Consultation outcome

Analysis: Regulating level 1 and 2 qualifications designed to lead to employment

Updated 22 May 2023

Background

The Department for Education (DfE) is conducting a review of post-16 qualifications at level 2 and below (L2B). The aim of the review, as set out in DfE’s consultation response, is to:

…ensure that all qualifications available within the new landscape are high quality and have a clear purpose, giving students the knowledge and skills to achieve positive outcomes, whether they are progressing to further study, on to an apprenticeship, traineeship or supported internship, or into employment”.

In the future, L2B qualifications approved for funding by DfE will need to meet any additional regulatory requirements introduced by Ofqual and, in the case of technical qualifications (which will only exist at level 2 and above), will also need to be approved by the Institute for Apprenticeships and Technical Education (IfATE). Ofqual will provide feedback on technical qualifications to IfATE, and DfE will base funding decisions on those qualifications that IfATE has approved.

Ofqual’s proposed approach to regulating level 1 and 2 qualifications designed to lead to employment is intended to work in conjunction with DfE’s new funding approvals process. It builds on the arrangements put in place for reformed level 3 qualifications.

For level 2 technical qualifications, Ofqual consulted on introducing a limited number of additional regulatory requirements which took account of the respective roles of IfATE and Ofqual in the approvals process for these qualifications. They were:

  • to require awarding organisations to develop, follow, and keep under review an assessment strategy
  • to require awarding organisations, following a review by Ofqual, to comply with any requirements, and to have regard to any guidance, specified by Ofqual in relation to the qualification
  • to require awarding organisations to inform Ofqual when approval for public funding is withdrawn, to allow Ofqual to decide when the conditions, requirements and guidance for these qualifications will cease to apply, and to require awarding organisations to comply with any additional requirements Ofqual specifies for qualifications for which approval for public funding has been withdrawn

For level 1 qualifications that are prerequisites to employment, Ofqual proposed not to introduce any additional requirements and to regulate them through the General Conditions of Recognition (GCR) only.

The consultation set out both the proposed regulatory approach and the draft conditions and requirements which would be used to implement the approach.

This was done to give awarding organisations as much time as possible to develop qualifications to meet the DfE’s intended first teach date of September 2025 for the first wave of qualifications in the new landscape. It was also intended to enable schools, colleges and other training providers to familiarise themselves with any changes to qualifications in advance of teaching the first reformed qualifications.

Summary

Level 2 qualifications designed to lead to skilled employment

There was broad support, from both awarding organisations and other respondents, for Ofqual’s proposals related to assessment strategies and Ofqual review of qualifications. There was broad support for the wording of the draft conditions and requirements through which these proposals would be implemented.

There was less support for the proposal to require awarding organisations to inform Ofqual when approval for funding was withdrawn from their qualifications. Awarding organisations thought that this would place an unnecessary burden on them, and questioned why Ofqual could not receive the information directly from DfE. Where respondents were asked to comment on the draft condition covering this requirement, they mostly commented on the proposed policy approach and not on the wording of the condition.

Level 1 qualifications that are prerequisites to employment

Respondents were strongly supportive of the proposal to regulate level 1 qualifications which are prerequisites to employment through the GCR only, without any additional controls.

Approach to analysis

The consultation included 15 questions (including questions on the equality and regulatory impact of the proposals) and was published on Ofqual’s website. Respondents could complete the questions using our online consultation platform.

Respondents to this consultation were self-selecting, so the sample of those that chose to reply cannot be considered as representative of any group. Efforts were made to engage as many interested parties as possible by holding stakeholder events, using social media, posting information on the Ofqual website and via the Ofqual newsletter.

