintenance loan, as she has now passed the age threshold. Had her move been classed as a transfer, rather than a withdrawal, she would have retained the maintenance loan.

6. She also complains about SLC’s communication. She says it provided her with contradictory explanations regarding the classification and its culpability. This went on between 2024 and 2025.

7. The whole experience has caused her to feel overwhelmed, confused, anguish, and constant distress. This has caused her blood pressure to increase, loss of appetite, headaches, insomnia, depression, and she has even had suicidal thoughts.

8. As an outcome of her complaint, she would like SLC to explain how she has ended up in this situation, change the status of her move to a ‘study transfer’, and compensation for her experience.

Complaint background

9. For anonymisation purposes, we will refer to the two universities involved as University A and University B.

10. Mrs A was enrolled on a course at University A. However, following staff reports about her behaviour, it suspended her for 18 months on 4 March 2024. While this suspension meant she could not study at University A for this period, it was made clear she would eventually be able to continue her studies at the university from October 2025.

11. On the same day that University A shared the decision, a psychiatrist published a report diagnosing Mrs A with Autistic Spectrum Disorder (ASD). The report said the behaviour leading to her suspension was linked to this condition.

12. Mrs A had the option to request a review and appeal the decision. Instead, she raised a complaint with the Office of the Independent Adjudicator (OIA), an independent body that considers complaints about Higher Education providers.

13. In April 2024, Mrs A complained to the OIA about University A’s failure to take her ASD diagnosis into account when determining her suspension. The OIA upheld her case and asked University A to award her with £10,000 as a settlement.

14. The following month, Mrs A informed the OIA that she did not wish to continue studying at University A, as her relationship with the university had irreparably broken down. She said she intended to withdraw from her course and wanted to study elsewhere. The OIA relayed her position to University A on the same day. University A confirmed this in an email to Mrs A on 26 June 2024, stating her last day of attendance had been 6 February 2024.

15. Mrs A subsequently applied to study at University B as a new student. She also applied to the SLC for a new maintenance loan. However, SLC refused it stating she had surpassed the age threshold for eligibility. According to section 157B of the Education (Student Support) Regulations 2011 (the regulations), the legislation that outlines how SLC should grant maintenance loans, students over the age of 60 are not eligible for maintenance loans. Sadly, she had passed this threshold that same year.

16. Mrs A appealed SLC’s decision in December, questioning why she could not be classified as either a new or continuing student. On 10 January 2025, SLC formally responded, explaining that she could not be classified as a new student because she was over 60 when she applied for the loan. Additionally, she could not be classified as a continuing student, as her eligibility had been terminated when she withdrew from her course at University A, in accordance with section 140 of the regulations.

17. Mrs A escalated her complaint to the OIA. Subsequently, SLC investigated the matter and contacted both University A and B on 16 April to clarify whether Mrs A had transferred or withdrawn from her previous course and whether University B classed her as a new student.

18. University B stated Mrs A had enrolled as a new student.

19. University A acknowledged Mrs A’s request to transfer but explained that it recorded ‘withdrawals’ and ‘transfers’ identically on its system. Despite this, it recommended to SLC that Mrs A be classified as a transfer.

20. SLC acknowledged University A’s intent but highlighted a formal transfer had not occurred. Under the regulations, University A’s classification of her departure as a withdrawal took precedence over its intent for her to be considered as a transfer.

21. On 4 August 2025, the OIA shared its decision on Mrs A’s complaint. It recognised differing views on whether she had withdrawn or transferred, but stated University A had classified her as a withdrawal. The OIA explained SLC lacked the authority to treat her as a transfer and had to process her application based on her withdrawal status.

22. The OIA advised Mrs A that University B would need to confirm her status as a transfer and submit a ‘Change of circumstances’ (CoC) form to amend her status. This prompted Mrs A to initiate enquiries with University A, University B, and the SLC.

23. Subsequently, extensive communication occurred between Mrs A and these parties between August and October, leading to some confusion.

24. During this period, Mrs A dealt with three separate teams at SLC. On 8 August, an SLC staff member informed her University B should submit a CoC form to confirm her transfer status. Then, on 28 August, University B explained she could not change her transfer status because University A had classified her departure as a withdrawal. Despite this, SLC repeated its previous advice on 1 September.

25. We have reviewed SLC’s internal correspondence records, which show it was exploring what advice was correct. It is evident Mrs A’s situation was unusual. On 4 September, SLC acknowledged it had caused confusion with its communication. Despite this, it repeated the incorrect advice again on 2 October before resolving the matter and providing accurate advice on 7 October, issuing an apology for the earlier inconsistent messages.

Administrative background

26. The SLC is a public body that is responsible for providing eligible members of the public with public funding for studying. It is governed by the Education (Student Support) Regulations 2011, which defines strict rules for the release of public funds. SLC has no discretion in determining whether an applicant qualifies for any element of support, as decisions are strictly bound by the regulations.

