Loans learning not being recorded in ILR
A funding monitoring report identifies records and patterns that DfE wants providers to investigate and be able to explain. Appearing on one does not by itself mean a record is wrong. Many flagged records are correct and simply need their evidence produced; others turn out to need a correction.
Where this comes from
Every word below is DfE’s own, read from the published guidance on 19 September 2026. Nothing in this section was written by FEFunding.
Summary
You must accurately complete all ILR fields for loans-funded learners and make ILR returns as required in the ILR specification and the provider support manual.
Funding streams reviewed
- advanced learner loans
What you need to do
If the learner has passed the initial liability point for provision funded through an approved loan, you must record the learning aim as follows:
- record Funding model code 99 (Non-funded (includes indirect DfE funding))
- record the advanced learner loans indicator (Learning delivery FAM Type ADL, code 1)
- do not record a source of funding
If a learner leaves before the initial liability point or never attends, you must confirm this to SLC using the learning provider portal. You must not claim any funding from SLC.
What we will do
Where your data does not support the funding that you have received from SLC or claimed from the loan’s bursary, we will take action to get this corrected. We will also use this data to support our performance management processes.
Changes from previous funding year
None
What this means in practice
This section is FEFunding’s explanation, not DfE’s wording. It was drafted with AI assistance against the official guidance above. Its approval is pending confirmation, so it is not yet shown as reviewed by a person. Where it differs from the Department’s own words, the Department’s words are the authority.
In plain English
This is about learners funded by an Advanced Learner Loan. Even though the loan pays for the course rather than DfE, the learning still has to appear in your ILR, recorded in a particular way. This report picks up loans learning that is missing or recorded wrongly.
Based on FRM20 Summary.
Working knowledge
Loans-funded learning must be returned in the ILR with the fields completed as the ILR specification and provider support manual require. DfE sets out the specific coding: Funding model code 99, non-funded, together with the Advanced Learner Loans indicator recorded as Learning delivery FAM type ADL, code 1, and no source of funding recorded.
Based on FRM20 Summary; FRM20 What you need to do.
Technical detail
The reconciliation is between the loans-funded learning DfE expects to see and what appears in the ILR. DfE distinguishes two cases by the initial liability point: where the learner has passed it, the aim is recorded as above; where the learner leaves before it or never attends, DfE requires confirmation to the Student Loans Company through the learning provider portal and states you must not claim any funding from SLC.
Based on FRM20 What you need to do.
Why this report exists
Loans funding flows through the Student Loans Company rather than through the ILR, but the ILR is still how DfE sees what was delivered. Without the ILR record there is nothing to reconcile the loan against.
Based on FRM20 Summary.
What DfE is identifying
Loans-funded learning that is absent from the ILR, or present but not recorded with the coding DfE specifies.
Based on FRM20 Summary.
Does appearing here mean something is wrong?
It usually means a recording problem rather than a funding one, but it is worth taking seriously because the consequence sits with the learner as well as the provider. A loan the learner is liable for, against learning DfE cannot see, is a difficult position for everybody.
Based on exception-is-not-error.
Legitimate reasons for appearing
- The learner left before the initial liability point or never attended, in which case DfE's instruction is to confirm this to SLC rather than to record funded delivery.
- The aim is recorded but the Advanced Learner Loans indicator has not been set, so the learning is present and simply not identifiable as loans funded.
Based on FRM20 What you need to do.
Data or process problems that can cause it
- The aim was recorded with a source of funding, which DfE states should not be present for loans learning.
- The Learning delivery FAM type ADL was not applied, so the aim does not read as loans funded.
- The learner withdrew before the initial liability point and the position was never confirmed to SLC through the provider portal.
Based on FRM20 What you need to do.
What to check first
- Establish whether the learner passed the initial liability point, because DfE's instruction differs either side of it.
- Check the three things DfE specifies on the aim: funding model 99, the ADL indicator, and no source of funding.
Based on FRM20 What you need to do.
Working through it
- Identify the loans-funded learners the report is asking about.
- For each, establish whether they attended and whether they passed the initial liability point.
- Where they did, check the aim exists in the ILR and carries the coding DfE specifies.
- Where they did not, check whether the position was confirmed to SLC through the learning provider portal.
- Reconcile what SLC has paid, or what has been claimed from the loans bursary, against what the ILR shows.
- Where the two disagree, establish which is right before changing either.