Responses to the consultation questions are presented in the order they were asked. The consultation was divided into 3 parts:

  • Part 1 covered policy proposals to introduce new regulatory requirements for level 2 qualifications designed to lead to skilled employment
  • Part 2 covered the policy proposal to continue to regulate level 1 qualifications which are prerequisites to employment through Ofqual’s General Conditions of Recognition and not to introduce additional controls
  • Part 3 covered the draft conditions and requirements through which the proposed regulatory approach to level 2 qualifications designed to lead to skilled employment would be implemented

For all of the questions in Part 1, Ofqual presented background contextual information followed by proposals. The questions asked respondents to indicate their level of agreement with the proposals and to provide additional comment if they wished. For Parts 2 and 3, Ofqual presented background contextual information followed by proposals, where respondents could provide additional comment if they wished. Respondents did not have to answer all the questions.

Who responded?

Ofqual’s consultation on regulating level 1 and 2 qualifications designed to lead to employment was open between 10 January and 20 March 2023.

Ofqual received 21 written responses to its consultation. One response, from a representative body, was in the form of a letter sent to our public enquiry mailbox. The rest were received via our Citizenspace consultation platform. All responses have been considered as part of this analysis. Not all respondents chose to answer all of the questions.

Nineteen responses were official responses from the following organisations:

  • 13 responses from awarding organisations
  • 4 responses from other representative or interest groups
  • 1 response from an educational consultancy
  • 1 response from a trade association

Ofqual also received 2 personal responses:

  • 1 response from an awarding organisation
  • 1 response from a representative body

All of the respondents were based in England.

Detailed analysis

Part 1 – Ofqual’s proposed regulatory approach for level 2 qualifications designed to lead to skilled employment

Question 1

To what extent do you agree or disagree with the proposal to require awarding organisations to develop, follow and keep under review an assessment strategy?

Choice Respondents
Strongly agree 5
Agree 10
Neither agree nor disagree 3
Disagree 2
Strongly disagree 0

There were 20 responses to this question. Fifteen respondents either strongly agreed or agreed with our proposal to require awarding organisations to develop, follow and keep under review an assessment strategy for these qualifications. Two respondents disagreed and 3 neither agreed nor disagreed. No respondents strongly disagreed with this proposal.

Awarding organisations generally agreed with this proposal. One noted that this is now the common approach for many types of regulated qualification.

Seven responses, all from awarding organisations, referred to the increased burden this requirement could place on awarding organisations. Of those awarding organisations who referred to burden, 3 agreed with the proposal, one disagreed and 3 neither agreed nor disagreed.

Two awarding organisations said that, although they agreed with the proposal, they would like further clarity on how the process of reviewing assessment strategies would work and on the timescales for reviews. A representative body also said that it had concerns regarding the timescales for review.

A trade association respondent said that, although it strongly agreed with the proposed approach, it did not think that awarding organisations should be required to provide sample assessments if the assessment strategy is sufficiently detailed, as this might encourage providers to teach to the sample assessment rather than to the qualification specification.

Both of the personal respondents to this question agreed with the proposal. One referred to the need to ensure the continued reliability and validity of assessments, and the other referred to assessment strategies being rendered out of date where qualifications are not reviewed by awarding organisations in a timely enough manner.

Question 2

To what extent do you agree or disagree with the proposal to require an awarding organisation, following a review by Ofqual, to comply with any requirements, and have regard to any guidance, specified to it by Ofqual in relation to the qualification?

Choice Respondents
Strongly agree 4
Agree 12
Neither agree nor disagree 3
Disagree 1
Strongly disagree 0

There were 20 responses to this question. Sixteen either strongly agreed or agreed with the proposal to require an awarding organisation, following a review by Ofqual, to comply with any requirements, and have regard to any guidance, specified to it by Ofqual in relation to the qualification. One respondent disagreed and 3 neither agreed nor disagreed. No respondents strongly disagreed with this proposal.

Awarding organisations generally agreed with this proposal. Two of the awarding organisations that agreed said that they would expect awarding organisations to comply with what Ofqual, as the regulator, requested of them, as did a representative body. Two of the awarding organisations that agreed said that they would welcome the opportunity to discuss any requirements that Ofqual might specify in relation to a qualification ahead of the qualification going live. One awarding organisation that agreed with the proposal was concerned about the impact of managing conflicting IfATE and Ofqual feedback on their ability to get qualifications ready in a timely manner.

