Which nation funded your student loan decides far more than which threshold applies to you. It decides how your maintenance support is structured, whether a postgraduate loan repays separately from your undergraduate one or gets folded into it, and even whether a doctoral loan exists for you at all. This guide compares all four systems side by side, including several genuine structural differences that most single-nation guides don't cover because they only need to explain one system at a time.
To model your own repayment under whichever plan applies to you, our student loan calculator covers all four nations directly.
Undergraduate Support, Nation by Nation
| England | Wales | Scotland | N. Ireland | |
|---|---|---|---|---|
| Repayment plan | Plan 5 | Plan 2 | Plan 4 | Plan 1 |
| Threshold | £25,000 | £29,385 | £33,795 | £26,900 |
| Interest rate | 4.1% | Up to 6% | 4.1% | 4.1% |
| Write-off | 40 years | 30 years | 30 years | 25 years |
| Tuition fee cap | £9,790 | £9,790 | £1,820* | £4,985* |
| Maintenance, away from home | up to £10,830 | up to £12,590† | up to £10,400 | up to £8,352 |
*Scottish and Northern Irish students studying in their home nation pay a lower fee than students from elsewhere in the UK. †Wales figure is total support including a grant portion, not all of which becomes debt, covered below.
Notice that Wales technically applies Plan 2, the same repayment plan used in England before Plan 5 replaced it, rather than having its own numbered plan. Wales chose not to adopt England's Plan 5 reforms, so Welsh students starting a course today are repaying under the older system that English students moved away from in 2023.
Three Genuine Structural Quirks
These aren't just different numbers slotted into the same template. Each nation makes a genuinely different design choice.
Wales splits support into a grant and a loan, and only the loan is debt. Every Welsh student in the same living circumstances receives the same total support regardless of household income, but lower-income households receive more of that total as a non-repayable grant rather than a loan. A student receiving the maximum grant portion graduates with meaningfully less debt than the headline maintenance figure suggests, for identical support received.
Scotland has no living-arrangement bands at all. England, Wales and Northern Ireland all vary maintenance by whether you live at home, away outside London, or away in London. Scotland doesn't ask the question. Support depends only on whether you're a dependent or independent student, with a separate non-repayable bursary of up to £2,000 layered on top for lower-income households.
Northern Ireland's maintenance grant actively reduces the loan rather than adding to it. In England and Wales, a grant (where one exists) sits alongside the loan. In Northern Ireland, receiving the maintenance grant, worth up to £3,569, reduces how much maintenance loan you're entitled to borrow. The two aren't cumulative, which catches people out if they assume NI works the way support in England does.
Your plan follows the funding body, not the campus. A Welsh student studying at an English university is still funded by Student Finance Wales and repays under Welsh terms. Where you study affects your tuition fee. Where you were living when you applied determines everything else.
Postgraduate Funding Compared
Postgraduate support diverges even more sharply than undergraduate support, and this is where most comparisons stop short.
| England | Wales | Scotland | N. Ireland | |
|---|---|---|---|---|
| Master's loan | up to £13,206 | up to £19,635 | up to £13,900* | up to £10,000† |
| Doctoral loan | up to £31,122 | up to £29,705 | None | None |
| Covers living costs? | Yes, single sum | Yes, single sum | Yes, split loan | No, fees only |
*Scotland splits this into a £7,000 tuition fee loan and a £6,900 living cost loan, paid separately. †Northern Ireland's loan covers tuition fees only, with no living cost element, and rose 54% from £6,500 in a 2026/27 reform.
Two things stand out. Wales is meaningfully more generous than England for a taught Master's, worth checking if you're weighing where to study. And neither Scotland nor Northern Ireland currently fund doctoral study through a loan scheme at all: both offer support for a taught Master's or Postgraduate Diploma only, so a Scottish or Northern Irish student pursuing a PhD needs to look elsewhere for funding, typically a research council studentship, rather than a government loan.
Why Repayment Stacking Matters Most
This is the difference with the biggest practical effect on anyone's actual repayments, and it's rarely covered anywhere. If you have both an undergraduate and a postgraduate loan, whether they repay as one deduction or two depends entirely on which nation funded you.
England and Wales keep them separate. You make two deductions from the same salary: 9% above your undergraduate threshold, plus 6% above the separate £21,000 postgraduate threshold, at the same time.
Scotland combines them into one. SAAS-funded undergraduate and postgraduate loans merge into a single Plan 4 repayment, one 9% deduction above the £33,795 threshold, covering both debts at once.
Northern Ireland also combines them, but differently. A Northern Irish postgraduate loan is added to the balance of any Plan 1 undergraduate loan and repaid together under Plan 1 terms, one 9% deduction above the £26,900 threshold.
Same total debt, same salary, and the Scottish combination repays at roughly a third of the English stacked figure in year one alone, because it's assessed once against a single, higher threshold rather than twice against two separate ones. Neither approach is more "correct." They're different design choices with genuinely different consequences for anyone holding both types of loan at once.