16 to 19 study programmes with planned learning hours but no regulated qualifications
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
Timetabled hours for non-qualification activity should be recorded in the Planned employability, enrichment, and pastoral hours field. In most cases, young people should be enrolled in learning that leads to:
- an external certificate offered by a regulated awarding organisation and approved on the DfE list of qualifications approved for funding 14 to 19
- a substantial work placement to prepare them for progression to an apprenticeship or other employment
- a T Level
Funding streams reviewed
- 16 to 19 study programmes
What you need to do
If you are not delivering any qualification hours, you must report the Planned learning hours field as 0. Non-qualification learning aims should be recorded in the Planned employability, enrichment, and pastoral hours field.
For non-qualification activity to be eligible for funding, you must be able to evidence that you have incurred a cost in delivering the activity that is proportionate to the amount of funding being recorded for this activity, and be able to demonstrate that it improves either progression to further levels of study or entry into employment.
What we will do
We may contact you in-year to understand the reasons for this data error and ensure data is reported accurately. We may ask to review evidence of cost and need and how value can be demonstrated.
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 report lists 16 to 19 students who have planned learning hours recorded but no regulated qualification on their programme. Planned learning hours are the hours for qualification delivery. If nothing on the programme leads to a qualification, DfE's instruction is that the figure should be zero and the hours should sit in the employability, enrichment and pastoral field instead.
Based on FRM56 Summary; FRM56 What you need to do.
Working knowledge
Two things are being compared: the Planned learning hours figure, and whether the student has an aim leading to a regulated qualification. DfE states that if you are not delivering any qualification hours you must report Planned learning hours as 0, and that non-qualification learning aims belong in the Planned employability, enrichment and pastoral hours field. So a student appears here either because the hours are in the wrong field, or because the qualification aim that justifies them is missing from the record.
Based on FRM56 What you need to do.
Technical detail
DfE frames the expectation in the summary: in most cases young people should be enrolled in learning leading to an external certificate from a regulated awarding organisation approved on the DfE list of qualifications approved for funding 14 to 19, a substantial work placement preparing them for progression to an apprenticeship or other employment, or a T Level. It then sets a separate eligibility test for non-qualification activity: you must be able to evidence a cost incurred in delivering it that is proportionate to the funding recorded against it, and demonstrate that it improves either progression to further levels of study or entry into employment. DfE calls this report a data error in its own wording, which is unusual for the FRM set and worth reading as intended.
Based on FRM56 Summary; FRM56 What you need to do; FRM56 What we will do.
Why this report exists
Planned hours drive the funding band, and DfE separates qualification hours from non-qualification hours so that the shape of what is being funded is visible. A programme recorded as qualification hours with no qualification in it makes that shape unreadable.
Based on planned-hours-drive-the-band; FRM56 Summary.
What DfE is identifying
16 to 19 study programmes carrying planned learning hours where the record shows no regulated qualification aim.
Based on FRM56 Summary.
Does appearing here mean something is wrong?
Something in the record is inconsistent, and DfE describes it as a data error rather than a pattern to explain. The useful question is which side is wrong: the hours, or the missing aim. Either way the programme itself may be entirely sound and correctly delivered.
Based on FRM56 What we will do; data-error-is-not-always-a-funding-error.
Legitimate reasons for appearing
- The programme is genuinely non-qualification and the delivery is eligible, but the hours were recorded in the wrong field.
- The qualification aim exists in the source system and did not reach the return, so the hours are right and the record is incomplete.
- The aim is recorded against a learning aim reference that is not a regulated qualification, for example a non-regulated code chosen in error.
Based on FRM56 What you need to do; mis-generates-the-ilr.
Data or process problems that can cause it
- Planned learning hours used as a single total for the whole programme, with nothing split into the employability, enrichment and pastoral field.
- An enrolment created against the programme with the aims added later, and the record extracted before they were.
- A non-regulated aim reference selected where a regulated one was intended.
- A template carrying qualification hours applied to a cohort whose programme has no qualification in it.
Based on mis-generates-the-ilr; FRM56 What you need to do.
What to check first
- Look at the student's aims and confirm whether a regulated qualification aim genuinely exists in the source system.
- If it does not, check whether the hours recorded as planned learning hours are in fact non-qualification delivery.
Based on FRM56 Summary.