Based on FRM20 What you need to do; FRM20 What we will do.
ILR fields involved
- LearningDelivery.FundModel
- LearningDeliveryFAM.LearnDelFAMType
- LearningDeliveryFAM.LearnDelFAMCode
- LearningDelivery.LearnAimRef
Based on FRM20 What you need to do; fams-carry-eligibility-and-monitoring.
Related ILR validation rules
- FundModel_03
- LearnDelFAMType_91
- LearnDelFAMType_36
Based on FundModel_03; LearnDelFAMType_91; LearnDelFAMType_36.
Related PDSAT reports
- A-104
- A-406
Based on A-104; A-406.
Funding implications
DfE states that where your data does not support the funding received from SLC or claimed from the loans bursary, it will take action to get this corrected. DfE also states it will use this data to support its performance management processes.
Based on FRM20 What we will do.
Audit and assurance implications
The reconciliation between SLC payments and ILR records is the thing to be able to show. Where a learner left before the initial liability point, the evidence that this was confirmed to SLC is what closes the question.
Based on FRM20 What we will do; evidence-must-be-contemporaneous.
Evidence to look for
- The loan agreement and what it covers.
- Attendance records establishing whether the learner attended and when they stopped.
- The confirmation sent to SLC through the learning provider portal, where the learner left before the initial liability point.
- The reconciliation between SLC payments received and the aims recorded in the ILR.
Based on FRM20 What you need to do.
If the data is wrong
- Record the aim with Funding model code 99, the Advanced Learner Loans indicator as Learning delivery FAM type ADL code 1, and no source of funding, as DfE specifies.
- Where the learner left before the initial liability point or never attended, confirm this to SLC through the learning provider portal and do not claim funding from SLC.
- Correct it in the source system and regenerate the ILR.
Based on FRM20 What you need to do; correct-the-source-not-the-return.
If the data is right
- Keep the reconciliation between SLC and the ILR where it can be produced on request.
- Record the initial liability point decision for each learner, since it is what determines which of DfE's two routes applies.
Based on change-evidence-matters.
Stopping it recurring
- Reconcile loans-funded enrolments against SLC records on a routine cycle rather than at year end.
- Make the ADL indicator and the absence of a source of funding part of how loans aims are set up, rather than something checked afterwards.
Based on mis-generates-the-ilr.
Questions an MIS manager should ask
- How do we identify loans-funded aims in our own system, and does that match how they are coded in the ILR?
- Who confirms to SLC when a learner leaves before the initial liability point, and how do we know it was done?
- When did we last reconcile SLC payments against ILR records?
Based on FRM20 What you need to do.
Questions a finance director should ask
- Are we holding any loans income that our ILR does not support, and what is our exposure if DfE asks?
- Who owns the reconciliation between SLC and the ILR, and how often does it happen?
Based on FRM20 What we will do.
What a good answer sounds like
- A good answer shows the reconciliation, names the learners either side of the initial liability point, and can produce the SLC confirmations.
- A weak answer is that loans learners are handled separately, without being able to show the two sets of records agreeing.
Based on evidence-must-be-contemporaneous.
Related Academy learning
- reconciling-funding
- data-quality-routine
- evidence-principles
Based on fams-carry-eligibility-and-monitoring.
Funding streams this report reviews
DfE also names advanced learner loans. The Academy has no section for that stream yet, so it is listed here as published rather than mapped onto something only approximately similar.
FRM20 in other funding years
Working through it in your own system
- Read the official wording for this report and note exactly which records it identifies.
- Find those records in your own data using the fields the report names.
- For each one, decide whether the record is correct and simply needs its evidence produced, or genuinely wrong.
- Trace a wrong record back to the entry in your source system that produced it, rather than to the file it appeared in.
- Correct it at that entry, regenerate and resubmit.
- Keep the evidence and the reason for the change together, so the record is explainable at audit.
The Academy has no verified supplier guidance for this report yet. Menu locations differ between product versions and between colleges on the same version, so we do not publish navigation we have not confirmed. The steps above are what has to be true in the data, which is the same in every system.
If the record does turn out to be wrong. Correct the record in the system where the data is entered, then regenerate the ILR file and resubmit it. Editing the generated file directly removes the symptom and leaves the cause in place, so the same record returns at the next submission with nobody expecting it. Keep a note of what was changed and why: that note is what makes the correction explainable later.