Open consultation

Part B: Impact assessments

Published 29 October 2026

Applies to England

Equality impact assessment

In considering the impact of these proposals, we have had due regard to the Public Sector Equality Duty.

We have considered whether the proposals in this consultation are likely to have an equality impact on students with a protected characteristic, or on other groups who share particular characteristics, such as socio-economic status or caring responsibilities.

Most of the changes set out in this consultation are operational in nature (for example, changing who aggregates results or issues a certificate) and we do not think they have a direct equality impact on any particular group of students.

However, we recognise a risk that students with a disability, socio-economic disadvantage, or caring responsibilities may be less able to complete the Industry Placement than other groups of students and so may fail to complete their T Level.

This risk is not created by our proposals; it already exists under the current arrangements, and the Department for Education’s (DfE’s) Industry Placement guidance to centres includes provision for reasonable adjustments. Any student affected in this way would still be able to receive a Statement of Achievement recognising completion of the Core and/or Occupational Specialism, as happens now.

Question 15

Are there any other potential equality impacts (positive or negative) on students  who share a particular protected characteristic or are from a lower socio-economic background arising from our proposals, either individually or in combination? Where possible, please separate your answer by protected characteristic.

Question 16

Are there any additional steps that Ofqual could take to mitigate any potential negative impacts resulting from the proposals, either individually or in combination, on students  who share a particular protected characteristic or are from a lower socioeconomic background?

Regulatory impact assessment

This regulatory impact assessment (RIA) considers the likely impacts of Ofqual’s proposals to amend the regulatory framework for Technical Qualifications (TQs) as set out above. The assessment compares the proposals against the current arrangements – which would continue if no changes were made – whereby TQs are delivered by a single DfE-appointed awarding organisation, Industry Placement completion is reported to DfE by centres, and DfE is responsible for issuing T Level certificates and Statements of Achievement.

We have assessed the likely impacts of these proposals descriptively rather than estimating their monetary cost or benefit. This is because there is uncertainty about how the proposals will be implemented and how awarding organisations may respond to them. This assessment focuses on the impacts arising from Ofqual’s proposed regulatory framework. Wider policy decisions taken by DfE include a move to an open market model. This change may make the following regulatory impacts applicable to a wider group of awarding organisations than the 4 current providers who are contracted by DfE and collectively offer the 20 TQs currently available to students. The competitive pressures introduced by a move to an open market may positively influence availability, quality and fees, which currently stand at £283.75 (weighted).

Assessment of impacts

The impacts of the primary policy proposal on awarding organisations, centres, students and employers are considered below as appropriate.

Renaming the technical qualification: impact on awarding organisations

Awarding organisations may incur minor one-off administrative costs in updating documentation, systems and communications to reflect the revised terminology. This may include amendments to qualification specifications, compliance documentation, scope of recognition records, centre guidance, websites and other published materials. Awarding organisations may also need to familiarise relevant staff with the revised terminology and make consequential changes to internal systems.

The scale of these costs is expected to vary between awarding organisations depending on the extent to which existing systems, processes and materials reference TQs. However, the proposal does not require awarding organisations to change design, delivery or operational processes. As a result, any costs are expected to be negligible to minor and largely one-off in nature.

Renaming the technical qualification: Impact on students, centres and other users

The proposal is not expected to result in significant impacts on centres or students. They may benefit from greater consistency in terminology between the qualification being regulated and the wider T Level programme, which is better recognised by users of the system. The impact of this proposal on other users is expected to be negligible.

Results aggregation, certification and Statements of Achievement: Impact on awarding organisations

The proposal would introduce additional responsibilities for awarding organisations regarding results aggregation and certification, with consequential changes relating to appeals arrangements. These are expected to result both in one-off implementation and in ongoing administrative costs.

Awarding organisations may incur familiarisation costs associated with understanding these requirements and implementing necessary changes to systems and processes. Awarding organisations are currently likely to possess the systems and operational capability required to undertake these activities, including certification and appeal arrangements, through their delivery of other regulated qualifications. While the proposals represent a transfer of some responsibilities from DfE to awarding organisations, implementation costs may be limited by adapting existing approaches.

Awarding organisations may incur implementation costs associated with establishing and maintaining arrangements for the aggregation of results, including quality assurance and governance processes to support the determination of overall T Level outcomes.

The proposal to bring the grade aggregation tables within Ofqual’s regulatory framework is not expected to create significant additional burden for awarding organisations. The proposal largely formalises arrangements that already underpin the determination of overall T Level outcomes and provides greater regulatory clarity regarding how overall grades are calculated.

Awarding organisations may incur ongoing administrative costs associated with updating and operating review and appeals arrangements relating to aggregation, certification and Statements of Achievement decisions. This may include updating procedures, providing staff training and handling appeals from centres or students.

Overall, the initial and ongoing impact of this proposal on awarding organisations is expected to be minor to moderate.

Results aggregation, certification and Statements of Achievement: Impact on students, centres and other users

Centres may experience minor changes to administrative processes where awarding organisations, rather than DfE, become responsible for certification and associated student queries. However, as most centres are already accustomed to working directly with awarding organisations for the delivery and certification of other regulated qualifications, any additional burden is expected to be limited.

