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Loads of our learners don't have a PLR. Either too old, or studied overseas, or attended a private school. We just ask for a self-declaration, which auditors have always been fine with (obviously as long as it isn't contradicted by something higher in the PLR). There's just not a chance we'd ever get them all to provide evidence of what they declared (we have to for HE students, but that's another story).
I will say, it's really tricky to get this right still. We ask them to tick something like the below, but also free type/write the highest qual. It's astounding how often they will do things like tick level 2, then write that they have A Levels. We then translate that as best we can to Prior Attainment. If we're ever fully funding on the basis of First Full Levels, we get an extra signed statement to confirm, though working out whether the L3 qual they already have is considered full, is a whole other problem!

Eleanor Piper
Prior Attainment on ILR (not RPLE assessment)
Created
If a learner does not have a PLR record (or that record contains very little information), and they don't have certificates, should we be coding them as 98- Not Known on the ILR, or would it be better to ask the learner for a declaration of their prior learning?
This is the case with a couple of our older learners whose certificates have gone AWOL over the years.
If they say "I got 7 GCSEs and 2 A Levels" is that enough to code them as Full Level 3 or would we need to have seen some proof?
We have a good system in place to assess their competence and any overlap of prior learning against KSBs for that side of things so this is really just for the ILR.