Consultation outcome

Analysis: Regulatory framework for apprenticeship assessment

Updated 3 December 2025

Background

Ofqual is the independent regulator for qualifications in England. Ofqual’s statutory objectives include securing the standards of, and promoting public confidence in, regulated qualifications. Our role is to steward the qualifications system, taking a whole system, long-term, proactive approach to protect the value of qualifications for students and apprentices and to support economic growth.

Ofqual’s rules, which awarding organisations must follow, are designed to achieve this. Ofqual monitors the application of these rules, supporting compliance and taking regulatory action where necessary.

Ofqual currently regulates the assessment of more than 580 apprenticeship occupational standards, set by Skills England, including through specific rules in relation to end-point assessments (EPA).

In February 2025, the Department for Education (DfE) published its Apprenticeship Assessment Principles. These principles set out a range of changes to the current EPA approach to assessment. They will apply to all apprenticeships, at all levels, and will apply to foundation apprenticeships as well as to specialised apprenticeships.

Through its principles, DfE intends to streamline the assessment process for apprenticeships by enabling more design and delivery flexibility, so that:

• assessment is more proportionate to the competency being tested and duplication is removed
• assessment can happen on programme
• providers can deliver and mark elements of the assessment, with appropriate oversight

To reflect these changes, the existing assessment plans on which all EPAs are based will be streamlined, on a phased basis, by Skills England. Employers’ views on assessing the competence of apprentices will continue to be important, but much of the detail included in the existing assessment plans will be removed, with awarding organisations given more flexibility when designing and delivering assessments that meet the employer-set occupational standard.

The implementation of DfE’s principles in the new simplified arrangements represents a significant change from the current EPA assessment approach, where all assessment happens at the end of the apprenticeship after a gateway process and is independently marked by the awarding organisation. In achieving greater design and delivery flexibility for awarding organisations, it is likely that the new arrangements will lead to greater diversity of approach between awarding organisations. Our priority is to ensure that Ofqual’s regulation reflects DfE’s policy while also mitigating risks as far as is reasonably possible and so maintains public and employer confidence in the results achieved by apprentices under the new arrangements.

The overall aims of our new rules for apprenticeship assessment are therefore to:

• embed DfE’s Apprenticeship Assessment Principles in Ofqual’s regulation
• secure awarding organisations’ compliance with the new streamlined apprenticeship assessment plans
• specify key requirements for the design of apprenticeship assessment to ensure their validity
• enable Ofqual to hold awarding organisations to account for the design and delivery decisions they have made

The consultation was an opportunity for interested groups to comment on the way Ofqual proposed to regulate the new apprenticeship assessments. It was not a consultation on DfE’s assessment principles, as their introduction is not a decision for Ofqual. It was a consultation on how we will reflect DfE’s assessment principles in our regulatory framework, in line with our statutory objectives.

Summary

The majority of organisational consultation responses came from awarding organisations, representative or interest groups and providers. A minority of responses came from employers.

All proposals set out in the consultation received overall support. Where respondents provided additional comments, several recurring themes emerged across the consultation, most of which were a consequence of the introduction of DfE’s assessment principles.

The most common theme concerned the potential impact on the consistency and comparability of apprenticeship assessment. Many respondents said that reducing prescription in apprenticeship assessment plans and increasing the autonomy of awarding organisations in designing and delivering assessments could lead to varied approaches. This, it was suggested, might affect the comparability of assessment outcomes and could adversely impact the consistency of performance standards.

Even among those who recognised the potential benefits of greater flexibility – such as increased innovation and accountability – there was a strong emphasis on the need for robust oversight by Ofqual to ensure consistency and comparability are maintained.

Respondents frequently requested detailed guidance from Ofqual to clarify expectations and support awarding organisations in meeting the requirements of any revised regulatory framework.

Respondents also raised concerns about the potential for increased burden across the sector. These included the regulatory demands on awarding organisations, the need for providers to adapt to new practices such as centre marking, and any additional engagement required with employers. Respondents highlighted the importance of support from Ofqual during the transition period and called for flexibility in implementing the revised framework for new assessments as ways to help mitigate these challenges.

Approach to analysis

The consultation consisted of 50 questions (including questions on equality and regulatory impact assessments and innovation) and was published on Ofqual’s website. Respondents could complete the questions using our online consultation platform or submit a response to our consultation mailbox address.

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.

Analysis of the consultation questions is presented in the order in which the questions were asked. The consultation questions covered the following areas:

• Purposes
• Content
• Assessment structure and synoptic assessment
• Setting assessments
• Marking assessments
• Assessment design
• Grading and standard setting
• Assessment strategies
• Employer engagement
• Disapplication of General Conditions
• Guidance in the current EPA regulatory framework
• Transition arrangements

For all questions that were part of the main body of the consultation, Ofqual presented background contextual information followed by proposals. Respondents could answer as many or as few questions as they wished. Twenty-one questions asked respondents to indicate their level of agreement with a particular proposal. Twenty-nine questions, including all the questions in the equality impact, regulatory impact and innovation sections were free text response questions where respondents could leave comments.