Working through it
- Take the student's planned learning hours and planned employability, enrichment and pastoral hours as recorded.
- List the aims on the programme and identify which, if any, lead to a regulated qualification approved for funding.
- If a qualification aim exists in the source system but not in the return, establish why it did not extract, because that affects more than this student.
- If no qualification is being delivered, establish what the hours actually cover, and whether that activity meets DfE's eligibility test on cost and progression.
- Decide whether the correction is to move hours between fields, to add a missing aim, or to correct an aim reference.
- Check whether the same pattern appears across a course or a cohort rather than one student.
Based on FRM56 What you need to do; mis-generates-the-ilr.
ILR fields involved
- Learner.PlanLearnHours
- Learner.PlanEEPHours
- LearningDelivery.LearnAimRef
- LearningDelivery.AimType
- LearningDelivery.FundModel
Based on PlanLearnHours_03; FRM56 What you need to do.
Related ILR validation rules
- PlanLearnHours_03
- PlanEEPHours_01
Based on PlanLearnHours_03; PlanEEPHours_01.
Related PDSAT reports
- Y-204
- Y-218
Based on Y-204; Y-218.
Returns this relates to
- R04
- R14
Based on r04-is-the-census-for-16-19; final-return-closes-the-year.
Funding implications
The hours decide the band, so moving them between fields does not by itself change what is earned, but establishing that non-qualification activity is eligible does. DfE states it may ask to review evidence of cost and need and how value can be demonstrated.
Based on planned-hours-drive-the-band; FRM56 What we will do.
Audit and assurance implications
For any non-qualification hours you keep, the test DfE names is specific: evidence of a cost incurred that is proportionate to the funding recorded, and a demonstration that the activity improves progression to further study or entry into employment. That is a costing question as much as a curriculum one, and it is much easier to answer from records kept at the time.
Based on FRM56 What you need to do; evidence-must-be-contemporaneous.
Evidence to look for
- The student's enrolment record in the source system, showing which aims were actually attached to the programme.
- The timetable showing what the hours cover and whether it is qualification or non-qualification activity.
- For non-qualification activity, the costing that shows what was spent on delivering it.
- The progression or employment outcome the activity is intended to improve, and how that is evidenced.
Based on FRM56 What you need to do; evidence-must-be-contemporaneous.
If the data is wrong
- Where no qualification hours are being delivered, report planned learning hours as 0, as DfE instructs, and record the non-qualification delivery in the planned employability, enrichment and pastoral hours field.
- Where a qualification aim is missing, add it in the source system rather than adjusting the hours to match its absence.
- Where the aim reference is wrong, correct it at source, regenerate the return and resubmit.
- Where a template produced the pattern, correct the template so the same cohort does not reappear next collection.
Based on FRM56 What you need to do; correct-the-source-not-the-return.
If the data is right
- Keep the costing and the progression evidence for the non-qualification activity, since that is what DfE says it may ask to review.
- Record why the programme has no regulated qualification, so the answer does not have to be reconstructed later.
Based on FRM56 What we will do; change-evidence-matters.
Stopping it recurring
- Split qualification and non-qualification hours at the point the programme is built, rather than recording one total and separating it afterwards.
- Check that aims have extracted before the hours are treated as final, since an incomplete extract looks identical to a programme with no qualification in it.
Based on mis-generates-the-ilr.
Questions an MIS manager should ask
- Do these students have a qualification aim in our source system that did not reach the return?
- Where the programme genuinely has no qualification, why are the hours recorded as learning hours rather than as employability, enrichment and pastoral?
- Is this one course or the way we build hours across a curriculum area?
Based on mis-generates-the-ilr.
Questions a finance director should ask
- For the non-qualification activity we are funding here, can we produce the cost we incurred and show it is proportionate?
- What would we show if DfE asked how this activity improves progression or entry into employment?
Based on FRM56 What you need to do.
What a good answer sounds like
- A good answer says which side of the record was wrong, names the correction, and for retained non-qualification hours produces the costing and the progression case without having to build them first.
- A weak answer is that the activity is valuable, with no cost record and no stated progression outcome behind it.
Based on FRM56 What we will do.
Related Academy learning
- planned-hours-explained
- sixteen-nineteen-mechanics
- curriculum-data-consequences
Based on planned-hours-drive-the-band.
Funding streams this report reviews
FRM56 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.