All of the respondents that neither agreed nor disagreed, and those that disagreed, with the proposal were from awarding organisations. Two of the awarding organisations that neither agreed nor disagreed expressed concerns regarding the alignment of any requirements specified by Ofqual with IfATE’s and employers’ needs. The other awarding organisation that neither agreed nor disagreed said it had no concerns with the proposal.

One awarding organisation disagreed with the proposal. It stated that the proposal was not clear on when awarding organisations would be expected to comply with any requests from Ofqual and whether that would be within an awarding organisation’s normal review and continuous improvement process. They also said that it was not clear what would be a requirement and what would be covered by guidance.

Three responses, 2 from awarding organisations and one from a representative body, raised concerns about the impact of this proposal on the timescales for introduction of qualifications. One awarding organisation said that it would be important that these qualifications could be developed in a timely manner to meet employers’ needs.

Two awarding organisations also referred to the increased burden that this proposal could impose upon them. One of the personal responses also referred to the need for the process around this approach not to be overly burdensome.

The other personal response referred to the bespoke nature of graded qualifications in the performing arts. These qualifications are outside of the scope of the Post 16 Qualifications Review and were not covered by this consultation.

Question 3

To what extent do you agree or disagree with the proposal to require an awarding organisation to notify Ofqual when a qualification ceases to be approved for public funding, and for Ofqual to specify additional requirements related to the qualification as a result?

Choice Respondents
Strongly agree 1
Agree 5
Neither agree nor disagree 6
Disagree 6
Strongly disagree 3

There were 21 responses to this question. Six either strongly agreed or agreed with the proposal to require an awarding organisation to notify Ofqual when a qualification ceases to be approved for public funding, and for Ofqual to specify additional requirements related to the qualification as a result. Nine respondents either strongly disagreed or disagreed, while 6 neither agreed nor disagreed with the proposal.

Two of the respondents that strongly agreed or agreed with the proposal were from awarding organisations, with the other 4 coming from other types of organisation. An awarding organisation that agreed with the proposal also suggested that any conventions relating to titling could lead to confusion for users of qualifications that have had their funding withdrawn. The other awarding organisation that agreed did not provide any comments.

Amongst the other respondents that strongly agreed or agreed, one suggested that Ofqual should continue to monitor the quality of the qualifications. One said that students’ needs should be protected. One said sector bodies will play an important role in defending the need for technical qualifications. One provided no further comment.

All 9 of the respondents that strongly disagreed or disagreed with the proposal, including 7 awarding organisations, suggested that Ofqual could get the information about funding withdrawal from DfE or the Education and Skills Funding Agency (ESFA). Two other respondents, who did agree with the proposal, also questioned why awarding organisations should have to provide this information directly to Ofqual themselves. These respondents focused on the notification of funding withdrawal aspect of the proposal and did not comment on the wider purpose of the requirement, which is to protect the interests of students taking the qualification at the time of funding withdrawal.

One awarding organisation that strongly disagreed with the proposal suggested that guidance would be needed on which rules would apply to each version of a qualification where public funding is being withdrawn. It also suggested that all qualifications, whether publicly funded or not, should adhere to the same assessment strategy requirements.

Three respondents said that following withdrawal of public funding, a qualification should stay on the Ofqual Register of Regulated qualifications[footnote 1]

Part 2 – Ofqual’s proposed regulatory approach for level 1 qualifications that are prerequisites to employment

Question 4

Do you have any comments on Ofqual’s proposed approach to regulating level 1 qualifications that are prerequisites to employment?

Fourteen respondents provided comments in response to this question. Of these, 8 were from awarding organisations, 3 were from representative bodies, 1 was from a trade association and 2 were personal responses.

Of the 8 responses received from awarding organisations, 4 were supportive of the proposal, one was not supportive, and 3 were neither supportive nor unsupportive.