Who responded

Ofqual’s consultation on the regulatory framework for apprenticeship assessment was open between 20 June and 27 August 2025.

Ofqual received 192 responses to its consultation. Most responses were received via our Citizen Space consultation platform, although a significant proportion (22 submissions) were received in the form of responses sent to our consultation mailbox.

All responses have been considered as part of this analysis. Not all respondents chose to answer all questions.

There were 113 official responses from the following types of organisation:

Type of organisation	Number of respondents
Awarding organisation	48 (15 of which only offer EPA)
Representative or interest group	22
Private training provider	14
Employer	11
School, college, university or higher education institution	5
Local authority	2
Other (did not identify with any of the above categories)	11
Total	113

Ofqual also received 79 personal responses:

Type of responder	Number of respondents
Private training provider employee	17
Awarding organisation employee	13
Senior leadership team member	13
School or college employee	10
Teacher or lecturer	6
Employer	5
Consultant	4
Exams officer or manager	3
Representative or interest group employee	3
Parent or carer	1
Other (did not identify with any of the above categories)	4
Total	79

All but one respondent was based in England.

The full list of organisations that submitted responses can be viewed at Annex A.

Detailed analysis

Purposes

Question 1
Do you have any comments on the drafting of the proposed general purposes for apprenticeship assessment?

There were 136 comments on the drafting of the proposed general purposes for apprenticeship assessment. Of these, 90 responses were made on behalf of organisations and 46 from individuals responding in a personal capacity.

Organisation responses comprised:

• 44 awarding organisations, including 13 which offer EPA only
• 16 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 12 representative or interest groups
• 9 employers
• 9 other organisations that did not identify with any of the categories above

In the consultation, Ofqual proposed that the general purposes for apprenticeship assessments should be as follows and should be prioritised as set out below:

• Purpose A: Enabling the apprentice to acquire and demonstrate the knowledge and skills specified in the occupational standard, to reflect the level of competence required
• Purpose B: Providing employers with reliable evidence of an apprentice’s attainment against the relevant knowledge and skills so they can have confidence that the apprentice has reached the expected performance standard and use the evidence to make employment decisions
• Purpose C: Building the apprentice’s confidence in the workplace and motivating them to develop their occupational competence

When providing comments on the proposed general purposes, respondents often started by expressing concern about the implications for consistency and comparability on the new assessment arrangements proposed by DfE. This was the case for all respondent groups.

When respondents commented on the proposed general purposes, some respondents said that general purposes could help to bring about some level of consistency and comparability. Some respondents suggested however that the proposed purposes were described at too high a level and that awarding organisations could interpret them differently.

Many respondents provided comments on the drafting of specific general purposes and their intended meaning. For Purpose A, some respondents questioned whether the function of apprenticeship assessment is the acquisition of knowledge and skills, or whether it should only be the demonstration of the knowledge and skills they have acquired through their training. Some respondents also felt that the use of ‘acquire’ blurred the distinction between ‘formative’ assessment (which would not contribute to the final grade) and ‘summative’ assessment (which would contribute to a final grade).

For Purpose B, respondents said that employers use apprenticeships in different ways and that this should be reflected in the purpose statement. Many respondents suggested that the achievement of the apprenticeship itself is not primarily used as evidence by employers when making employment decisions. Some suggested it is the achievement of a mandatory qualification in an apprenticeship programme that provides this role.

For Purpose C, respondents said that motivating apprentices is the responsibility of the apprentice’s provider and/or employer rather than the awarding organisation. Several respondents also questioned whether it would be possible to measure whether this purpose had been achieved through an assessment, given the difficulty of measuring levels of motivation.

Respondents referred to the relationship between the general purposes and products produced by Skills England, such as occupational standards and apprenticeship assessment plans. Some of these respondents were concerned that there could be a conflict between Purpose A and Skills England’s intention that knowledge and skills statements are sampled. Others suggested that the general purposes could be more explicitly linked to the expectations set out in occupational standards and apprenticeship assessment plans.

Some respondents made comments related to EPA, some of whom indicated general support for EPA while some others suggested the introduction of general purposes could help to address issues with EPA.

Question 2
To what extent do you agree or disagree with the proposed order of prioritisation of the proposed general purposes?

Choice	Respondents
Strongly agree	21
Agree	91
Neither agree nor disagree	37
Disagree	24
Strongly disagree	12
Did not answer the question	7

There were 185 responses to this question. Of these, 112 respondents either strongly agreed or agreed on our proposed order of prioritisation of the proposed general purposes. There were 65 responses made on behalf of an organisation, with 26 coming from awarding organisations, 8 of which offer EPA only.

