DfE franchise guidance explains registration and student finance rules

Updated Sep 07, 2026

DfE updated its franchise guidance on 19 May 2026 when the undergraduate student support amendments came into force. The guidance was first published on 20 March. A later update on 25 June reflects amendments covering postgraduate master’s and doctoral loans. Publication history.

The threshold and its scope

In England, from 2028–29, delivery providers with 300 or more franchised students need OfS registration, unless exempt, for continued public finance eligibility for new students. The headcount covers students across partnerships on courses designated for student finance, including international and self-funded students.

The guidance covers level 4 and above, including postgraduate courses, while excluding apprenticeships and modules or credits alone. It protects course designation for students who started before implementation; individual eligibility remains subject to the relevant student finance rules. DfE guidance.

Read the transition separately from the headline rule

The December 2025 response schedules the first designation decision for September 2027, using 2025–26 data, for the 2028–29 implementation year.

Its early-application protection allows qualifying applications still awaiting an OfS decision to retain designation temporarily. The response’s 1 July 2026 cut-off concerns that protection: it is not an absolute prohibition on a later applicant securing designation if registration succeeds before the decision point. The response’s scenarios explicitly include that outcome. Consultation response, implementation section and Annex D.

Provider teams should check the current guidance, exemptions and their registration position when assessing their arrangements. This article does not determine an individual provider’s eligibility.

Where student comments fit

The rule concerns registration and course designation. It does not itself prescribe a new system for analysing student feedback or require all feedback channels to be merged.

Our practical suggestion is to define a separate purpose for reviewing partner survey comments. Retain delivery partner, question and collection-period context where appropriate, and avoid comparisons that conceal different populations or survey methods.

Keep complaints and formal case records within their agreed processes. Theme summaries from a survey can inform questions for further review; they cannot demonstrate regulatory compliance or prevent funding problems.

The governance checklist can support planning that bounded comment review alongside the institution’s formal partnership oversight.

Review note, 7 September 2026: added the June postgraduate update and designated-course headcount condition, corrected the blanket reading of the application cut-off, and separated student finance rules from suggested survey analysis.