Students may benefit from a simpler and more integrated approach to the determination of outcomes, certifications and appeals with a single organisation responsible for assessment, aggregation and certification decisions. The proposal may also provide greater clarity regarding routes of appeal where certification decisions are challenged. Overall, ongoing impacts on centres and students are expected to be minor, with negligible impact on other users.

Overseeing reporting of completion of the Industry Placement: Impact on awarding organisations

Awarding organisations would be required to establish systems and processes for collecting centre declarations, undertaking quality assurance activities, and maintaining records. Awarding organisations may also need to update centre agreements, guidance and internal processes to reflect the new arrangements. The proposed changes would not require awarding organisations to secure Industry Placements for students, monitor placement quality or reassess centre judgements regarding completion of the Industry Placement. However these additional responsibilities are expected to increase burden relative to the current position, in which centres report completion of the Industry Placement to DfE.

The proposal may also lead to ongoing costs associated with any quality assurance activity, such as reviewing evidence from sampled centres and investigating suspected cases of malpractice or maladministration. The extent of these costs will depend on the quality assurance arrangements adopted by individual awarding organisations and the number of centres delivering their qualifications.

The proposal is therefore expected to introduce minor to moderate implementation and ongoing costs.

Overseeing reporting of completion of the Industry Placement: Impact on students, centres and other users

Centres are already required by DfE to arrange Industry Placements, to determine whether students have met DfE’s completion criteria and to maintain records. The proposal primarily changes reporting arrangements rather than introducing wholly new requirements, although currently DfE does not undertake any quality assurance activity of centre records.

For students, the proposals do not alter the requirement to complete an Industry Placement in order to achieve a full T Level. Students who do not complete all parts of the T level would continue to be eligible for a Statement of Achievement. Similarly, the proposal is not expected to result in any new requirements for employers who will continue to provide Industry Placements as before.

For centres, the proposal may introduce minor ongoing costs arising from the quality assurance activity undertaken by awarding organisations, although this will only affect sampled centres.

Other changes to TQ regulatory framework: Impact on awarding organisations

Awarding organisations already offering TQs may incur one-off familiarisation costs associated with understanding and implementing the new condition requiring compliance with DfE subject content. These may include reviewing internal policies and procedures, updating compliance documentation, and ensuring that qualifications remain aligned to DfE subject content requirements. This proposal largely builds on existing arrangements rather than introducing substantive new requirements, so is expected to have limited impact.

Awarding organisations may incur minor one-off costs associated with reviewing and updating TQT calculations and related documentation to reflect the inclusion of Industry Placement hours. As the proposal affects how qualification size is described rather than the underlying delivery requirements, ongoing impacts are expected to be limited.

Awarding organisations already produce and publish indicative exemplification materials and therefore no additional costs are expected from this proposal. The current proposal would remove the additional requirement for awarding organisations to publish actual exemplification materials following assessment delivery. This is expected to reduce ongoing administrative and operational burden relative to the current position in which both indicative and actual exemplification materials are published.

For awarding organisations seeking to enter the market, compliance with Ofqual’s requirements may result in additional administrative activity associated with obtaining and maintaining recognition. These requirements are broadly consistent with those that apply across other regulated qualification markets and are expected to be familiar to awarding organisations. The impact on these awarding organisations is therefore expected to be minor and largely one-off.

The proposal does not introduce Subject Level Conditions but provides flexibility for Ofqual to consult on and introduce such conditions in the future. As such, no impacts have been identified at this stage.

Other Changes to TQ regulatory framework: Impact on students, centres and other users

The proposals are not expected to require changes to assessment arrangements, qualification standards or centre delivery practices. Direct impacts on students, centres and other users are therefore expected to be limited. The proposal may provide benefits through establishing a comprehensive regulatory framework, helping to support confidence in qualification outcomes and the operation of the market over time. The ongoing impacts on students, centres and other users are expected to be negligible.

Question 17

Are there any impacts of these proposals that we have not identified? Please outline any additional costs or benefits that you foresee.

Question 18

Are the descriptions of the magnitude of the impacts accurate? Please inform us where we have over or underestimated cost or benefit. We welcome specific quantifiable information to support our understanding of the scale of change.

Question 19

Do you have any suggestions for reducing or mitigating the costs associated with these proposals?

Growth Duty

The proposals are intended to support the transition from the current single-supplier model to a regulated market and to simplify oversight and regulation of T Levels. The proposals will result in some additional requirements, primarily falling on awarding organisations, which are designed to support effective regulation and maintain confidence in T Level outcomes. T Level outcomes include preparing students for entry into skilled employment or study and meeting the skills needs of industry, each of which are expected to support overall economic growth. Using proportionate regulation to support these outcomes is therefore in line with Ofqual’s statutory duty to avoid imposing unnecessary regulatory burdens, and the Growth Duty, which requires regulators to have regard for the desirability of promoting economic growth through their regulatory approach.

Innovation

The proposals are not intended to prescribe the operational arrangements awarding organisations must adopt beyond those necessary to secure valid and reliable outcomes. This provides awarding organisations with the flexibility to determine how best to meet regulatory requirements, including through the use of existing systems, processes and technologies. While the scale of any innovation effects is uncertain, the proposals are unlikely to impact on innovation.

Question 20

Do you have any comments on the impact of these proposals on innovation by awarding organisations?