Of the 36 respondents that disagreed or strongly disagreed with the proposal, 18 were organisation responses. These included responses from 8 awarding organisations (4 being EPA only awarding organisations), 5 representative or interest groups, 3 employers, and 2 providers.

Of the 37 that neither agreed nor disagreed with the proposal, 23 were organisation responses. Fourteen organisation responses were from awarding organisations, 3 of which offer EPA only.

Question 3
To what extent to do you agree or disagree with the proposal to require awarding organisations to design apprenticeship assessments that are in line with nationally set general purposes which will be included in Ofqual’s regulatory framework?

Choice	Respondents
Strongly agree	39
Agree	93
Neither agree nor disagree	16
Disagree	17
Strongly disagree	18
Did not answer the question	9

There were 183 responses to this question. Of these, 132 respondents either strongly agreed or agreed with our proposal to require awarding organisations to design apprenticeship assessments that are in line with nationally set general purposes which will be included in Ofqual’s regulatory framework. There were 78 responses made on behalf of an organisation, with 36 coming from awarding organisations, 6 of which offer EPA only.

Of those 35 respondents that disagreed or strongly disagreed with the proposal, 18 were organisation responses. These included responses from 9 awarding organisations (5 being EPA only awarding organisations), 4 representative or interest groups, 3 employers, and 2 other organisations that did not identify with any of these categories.

Of the 16 that neither agreed nor disagreed with the proposal, 8 were organisation responses. Three of these were from awarding organisations, one of which offers EPA only.

Question 4
To what extent do you agree or disagree with the proposal to require awarding organisations to explain how they have developed apprenticeship assessments that reflect the nationally set purposes and justify any trade-offs they have made between the purposes?

Choice	Respondents
Strongly agree	58
Agree	84
Neither agree nor disagree	18
Disagree	13
Strongly disagree	11
Did not answer the question	8

There were 184 responses to this question. Of these, 142 respondents either strongly agreed or agreed with our proposal to require awarding organisations to explain how they have developed apprenticeship assessments that reflect the nationally set general purposes and to justify any trade-offs made between the purposes. There were 82 responses made on behalf of an organisation, with 38 coming from awarding organisations, 11 of which offer EPA only.

Of those 24 respondents that disagreed or strongly disagreed with the proposal, 15 were organisation responses. These included responses from 7 awarding organisations (3 being EPA only awarding organisations), 3 employers, 2 representative or interest groups, one private training provider, and 2 other organisations that did not identify with any of these categories.

Of the 18 that neither agreed nor disagreed with the proposal, 8 were organisation responses. Three of these were from awarding organisations, one of which offers EPA only.

Question 5
To what extent do you agree or disagree with the proposal to require awarding organisations to develop specific purposes for individual apprenticeship assessments in line with the proposed general purposes?

Choice	Respondents
Strongly agree	35
Agree	90
Neither agree nor disagree	24
Disagree	20
Strongly disagree	14
Did not answer the question	9

There were 183 responses to this question. Of these, 125 respondents either strongly agreed or agreed with our proposal to require awarding organisations to develop specific purposes for individual apprenticeship assessments in line with the proposed general purposes. There were 67 responses made on behalf of an organisation, with 26 coming from awarding organisations, 7 of which offer EPA only.

Of those 34 that disagreed or strongly disagreed with the proposal, 20 were organisation responses. These included responses from 13 awarding organisations (5 being EPA only awarding organisations), 3 employers, 2 representative or interest groups, one private training provider, and one other organisation that did not identify with any of these categories.

Of the 24 that neither agreed nor disagreed with the proposal, 17 were organisation responses. Nine of these were from awarding organisations, 3 of which offer EPA only.

Question 6
Do you have any further comments on the proposals contained in this section?

There were 95 further comments on the drafting of the proposed general purposes for apprenticeship assessment. Of these, 62 responses were made on behalf of organisations and 33 from individuals responding in a personal capacity.

Organisation responses comprised:

• 29 awarding organisations, including 13 which offer EPA only
• 12 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 10 representative or interest groups
• 4 employers
• 7 other organisations that did not identify with any of the categories above

As with question 1, the implication of moving away from EPA for consistency and comparability was the theme most commonly mentioned. Some respondents said that increased autonomy for awarding organisations in designing assessments could lead to inconsistent interpretations of the general purposes, while others suggested that allowing centre adaptations of assessments (addressed in a later question in the consultation) could threaten consistency and undermine the general purposes.

Many of those responding said that Ofqual would need to clarify how awarding organisations should meet the general purposes set out, with most proposing that Ofqual should set this out in examples and/or guidance. Respondents suggested that Ofqual could provide worked examples of assessment tasks and grading criteria, templates which awarding organisations could use to document the trade-offs made between the purposes, and case studies setting out how different types of assessment could align with the purposes.