27. Section 157 of the regulations state that applicants for part-time student loans must be under the age of 60 on the first day of the academic year of their course.

28. Section 139 and 140 explain that eligibility as a part-time student is terminated if they withdraw from a designated course. However, eligibility is retained when transferring between courses, providing the student makes such a request, meets the grounds for a transfer (e.g. enrolling somewhere else), and their period of eligibility remains active.

29. According to SLC’ internal processing guidance, universities are required to classify a student’s departure as a transfer in their system and confirm the student’s eligibility for the move.

SLC’s decision to class Mrs A’s transfer between universities as a ‘withdrawal’, rather than a ‘study transfer’

32. Our view is that SLC acted in line with the regulations when it treated Mrs A as having withdrawn, rather than transferred, from University A. We therefore cannot say SLC’s decision was unreasonable. We explain our reasons below.

33. The issue appears to lie with Mrs A’s withdrawal from University A and its classification of her departure as a ‘withdrawal’ on its system (which we can see proof of on SLC’s portal records). Informally, via an email to SLC on 6 May 2025, it supported the idea of Mrs A studying somewhere, and being classed as a ‘study transfer’, but it did not record this on the SLC’s portal system.

34. The key issue is that University A recorded Mrs A’s departure as a withdrawal on SLC’s portal records. Although University A later supported the idea of Mrs A studying elsewhere and being treated as a study transfer, it did not record her departure as a transfer on SLC’s system.

35. Mrs A wants SLC to change her status from withdrawal to study transfer so she can receive a maintenance loan. However, SLC is required to follow the regulations. Section 139A of the regulations sets out the conditions that must be met for a student to be treated as a transfer. Mrs A did not meet those conditions because University A had recorded her as withdrawn, which ended her eligibility for the maintenance loan SLC had previously granted.

36. Because Mrs A had passed the age threshold for a new maintenance loan in 2024, the only apparent route to further maintenance support was for her existing entitlement to continue through a valid transfer.

37. SLC’s approach was consistent with our principle of good administration, ‘Getting it right’. Under this principle, we expect public bodies to comply with the law and act within their statutory powers and duties. They should have regard to relevant legislation, take account of relevant considerations and ignore irrelevant ones. In this case, SLC applied the regulations to Mrs A’s entitlement to a maintenance loan. We have not seen evidence that it had discretion to treat her as a transfer when University A had recorded her as withdrawn.

38. We empathise with Mrs A’s situation. She was clear that she wanted to study elsewhere and University A appears to have supported that intention. However, the evidence we have seen shows University A did not facilitate a valid transfer on SLC’s system. If Mrs A wishes to pursue that issue, she may want to consider raising it with University A. This is not something we can help her with.

SLC provided Mrs A with contradictory explanations regarding her transfer between universities

39. On 8 August, 20 August, 1 September, and 2 October, we can see evidence from the email records that SLC did miscommunicate to Mrs A that it was possible for her to change her status from ‘withdrawn’ to ‘study transfer’.

40. On 8 August, SLC said:

‘Dear [Mrs A]

Thank you for your email. I’m sorry that the process has been a difficult time for you.

We’ll need a Change of Circumstance (COC) from [University B], which they will send to us electronically.

The COC will need to confirm you have transferred. Once received, your account will be reviewed by our Processing team, and they’ll contact you directly.

Kind regards’

41. On 20 August, it said:

‘…it appears that [University B] are currently communicating with the most appropriate department within SLC to resolve an issue they are encountering in sending over the CoC. [University B] have advised you that they will not be able to resolve the issue today and ask that you allow them time to investigate and follow up on this. I would therefore advise you await further correspondence form [University B’s] as they have promised.’

42. On 2 October, it said:

‘We’re unable to award you a Maintenance Loan from the 2024/25 academic year onwards because you’re over 60 and classed as a new student.

The email we sent you on 1 September doesn’t confirm your award, but it explains that you could get a Maintenance Loan from the 2024/25 academic year. This is only if [University B} send us confirmation that you transferred in, rather than enrolled as a new student. They haven’t done this, so we can’t make any changes’

43. This communication was wrong, because there was no option for Mrs A’s eligibility to be reviewed simply upon receipt of a CoC form from University B. University A had ended her eligibility when it recorded her departure as a withdrawal. SLC’s communication fell short of our ‘principles of good administration’, particularly our principle for ‘Being customer focused’, which says public bodies should make sure service users are clear about their entitlements, and they should communicate effectively and clearly in a way that is appropriate for the service user and their circumstances.

44. Our principle also says public bodies should treat people with sensitivity, bearing in mind their individual needs, and respond flexibly to the circumstances of the case. Where appropriate they should deal with customers in a co-ordinated way with other providers to ensure their needs are met, and, if they are unable to help, refer them to any other sources of help.