Where awarding organisations were supportive of the proposal, 2 did not provide detailed comments beyond general agreement, one said the qualifications were important to employers and one agreed on the basis that no common issues had been identified with the qualifications.

The awarding organisation that was not supportive of the proposal said that it would mean a disparity in how level 1 and level 2 qualifications are regulated.

Where awarding organisations did not indicate a level of support for the proposal, one provided comments relating to a group of qualifications not in scope of the consultation while the other 2 said they needed more clarity on what the proposal meant in practice. Both of these respondents suggested that more clarity was needed on which qualifications were in this group, while one also sought more clarity on what controls and restrictions Ofqual could seek to introduce in future for one or more of these qualifications if it was deemed necessary.

Of the 4 other respondents who provided comments, 3 were representative bodies while the other was a trade association. Two of the representative bodies were supportive of the proposal, on the basis that the current system of regulation is working and that employers want to be able to access the training delivered through these qualifications. The other representative body neither agreed nor disagreed, suggesting that delivery and assessment of these qualifications would need to be accessible to the cohort of students who take them. The trade association that responded also neither agreed nor disagreed but said that the qualifications needed to meet the needs of both students and employers.

Part 3 – Proposed Qualification Level Conditions for level 2 qualifications designed to lead to skilled employment

Question 5

Do you have any comments on the drafting of proposed Condition TOQ1 (relating to interpretations and definitions)?

Ten respondents provided comments in response to this question. Four of those respondents were supportive of the drafting of the Qualification Level Condition (QLC) and the other 6 did not indicate a level of support. Of the respondents that were supportive, one welcomed the similarity to the equivalent QLC previously introduced for Level 3 Technical Occupation Qualifications, while the others made positive comments related to the clarity of the wording of the draft QLC.

Where respondents did not indicate a level of support for the drafting, they generally sought further clarification on one or more aspects of the draft wording of the QLC. Two respondents also provided comments that were out of scope of the consultation.

One respondent suggested that the title of the proposed QLCs could be made clearer, in order to distinguish them from any future Conditions which might be introduced for qualifications designed to lead to further study.

One respondent questioned whether this Condition would continue to apply in cases of withdrawal of public funding.

One respondent requested that the QLCs are clear and transparent, and that they align with the General Conditions of Recognition (GCR). However, the respondent did not explain what they meant by this.

One respondent suggested that having 2 definitions of Technical Occupation Qualifications across the respective sets of level 2 and level 3 QLCs could be confusing. The respondent also suggested that all Technical Occupation Qualification QLCs could be included in one set of requirements, covering all levels.

Two respondents made comments which did not relate to the drafting of this Condition. One referred to National Occupational Standards and the other to involving trade associations and sector bodies in qualification approval, both of which are matters for IfATE in its approvals remit rather than for Ofqual in its regulatory remit.

Question 6

Do you have any comments on the drafting of proposed Condition TOQ2 (relating to assessment strategies)?

Eleven respondents provided comments in response to this question. Ten were within the scope of this consultation and one comment related to involving trade associations in qualification approval, which was outside of the scope of this consultation.

Of the 10 respondents who provided relevant comments, 4 were supportive of the drafting of the condition. Two of these did not provide any further feedback and the other 2 welcomed that the wording is consistent with similar conditions that have been introduced for other groups of qualifications. Three of the respondents who indicated their support for the draft wording were from awarding organisations, while the other was from a representative body.

One respondent suggested that guidance on what must be included in the assessment strategy would be welcome[footnote 2].

One respondent requested clarity on whether every individual qualification would need a separate assessment strategy or whether one document could cover multiple qualifications. Another respondent suggested that a template assessment strategy document would be welcome, while another suggested that the requirements should be drafted as a minimum guideline.

One respondent said that the information provided in the consultation did not make it clear what the assessment strategy requirements would be for non-technical qualifications at level 2[footnote 3].

Question 7

Do you have any comments on the proposed requirements relating to assessment strategies for level 2 qualifications designed to lead to skilled employment?