Some respondents questioned the proposed order of prioritisation set out. Some of these respondents felt that Purpose A and Purpose B overlapped, as competence should naturally lead to employer confidence in an apprentice’s ability. Some respondents felt that the purposes should be equally weighted, while others felt that there could be a different order of prioritisation in different contexts, or for different sectors, and that awarding organisations should be able to justify a different order of prioritisation if they felt it appropriate for a given assessment.

Some respondents questioned the use of ‘employment decisions’, saying the different types of employment decision would mean different stakes being attached to the assessment (for example, a hiring decision would be higher stakes than a decision on which tasks to allocate to an apprentice).

Several respondents questioned whether Purpose C should be set by Ofqual at all, even where they indicated agreement with the need to motivate apprentices. Where respondents proposed a different order of prioritisation, some suggested that Purpose C should take priority over Purpose B. No respondents suggested that Purpose A should be a lower priority than the other proposed general purposes.

Some respondents also commented on the proposal to require awarding organisations to develop specific purposes in line with the general purposes. These respondents were generally supportive of the proposal, with some seeing value in allowing them to reflect professional bodies’ requirements and others more generally welcoming the idea of awarding organisations being able to more accurately reflect the requirements of different occupations than the general purposes can. However, several respondents raised the potential for this requirement to add regulatory burden.

A small number of respondents questioned why Ofqual was setting general purposes at all and suggested that it was not necessary.

Content

Question 7
To what extent do you agree or disagree with the proposal to require awarding organisations to explain how their apprenticeship assessment covers the knowledge and skills set out in the relevant occupational standard published by Skills England?

Choice	Respondents
Strongly agree	77
Agree	80
Neither agree nor disagree	12
Disagree	9
Strongly disagree	7
Did not answer the question	7

There were 185 responses to this question. Of these, 157 respondents either strongly agreed or agreed with the proposal to require awarding organisations to explain how their apprenticeship assessments cover the knowledge and skills set out in the relevant occupational standard published by Skills England. There were 85 responses made on behalf of an organisation, with 36 coming from awarding organisations, 12 of which offer EPA only.

Of the 15 respondents who disagreed or strongly disagreed with the proposal, all but one were organisation responses. These included 7 awarding organisations (3 being EPA only awarding organisations), 3 representative or interest groups, 2 employers, 2 private training providers, and one other organisation that did not identify with any of these categories.

Of the 12 that neither agreed nor disagreed with the proposal, 6 were official responses, with 6 responding in an individual capacity. Five organisational responses were from awarding organisations, none of which offer EPA only.

Question 8
To what extent do you agree or disagree with the proposal to require awarding organisations to design apprenticeship assessments that cover the assessment outcomes set out in the apprenticeship assessment plans published by Skills England?

Choice	Respondents
Strongly agree	70
Agree	82
Neither agree nor disagree	14
Disagree	9
Strongly disagree	8
Did not answer the question	9

There were 183 responses to this question. Of these, 152 respondents either strongly agreed or agreed with the proposal to require awarding organisations to design apprenticeship assessments that cover the assessment outcomes set out in the apprenticeship assessment plans published by Skills England. There were 87 responses made on behalf of an organisation, with 42 coming from awarding organisations, 14 of which offer EPA only.

Of the 17 respondents who disagreed or strongly disagreed with the proposal, 10 were organisation responses, which included 2 awarding organisations (one being an EPA only awarding organisation), 3 employers, 3 representative or interest groups, one provider and one other organisation that did not identify with any of these categories.

Of the 14 that neither agreed nor disagreed with the proposal, 7 were organisation responses. Four of these were from awarding organisations, none of which offer EPA only.

Question 9
To what extent do you agree or disagree with the proposal to require awarding organisations to comply with any requirements regarding coverage of content set out in the apprenticeship assessment plans published by Skills England?

Choice	Respondents
Strongly agree	74
Agree	88
Neither agree nor disagree	12
Disagree	5
Strongly disagree	4
Did not answer the question	9

There were 183 responses to this question. Of these, 162 respondents either strongly agreed or agreed with the proposal for awarding organisations to comply with any content coverage requirements set out in the apprenticeship assessment plans published by Skills England. There were 91 responses made on behalf of an organisation, with 43 coming from awarding organisations, 14 of which offer EPA only.

Of the 9 respondents who disagreed or strongly disagreed with the proposal, 6 were organisation responses which included responses from an awarding organisation offering EPA only, 2 representative or interest groups, 2 employers, and one other organisation that did not identify with any of these categories.

Of the 12 that neither agreed nor disagreed with the proposal, 7 were organisation responses. Four of these were from awarding organisations, none of which offer EPA only.

Question 10
Do you have any comments on the proposals contained in this section?

