Casework note: Complaints relating to student transfer
Each year we review a small number of complaints from students who have transferred to a new course, campus or provider before completing their studies.
Sometimes the student has chosen to make this change. They may have changed their mind about the field of study they wish to pursue, or a change in personal circumstances can prompt them to change the location or duration of their study.
But sometimes the transfer will be prompted by an action of the provider delivering the course or the provider that awards the qualification. For example, a provider may have decided to reduce the module options available on a particular course, or supervision capacity within a particular field may be reduced when a member of staff departs or a specific project ends. Students may consider that these changes mean the course no longer meets their needs.
Providers may also make operational decisions to close a course or campus or decide to bring to an end arrangements between providers working together to deliver learning opportunities. Where there is a planned teach-out period, it may be the case that only students who have not followed the conventional progression through their studies may need to consider a transfer to another course or provider. However, if there is a sudden course, campus or provider closure, the number of students seeking transfer options may be high.
Arrangements that allow students to complete their course at a different provider may not work for all students. Providers may need to act flexibly to consider alternative remedies where the student is unable to, or does not wish to, transfer. Providers may also need to consider additional remedies or support to mitigate any disadvantage to the student as a result of the transfer. Our separate briefing note considers course, campus and provider closure in more detail.
Students raise a variety of issues in their complaints to us about transfer and there are sometimes elements that we are not able to look at under the Rules of our Scheme. Decisions about whether a student can transfer credits between similar courses often involve a degree of academic judgment, and while we can consider whether the provider properly applied its procedures for considering these requests, we cannot interfere with the academic judgment itself. A student whose application to transfer to a new provider was rejected would also be unable to bring a complaint to us about that decision because under our Rules we cannot review a complaint about an application for admission.
Some students’ complaints are focused on their dissatisfaction with the original course of study, or dissatisfaction that a transfer has become necessary. Others are concerned with their experience on the new course not being as expected. In cases like this we may refer to guidance published by the Competition and Markets Authority (CMA) on how consumer protection law applies to the higher education sector to help us form a view on whether the provider’s final decision was reasonable. As set out within the CMA’s guidance, providers need to make material information available to applicants that will enable them to make an informed decision about which course to study, including information about the total course costs. Students are entitled to rely on information made available to them by the provider at the time they applied for and accepted a place on a course about what their experience will include. Students considering transfer also need to be given material information that will allow them to make a properly informed decision about whether to transfer their studies.
It is likely that students considering transfer options will have to reach a decision promptly. In our experience, providers usually set deadlines for in-year course transfers. It is not normally possible for students to transfer courses during the academic year after the deadline has passed due to concerns about the amount of content the student may have missed. This is normally a reasonable approach, but it is good practice for providers to make sure the deadline is clearly communicated. In circumstances where a bespoke transfer option has been created for a specific cohort of students, it is important to explain clearly how long this option is available for and what the default position will be after this date.
Students should also be signposted to wellbeing support because making a decision of this significance within a short timeframe is often a cause of stress.
It is good practice for providers to make sure the student is aware of any potential implications of deciding to change course or withdraw from the provider to continue their studies elsewhere, for example in relation to their tuition fee liability or any bursaries they may have received. Students who need a visa to study in the UK or whose studies are being sponsored may find it more difficult to transfer between courses or providers. It is good practice to signpost students to any sources of further support or advice relevant to their circumstances.
In circumstances where a course closes as short notice, it is good practice to prioritise any ongoing fitness to practice or disciplinary processes, because these may inhibit students’ ability to transfer if left unresolved.
Recognition of Prior Learning (RPL)
Many providers’ academic regulations include provisions which allow students to be awarded credit or exemption from completing components of the course in recognition of their previous studies or relevant professional experience. Providers may use different terms to describe these policies, for example Accreditation of Prior Learning (APL), Recognition of Prior Certified Learning (RPCL) or Accreditation of Prior Experiential Learning (APEL). But for the purpose of this note we use the term Recognition of Prior Learning (RPL) to collectively describe these different policies. It is good practice for providers to make sure that the language they use to describe these policies is clear and properly explained to students.
Although in some circumstances providers may consider it proactively, students normally need to individually request RPL and provide supporting information about their prior studies or experience. Decisions about whether the student’s previous studies or experience have enough in common with the course curriculum to be awarded credit or exemption normally involve academic judgment. The student’s new provider will normally be responsible for making the decision, but the student’s original provider can help facilitate this by promptly providing any information that may be needed, for example transcripts, information about the course or references. Providers may cap the number of credits a student can transfer or be granted exemption from.
It is good practice for students’ requests for RPL to be considered in a timely way. It can be very distressing for students to find out that their request hasn’t been successful or that they can’t transfer as many credits as expected after they’ve already changed courses or providers, especially where this may extend the overall duration of their studies.
While many students find RPL to be a positive way to manage their studies or “top-up” an award, there can sometimes be unintended consequences. For example, exemption from completing particular modules may disrupt the student’s balance between the academic and practical components of their course or impact module pathways at a later stage, and students may need to complete a minimum number of credits at the provider to be awarded a classified degree. It is good practice to make sure students have all the information they need to make a properly informed decision about applying for RPL and providers should clearly draw students’ attention to the relevant academic regulations and highlight any important or surprising terms.
Courses leading to entry to a regulated profession may have more stringent rules about RPL and about the minimum time a student must complete with the provider that will certify them as fit to enter that profession. Where providers are considering closure of such courses, the impact of a transfer is likely to be greater on students who are furthest along in their studies.
We do not uphold the majority of complaints made to us about student transfer. But even where we’ve ultimately decided the provider’s final decision was reasonable or that it had already taken reasonable steps to put things right for the student, the complaints we receive still tell us a lot about the realities of transfer for students and the dissatisfaction they feel when things have not gone smoothly or as they’d expected.

Student transfer
Learning from our casework on complaints relating to student transfer