45. We recognise that Mrs A’s situation was complex and unusual. SLC’s internal correspondence suggests staff were unfamiliar with this scenario and were working through the regulations to understand the correct process and advice. SLC also worked with University B to better understand Mrs A’s situation and provide accurate advice

46. SLC apologised to Mrs A for its poor communication on 7 October, and we considered whether this was a suitable remedy.

47. Mrs A told us SLC’s communication caused her significant emotional distress, including feelings of confusion, frustration, and being overwhelmed. She said this psychological impact contributed to physical symptoms such as loss of appetite, headaches, insomnia, depression, high blood pressure, and suicidal thoughts. We recognise that Mrs A experienced significant hardship. However, the evidence does not allow us to conclude that SLC’s incorrect communication caused all of the impact she has described, particularly given the wider circumstances, including the decision not to award her a maintenance loan.

48. It took SLC two months to recognise and correct its miscommunication. However, during that period, we can see University B did provide her with the correct advice on 28 August:

‘Please see the email below from the SLC Account Manager for [University B]. It explains that SLC provided you incorrect information on the action required by [University B] and that there is nothing that [University B] can do to change the maintenance loan eligibility.

At present, we have been told that we are not able to do anything that would make Student Finance consider you as a transferred student from [University A] to [University B] because you have left the programme at [University A] and started a new programme at [University B] and that, under Student Finance rules, you are therefore considered a new student for the study at [University B].’

49. SLC and OIA’s incorrect advice is likely to have added to Mrs A’s confusion and frustration while she tried to establish what her actual entitlement was. However, SLC’s internal correspondence shows it was actively considering her case and engaging with the universities to determine whether it could treat her as a transfer.

50. SLC recognised on 29 August that it had communicated poorly. It tried to coordinate its communication to avoid further inconsistent messages and encouraged staff to work together. Between 29 August and 4 September, there was internal discussion about how the regulations applied to Mrs A’s case and whether she could be treated as a transfer. On 5 September, an SLC staff member emailed the team to say they had personally contacted Mrs A to explain her funding entitlement and that she would only be able to apply for tuition fees.

51. However, once it had provided this correct message, an SLC customer services staff member repeated the wrong advice to Mrs A on 2 October.

52. We cannot say that, had SLC never miscommunicated, Mrs A would have received the correct advice from SLC sooner. At best, she may have had to wait until 5 September.

53. It is difficult to separate how much of Mrs A’s distress was caused by SLC’s delay in providing correct advice, how much was caused by the decision not to treat her as a transfer, and how much was caused by the incorrect advice itself. On 4 August, Mrs A emailed SLC and explained that she was already distressed by the decision and was experiencing severe anxiety and depression. However, the email records show she became increasingly frustrated, and SLC’s poor communication is likely to have added to that frustration.

54. Mrs A seeks compensation to put right the impact of SLC’s communication. If we refer to our description of a ‘level 1’ injustice on our guidance on financial remedy, this says the following:

‘These will usually be injustices such as annoyance, frustration, worry or inconvenience, typically arising from a single (one-off) incidence of maladministration or service failure, where the effect on the individual is of short duration, and where there are no other adverse effects or ongoing wider impact. Assuming that there are no issues of vulnerability, that the person affected is an adult of reasonable physical and mental health, and there are no external factors to exacerbate the injustice, we would expect them to recover from the injustice very quickly once the direct impact of the poor service comes to an end. We would generally consider an apology to be an appropriate remedy for level 1 injustice.’

55. We do not consider there is enough evidence to say SLC’s incorrect communication caused an injustice greater than level 1. There were several other factors contributing to Mrs A’s significant distress at the time, including the loss of maintenance support and the wider circumstances around her move between universities. We therefore consider SLC’s apology for providing incorrect information to be a suitable remedy.

56. We are reassured by our communication with SLC that it recognises the part it played in the miscommunication.

57. As such, we will not look at this matter further, as we consider SLC has put right the injustice.

1. We are sorry to hear about the difficulties Mrs A has faced since withdrawing from her university course. We recognise that losing access to a maintenance loan has caused her considerable distress and has had a significant impact on her wellbeing.

2. Having reviewed Mrs A’s case, we have decided not to consider the complaint further. We have not seen evidence that the Student Loans Company (SLC) was responsible for the decision that ended her eligibility for a maintenance loan. That decision followed University A recording her departure as a withdrawal. While SLC gave Mrs A inconsistent and confusing advice, it has acknowledged this and apologised. We consider that an apology is a suitable remedy for the injustice caused by SLC’s poor communication.

3. We appreciate why this complaint is important to Mrs A and we will explain our decision in more detail below. We hope our explanation provides her with reassurance about how carefully we have considered her complaint before reaching our decision.