There were 116 comments in response to this question. Of these, 79 responses were made on behalf of organisations and 37 from individuals responding in a personal capacity.

Organisation responses comprised:

• 37 awarding organisations, including 10 which offer EPA only
• 15 providers, including private training providers, schools, colleges and higher education institutions
• 10 representative or interest groups
• 9 employers
• 8 other organisations that did not identify with any of the categories above

Many respondents said that requiring awarding organisations to explain how the content of their apprenticeship assessments reflected the knowledge and skills set out in occupational standards would help to enhance stakeholder confidence. They noted that explicitly linking content of the occupational standard to the content of the assessment would help ensure assessments are fit for purpose and reinforce the role of apprenticeships as a valid measure of occupational competence.

Some respondents also said that this would address a key validity concern in the current EPA model, namely the risk that assessments may overlook or insufficiently measure essential knowledge, skills, and behaviours outlined in occupational standards. By allowing awarding organisations to make decisions about the coverage of the knowledge and skills statements, it was argued that they would be able to prioritise and embed these critical elements more effectively within assessment design.

Many respondents commented on the implications of changes on the consistency and comparability of assessment design and delivery across different occupational standards as well as for the same occupational standard.

Respondents said that divergent approaches taken by awarding organisations in designing apprenticeship assessments may lead to inconsistencies that undermine clarity for apprentices, employers, and providers. Respondents stated that variation in assessment approaches could result in misalignment between assessment content and employer expectations, potentially affecting the perceived relevance and credibility of apprenticeships.

Many respondents specifically noted risks associated with variability in the level of demand of assessments. They cautioned that competitive market pressures may incentivise awarding organisations to design assessments that are easier to pass, potentially leading to a decline in quality — described by some as a “race to the bottom”.

Some respondents remarked on the importance of Ofqual implementing robust assurance mechanisms to support the comparability of assessment outcomes across awarding organisations. Concerns were raised about whether comparability could be effectively maintained in the absence of consistent approaches to assessment design and delivery.

Many respondents suggested Ofqual would need to provide clear guidance to stakeholders on implementing the proposed content coverage requirements. Specifically, they requested support in understanding the relationships between assessment purposes, outcomes, and the knowledge and skills statements.

Additionally, many respondents sought clarification on how these requirements should be applied in practice, particularly in relation to assessment outcomes and their alignment with knowledge and skills statements. Concerns were raised about the lack of clarity surrounding sampling approaches and the expectations placed on awarding organisations to justify their decisions. Several respondents recommended that Ofqual offer positive and negative indicators of compliance, alongside exemplars, templates, and case studies to support consistency and standardisation across awarding organisations.

Respondents also highlighted the need for Skills England’s apprenticeship assessment plans to provide clear, consistent guidance, retain employer input, and stay relevant to evolving sectors. Several respondents raised concerns about the assessment plans lacking prescriptiveness, and several others asked that assessment methods be explicitly specified.

Many respondents also stressed the importance of employer involvement in the development of the apprenticeship assessment plans and the need for apprenticeship assessment plans to keep pace with fast-changing industries.

Assessment structure and synoptic assessment

Question 11
To what extent do you agree with the proposal to require awarding organisations to comply with any requirements on the timing of assessment set out in an apprenticeship assessment plan published by Skills England?

Choice	Respondents
Strongly agree	59
Agree	82
Neither agree nor disagree	18
Disagree	19
Strongly disagree	5
Did not answer the question	9

There were 183 responses to this question. Of these, 141 respondents either strongly agreed or agreed with the proposal to require awarding organisations to comply with any requirements on the timing of assessment set out in an apprenticeship assessment plan published by Skills England. There were 79 responses made on behalf of an organisation, with 34 coming from awarding organisations, 10 of which offer EPA only.

Of the 24 respondents who disagreed or strongly disagreed with the proposal, 14 of these were organisation responses, which included responses from 7 awarding organisations, 4 of these offering EPA only.

Of the 18 that neither agreed nor disagreed with the proposal, 11 were organisation responses. Seven organisational responses were from awarding organisations, one of which offers EPA only.

Question 12
Do you have any comments on the proposed definition of synoptic assessment?

There were 107 comments in response to this question. Of these, 77 responses were made on behalf of organisations and 30 from individuals responding in a personal capacity.

Organisation responses comprised:

• 40 awarding organisations, including 10 which offer EPA only
• 13 providers, including private training providers, schools, colleges and higher education institutions
• 6 representative or interest groups
• 10 employers
• 8 other organisations that did not identify with any of the categories above

The most common theme referred to by respondents concerned the timing of any synoptic assessment. It was felt that synoptic assessment should take place towards the end of the apprenticeship programme and that the definition should reflect this. Many of these respondents felt that allowing awarding organisations to decide on the timing of their synoptic assessment risks undermining comparability of outcomes between awarding organisations. It was felt that only an assessment taken towards the end of the programme would accurately reflect an apprentice’s ability to use their knowledge and skills effectively and in an integrated way. Some of these respondents felt there was a risk that synoptic assessment and summative assessment would be confused and sought clarification on whether the two were considered synonymous.