Twelve respondents provided comments in response to this question. Of these, 6 were supportive of the proposed requirements and the other 6 did not indicate a level of support.

Where respondents were supportive of the drafting of the requirements, they did so on the basis that they are drafted clearly and that they are consistent with those introduced for other qualifications, particularly for level 3 Technical Occupation Qualifications.

Three awarding organisations commented on the additional burden the assessment strategy requirements will place on awarding organisations. One awarding organisation suggested that an assessment strategy serves the dual purpose of being both a regulatory document and an important working document for awarding organisations to use as a point of reference when developing their assessments.

Two respondents did not comment on the requirements but said that assessments need to be manageable for the students who take these qualifications, while another 2 respondents said assessments need to reflect employers’ needs. One respondent said that it would be difficult to know what Ofqual would find acceptable given it has not chosen to set assessment requirements alongside the requirement for an assessment strategy. For example, Ofqual has not set a requirement relating to the percentage of assessment to be done by examination.

One respondent provided a comment relating to the role that sector body criteria should have in the qualification development and approvals process, which was outside the scope of this consultation.

Question 8

Do you have any comments on the drafting of proposed Condition TOQ3 (relating to reviews of qualifications by Ofqual)?

Seven respondents provided comments in response to this question. Of these, 4 were supportive of the drafting of the proposed condition and 3 did not indicate a level of support.

The respondents who were supportive of the drafting said that they would expect to comply with Ofqual’s requirements anyway, and that the drafting of the Condition is consistent with that previously introduced for level 3 Technical Occupation Qualifications. One of these respondents also emphasised the need for a transparent process for awarding organisations to appeal against any requirements Ofqual specifies, while another said they hoped there would be a degree of flexibility with timeframes for awarding organisations to make any required changes and clarity on how any changes made following Ofqual’s review would impact IfATE approval of the qualification.

Where respondents did not indicate a level of support for the drafting of the proposed Condition, they requested greater clarity on what would trigger a review of a qualification and how long an awarding organisation would have to make any changes. One awarding organisation suggested this requirement would place an undue burden on awarding organisations.

One awarding organisation also suggested that a process requiring qualifications to be submitted to both Ofqual and IfATE would not enable qualifications to be developed quickly enough to meet emerging employer demands.

One respondent provided a comment relating to the role of sector body criteria in the qualification development and approvals process, which was outside the scope of this consultation.

Question 9

Do you have any comments on the drafting of proposed Condition TOQ4 (relating to the withdrawal of approval for public funding)?

Twelve respondents provided comments in response to this question. Most of these respondents commented on the policy proposal, which they disagreed with, not on the wording of the draft condition itself. However, 4 respondents provided comments on the drafting of the condition.

Two of the respondents who commented on the drafting of the condition welcomed its similarity to that previously introduced for level 3 Technical Occupation Qualifications. A representative body indicated general agreement with the drafting of the condition. An awarding organisation asked for greater clarity on what “promptly” and “likely to” mean in the context of the condition, suggesting that awarding organisations could interpret the condition differently and create inconsistencies in the market as a result.

One respondent reiterated the point made earlier in the consultation that qualifications should remain on the Ofqual register and be subject to Ofqual regulation in cases where public funding is withdrawn[footnote 4].

One respondent queried how the condition would apply in areas of England where funding decisions are devolved, such as Mayoral Combined Authorities.

One respondent provided a comment related to qualifications outside the scope of this consultation, while another provided a comment related to IfATE route panel membership which is also outside the scope of this consultation.

Equality impact

Question 10

Are there further impacts (positive or negative) on student equality arising from our proposed regulatory approach to level 1 and 2 qualifications Ofqual should consider? Where possible, please separate your answer by protected characteristic.

Ten respondents answered ‘yes’ to this question. Eleven respondents provided detailed comments, which included the 10 who answered ‘yes’ and one who did not answer the question.