In our consultation, Ofqual proposed to define synoptic assessment as requiring the apprentice to:

identify and use effectively, in an integrated way, an appropriate and substantial selection of knowledge and skills from the occupational standard.

Some respondents said that the proposed definition was too vague. Several respondents said that the definition was unclear on how integration of knowledge and skills should be demonstrated. Some respondents suggested using sector-specific examples and case studies to more clearly demonstrate what kinds of approach to synoptic assessment would be acceptable.

Some responses questioned the use of specific terms in the proposed definition. Many respondents questioned the meaning of the term ‘substantial’ in the definition, feeling the term too vague and open to interpretation, which could lead to inconsistent application between awarding organisations.

Several of these respondents suggested that Ofqual should set clearer parameters for synoptic assessment, since ‘around 40%’ was seen as too subjective and open to (mis)interpretation. A respondent thought that the 40% figure could also be too confusing and suggested using 50% instead. Some respondents also questioned the use of the term ‘appropriate’, again feeling it was too subjective. It was suggested that Ofqual guidance would be needed to help awarding organisations determine what would be ‘appropriate’ for different occupational standards.

Many respondents referred to the need for consistency and comparability across awarding organisations to ensure performance standards are upheld. It was suggested that the proposed definition could lead to variation in assessment design and grading, threatening consistency and comparability across awarding organisations. Several respondents suggested Ofqual should provide exemplars to support standardisation of approaches across awarding organisations.

Question 13
To what extent do you agree with the proposal that Ofqual should require awarding organisations to design apprenticeship assessments to include some synoptic assessment?

Choice	Respondents
Strongly agree	62
Agree	75
Neither agree nor disagree	28
Disagree	9
Strongly disagree	8
Did not answer the question	10

There were 182 responses to this question. Of these, 137 respondents either strongly agreed or agreed with the proposal to require awarding organisations to design apprenticeship assessments to include some synoptic assessment. There were 78 responses made on behalf of an organisation, with 37 coming from awarding organisations, 9 of which offer EPA only.

Of the 17 respondents who disagreed or strongly disagreed with the proposal, 10 of these were organisation responses. These included responses from 5 awarding organisations (3 offering EPA only), 2 representative or interest groups, one employer, one provider, and one other organisation that did not identify with any of these categories.

Of the 28 that neither agreed nor disagreed with the proposal, 15 were organisation responses. Five of these were from awarding organisations, 2 of which offer EPA only.

Question 14
Do you have any comments on the proposal to issue Ofqual guidance in relation to the use of synoptic assessment? Please specify any areas you think that it would be helpful to include in the guidance.

There were 109 comments in response to this question. Of these, 77 responses were made on behalf of organisations and 32 from individuals responding in a personal capacity.

Organisation responses comprised:

• 39 awarding organisations, including 10 which offer EPA only
• 12 providers, including private training providers, schools, colleges and higher education institutions
• 11 representative or interest groups
• 7 employers
• 8 other organisations that did not identify with any of the categories above

The most common theme raised by respondents was the need for Ofqual to be clear in its expectations of awarding organisations. As in the comments for question 12, respondents asked for clarity on what ‘appropriate’ and ‘substantial’ integration would look like. Respondents also asked for clarity on adaptations that schools, colleges and providers could and could not make to synoptic assessment, and what documentation awarding organisations must retain to demonstrate how they have determined their approach to synoptic assessment.

Many respondents suggested additions to the proposed definition of synoptic assessment. This included confirming whether the use of directly graded assessments would be acceptable as well as mark-based approaches, and on expectations regarding assessment conditions. Some awarding organisations argued that requiring a minimum amount of synoptic assessment rather than guidance would better mitigate a ‘race to the bottom’.

The timing of synoptic assessment was another theme raised by many respondents as being important. It was suggested that having variation in when synoptic assessment takes place could lead to unfairness between apprentices and cause confusion for providers. Some proposed defined assessment windows as a potential mitigation.

Some respondents also commented on the potential for duplication of knowledge and skills across assessments, with several noting that there was a risk that apprentices might fail to demonstrate knowledge and skills during a synoptic assessment which they had successfully demonstrated during previous, non-synoptic assessments. Similarly, some respondents commented on the potential for synoptic assessment to duplicate content that had already been covered in a mandatory qualification taken earlier in the programme.

Some respondents referred to the importance of synoptic assessment being assessed independently of providers so that it maintains reliability and credibility in assessment outcomes.

Question 15
Do you have any further comments on the proposals contained in this section?

There were 76 further comments on the proposals contained in this section. Of these, 58 responses were made on behalf of organisations and 18 from individuals responding in a personal capacity.