Where respondents commented on the impact on students who share specific characteristics, they included socio-economically disadvantaged students, students with special educational needs and disabilities (SEND), students who are care leavers, students who suffer long-term illness, and students with physical disabilities. Several responses referred to the multiple barriers that can be faced by some students in the cohort who take these qualifications.

Many of the comments referred to the potential negative impact of the new funding approvals process on students sharing a particular protected characteristic without providing specific examples of negative impact. Several respondents suggested that, as students sharing specific protected characteristics are disproportionately represented in the cohort who take qualifications at this level, they will be disproportionately impacted. One respondent suggested it would be difficult to comment fully on the equality impacts of the proposals without knowing which qualifications would be affected.

One respondent commented specifically on the negative impact on students with SEND when funding was withdrawn for qualifications with low demand. The respondent suggested that training providers could find it difficult to identify suitable alternative provision for those students, especially where the students are used to a particular teaching approach.

Three respondents mentioned the need for entry level and level 1 academic provision, which was outside of the scope of this consultation. One respondent queried whether including literacy and numeracy outcomes in all qualifications had been considered. One respondent suggested British Sign Language qualifications are important for ensuring equality between deaf and hearing people, but these qualifications were also outside the scope of this consultation.

Question 11

Other than those identified above, are there any ways in which Ofqual could mitigate potential negative impacts on particular groups of students?

Six respondents provided comments in response to this question, of which 2 referred to their answers to Question 10 and one made a general comment about the need to prioritise students with protected characteristics during the funding approvals process.

One respondent suggested that bitesize or modular provision would meet the needs of students with SEND, while another suggested that flexible assessment approaches should be permitted and that summative assessment should not be required[footnote 5].

One respondent suggested that the potential negative impact of the proposals on members of displaced communities could be mitigated if qualifications were mapped to English for Speakers of Other Languages (ESOL) Skills for Life levels of language achievement.

Regulatory impact

Question 12

Eleven respondents provided comments in response to this question. Of these, 6 were from awarding organisations, 2 were from representative bodies, one was from a trade organisation and 2 were personal responses.

One respondent referred in general terms to the greater burden that the proposed regulatory approach to these qualifications will place on smaller awarding organisations.

One respondent referred to anticipated additional costs and longer timescales in qualification design arising from the ‘dual approvals process’. They also questioned how revisions to occupational standards will affect the timescales for development of these qualifications and the currency of live qualifications which are no longer aligned to the relevant standard.

One respondent said that the requirement to produce an assessment strategy might lead to Ofqual focusing its review on the quality of explanation given by awarding organisations, rather than on the substance of their assessment approaches. The respondent also suggested that it would be helpful to know whether there were approaches to assessment that Ofqual would only find acceptable in specific cases.

One respondent commented on the potential impact of licences to practise in certain professions, with those requirements also needing to be covered by the relevant qualifications.

Three respondents referred to the need for clarity on the impact of funding withdrawal on the titles of qualifications, where IfATE will introduce its own requirements, and where Ofqual has not chosen to specify any additional requirements beyond the General Conditions of Recognition. These respondents suggested that guidance would help to provide the clarity needed.

Three respondents reiterated their view that the requirement for awarding organisations to notify Ofqual when public funding is withdrawn from a qualification is a regulatory burden. They suggested the impact could be mitigated if DfE or ESFA shared the information with Ofqual instead.

One respondent sought clarification on Ofqual’s decision not to introduce a new regulatory qualification type or to require awarding organisations to extend their scope of recognition to offer these qualifications.

One respondent also commented on the equalities impact, rather than regulatory impact, arising from the reduction in the number of funded qualifications that will result from the Post 16 Qualifications Review.

One respondent made a comment related to the academic learning and social development of students, which was out of scope of the consultation.

Question 13

Are there any costs, savings or other benefits associated with the proposed regulatory approach which have not been identified? Please provide estimated figures where possible.

Seven respondents provided comments in response to this question. Of these, 4 identified potential additional costs, while none identified potential savings or other benefits. None provided estimated figures.