Organisation responses comprised:

• 29 awarding organisations, including 8 which offer EPA only
• 9 providers, including private training providers, schools, colleges and higher education institutions
• 9 representative or interest groups
• 5 employers
• 6 other organisations that did not identify with any of the categories above

Of those respondents who provided comments, a majority expressed support for the proposals contained in the assessment structure and synoptic assessment section.

Many of the themes identified in the responses to previous questions in this section were repeated or re-emphasised here. The most common theme was consistency and comparability of assessment. Respondents felt that increased flexibility for awarding organisations could lead to inconsistent interpretations of occupational standards, undermining comparability across sectors. Some of these respondents suggested that Ofqual should provide exemplars of good practice to support consistent implementation of synoptic assessment.

Respondents proposed areas to include in any guidance on the use of synoptic assessment provided by Ofqual, including:

• examples of good practice for integrating synoptic assessment into the wider apprenticeship assessment
• clarification of terminology within the definition of synoptic assessment
• expectations for evidence of decisions taken by awarding organisations
• where and when non-mark-based approaches could be used
• clarification on the timing and scope of synoptic assessment

On the latter point, some respondents felt that clear requirements regarding assessment timing would help to ensure the readiness of apprentices to take their assessments, including any synoptic assessment. Others felt that rigid assessment timings could limit flexibilities and that this could have a particular negative impact on apprentices with additional needs.

As mentioned in the previous question, some respondents suggested that independent oversight and marking of any synoptic assessment would be needed, with several saying this would particularly be the case in high-stakes sectors or those with specific safety considerations. Some respondents warned that relying on providers or employers without expertise in carrying out and marking synoptic assessments could compromise the fairness and reliability of assessment.

Several respondents referred to the apprenticeship assessment plans published by Skills England. Some suggested that any Ofqual guidance on synoptic assessment would need to be aligned with the contents of those plans to avoid duplication or contradiction. Several respondents also sought clarification on what would happen in instances where following Ofqual’s guidance regarding synoptic assessment would mean non-compliance with the apprenticeship assessment plan.

Setting assessments

Question 16
To what extent do you agree or disagree with the proposal that awarding organisations should set all assessments?

Choice	Respondents
Strongly agree	72
Agree	65
Neither agree nor disagree	15
Disagree	17
Strongly disagree	17
Did not answer the question	6

There were 186 responses to this question. Of these, 137 respondents either strongly agreed or agreed with the proposal that awarding organisations should set all assessments. There were 78 responses made on behalf of an organisation, with 44 coming from awarding organisations, 14 of which offer EPA only.

Of the 34 respondents who disagreed or strongly disagreed with the proposal, 20 were organisation responses. These included responses from 2 awarding organisations (one offering EPA only), 6 employers, 5 representative or interest groups, 4 providers, and 3 other organisations that did not identify with any of these categories.

Of the 15 that neither agreed nor disagreed with the proposal, 9 were organisation responses. Two of these were from awarding organisations, none of which offer EPA only.

Question 17
To what extent do you agree or disagree with the proposed definition for setting the assessment?

Choice	Respondents
Strongly agree	36
Agree	97
Neither agree nor disagree	29
Disagree	11
Strongly disagree	10
Did not answer the question	9

There were 186 responses to this question. Of these, 133 respondents either strongly agreed or agreed with our proposed definition for setting the assessment. There were 78 responses made on behalf of an organisation, with 40 coming from awarding organisations, 13 of which offer EPA only.

Of the 21 respondents who disagreed or strongly disagreed with the proposal, 12 of these were organisation responses. These included responses from 4 awarding organisations (one offering EPA only), 3 employers, 3 representative or interest groups, one provider, and one other organisation that did not identify with any of these categories.

Of the 29 respondents that neither agreed nor disagreed with the proposal, 16 were organisation responses. Four of these were from awarding organisations, one of which offers EPA only.

Question 18
To what extent do you agree or disagree with the proposal that centres should be able to adapt certain aspects of awarding organisation-set assessments?

Choice	Respondents
Strongly agree	34
Agree	71
Neither agree nor disagree	28
Disagree	32
Strongly disagree	21
Did not answer the question	6

There were 187 responses to this question. Of these, 105 respondents either strongly agreed or agreed with the proposal that centres should be able to adapt certain aspects of awarding organisation-set assessments. There were 58 responses made on behalf of an organisation, with 19 coming from awarding organisations, 7 of which offer EPA only.

Of the 53 respondents who disagreed or strongly disagreed with the proposal, 28 of these were organisation responses. These included responses from 16 awarding organisations (7 offering EPA only), 5 employers, 4 representative or interest groups, one provider, and 2 other organisations that did not identify with any of these categories.