Four respondents suggested that awarding organisations could face additional resource costs because of the proposed regulatory approach but did not identify any specific cost areas. Two of these respondents said it would be important not to pass any costs onto training providers.

One respondent said that there would be an increased administrative burden on awarding organisations because of the proposals. One respondent said that the requirement to produce and maintain assessment strategies would generate additional costs for awarding organisations.

Two respondents provided potential mitigations for identified costs. One suggested it would help to reduce delays for awarding organisations if they could prepare in advance the additional information beyond the assessment strategy that IfATE requires as part of its approvals process. Another suggested that awarding organisations could produce one overarching assessment strategy for all of their qualifications with appendices for each particular qualification.

Question 14

Is there any additional information that Ofqual should consider when evaluating the costs and benefits of the proposed regulatory approach?

Four respondents provided comments in response to this question. Two comments related to assessment strategies, 2 comments referred to training providers, and one comment referred to students.

One respondent who referred to assessment strategies requested a clear timeframe for qualification submission and approval. Another respondent said clarity was needed on whether IfATE’s approvals process will vary between technical qualifications at different levels.

One respondent who referred to training providers suggested Ofqual should consider the impact of the need to for training providers to familiarise themselves with new qualifications ahead of delivery. The other respondent who referred to training providers noted the potential for them to face increased costs as a result of the proposals.

The respondent who referred to students suggested that fee-paying adults would be likely to face higher fees because of increased costs to awarding organisations as a result of the proposed regulatory approach being passed onto them.

Question 15

Do you have any comments on the impact of the proposed regulatory approach on innovation by awarding organisations?

Eight respondents provided comments in response to this question. Of these, 6 made comments that they felt related to the impact of the proposals on innovation. Of the other 2 responses, one referred to awarding organisations working with trade associations, while the other referred to National Occupational Standards and membership body standards.

Four respondents referred to the impact of timescales on the ability of awarding organisations to innovate, with 2 of these referring specifically to Ofqual’s regulatory approach and the others referring to the wider Post 16 Qualifications Review. One suggested the impact could be avoided if Ofqual provided a clear timetable for submissions which is agreed with awarding organisations. One respondent commented on the need to take into account that providers need time to familiarise themselves with new qualifications ahead of delivery.

Three respondents suggested that the additional regulatory burden arising from the proposals outlined in this consultation would affect the ability of awarding organisations to innovate. One referred specifically to the requirement to notify Ofqual when public funding is withdrawn from a qualification, while the other 2 referred to the proposals in general terms.

One respondent welcomed Ofqual’s commitment to fostering innovation within qualifications and willingness to look at any innovative practices in a positive way.

Annex A: List of organisational respondents

When completing the consultation questionnaire, respondents were asked to indicate whether they were responding as an individual or on behalf of an organisation. These are the organisations that submitted a non-confidential response:

  • Association of Colleges (AoC)

  • Association of School and College Leaders (ASCL)

  • Association of Accounting Technicians (AAT)

  • City & Guilds

  • EAL Awarding

  • Federation of Awarding Bodies (FAB)

  • Gateway Qualifications

  • Gradu8Ed Education Group

  • HOLEX

  • Lantra

  • NCFE

  • National Open College Network (NOCN) Group

  • Open Awards

  • Pearson Education

  • Qualifi

  • Training Qualifications UK

  • UK Fashion and Textile Association

  1. The publicly funded status of a qualification or otherwise would not affect its status as an Ofqual approved and regulated qualification. 

  2. The draft assessment strategy requirements included in this consultation include this information. 

  3. The draft assessment strategy requirements for these qualifications were consulted upon between 16 March and 25 May 2023. The consultation can be found here

  4. As noted previously, the funding status of a qualification would not affect its status as a regulated qualification which is on the Ofqual Register. 

  5. Ofqual has not taken a policy position on either of these two issues. IfATE will be introducing its own requirements in this area, which will neither preclude awarding organisations from taking a modular approach nor require summative assessment.