Of the 28 respondents that neither agreed nor disagreed with the proposal, 21 were organisation responses. Twelve of these were from awarding organisations, none of which offer EPA only.

Question 19
Do you have any comments on the proposals contained in this section?

There were 143 comments on the proposals contained in this section. Of these, 92 responses were made on behalf of organisations and 51 from individuals responding in a personal capacity.

Organisation responses comprised:

• 41 awarding organisations, including 8 which offer EPA only
• 14 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 15 representative or interest groups
• 11 employers
• 11 other organisations that did not identify with any of the categories above

Most respondents indicated that they agreed that awarding organisations should set all assessments. Awarding organisations in particular indicated support for this view, on the grounds that this would ensure valid, reliable and consistent assessment, and command public confidence. Some respondents said this would improve awarding organisations’ accountability.

A smaller number of respondents argued in favour of retaining something closer to the current EPA model, where the assessments are prescribed in the apprenticeship assessment plan, prioritising consistency across all awarding organisations. It was felt that awarding organisations could develop less rigorous assessments to attract customers or inadvertently interpret the same apprenticeship assessment plan differently when designing assessments, leading to variation in the level of demand or scope. It was also suggested that cross-awarding organisation standardisation could be the way to address potential risks to comparability or consistency.  

Most respondents agreed with the proposed definition for setting the assessment, and the areas to be specified by awarding organisations, although a couple queried whether performance or grading criteria should be included, and some respondents noted that not all assessments are timed.

Most respondents commented on the proposal to permit providers to adapt certain aspects of awarding organisation-set assessments.

Respondents commented on the need to balance ensuring that assessments are meaningful and authentic for all students, and are manageable for providers, but not beyond the point where they fail to support transferable occupational competence or where assessments taken with different providers are not sufficiently comparable.  

Some respondents argued that providers should never be permitted to adapt assessments whereas others argued that provider adaptations could have benefits.

The most common concern raised about allowing providers to adapt some aspects of assessments was the potential risk to consistency and comparability. This was mentioned by most awarding organisations. Some of those respondents also mentioned risks to safety, fairness, and public confidence in apprenticeship assessments as well as providing an increased burden for awarding organisations.

Some respondents offered views on how these risks could be mitigated, which included placing requirements on awarding organisations to:

• approve or quality assure any adaptations proposed by providers
• monitor all adaptations made by providers
• provide guidance and/or support to providers on adaptations that are permissible, noting that this would also allow for regulatory scrutiny

Alternatively, some respondents suggested that Ofqual itself should be responsible for monitoring provider adaptations and providing further guidance to both awarding organisations and providers.

Some respondents saw benefits in terms of manageability, authenticity, and accessibility, particularly for apprentices with additional needs or in sectors where equipment can vary between employers.

Some respondents suggested that adaptations should be limited to reasonable adjustments only, to mitigate risks to comparability. It was also suggested that awarding organisations should have a responsibility to design assessments in a way that enables them to be delivered flexibly across a variety of settings, rather than relying on providers to adapt tasks.

Other suggestions for mitigating risks arising from permitting centre adaptations included limiting them to only small elements of the overall assessment, or by specifying that some core elements could not be adapted. Several respondents noted that it was important that adaptations were contextual only, or related to tools used, rather than substantive.

Some respondents made comments that were out of scope of the question, many commenting on the role of employers and the verification of behaviours.

Marking assessments

Question 20
To what extent to you agree or disagree with the proposal to require awarding organisations to mark some apprenticeship assessments to mitigate against threats we have identified to the reliability of the assessments?

Choice	Respondents
Strongly agree	93
Agree	58
Neither agree nor disagree	13
Disagree	13
Strongly disagree	10
Did not answer the question	5

There were 187 responses to this question. Of these, 151 respondents either strongly agreed or agreed with the proposal to require awarding organisations to mark some apprenticeship assessments to mitigate against threats we have identified to the reliability of assessments. There were 86 responses made on behalf of an organisation, 43 coming from awarding organisations, 11 of which offer EPA only.

Of the 23 respondents who disagreed or strongly disagreed with the proposal, 16 of these were organisation responses. These included responses from 5 awarding organisations (4 offering EPA only), 3 employers, 2 representative or interest groups, 4 providers, and 2 other organisations that did not identify with any of these categories.

Of the 13 respondents that neither agreed nor disagreed with the proposal, 6 were organisation responses, none of which were from awarding organisations.

Question 21
Do you have any comments on the proposal to issue Ofqual guidance in relation to the marking of assessments? Please specify any areas that you think that it would be helpful to include in the guidance.

There were 127 comments on the proposal to issue Ofqual guidance in relation to the marking of assessments. Of these, 84 responses were made on behalf of organisations and 43 from individuals responding in a personal capacity.

Organisation responses comprised:

• 41 awarding organisations, including 13 which offer EPA only
• 14 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 13 representative or interest groups
• 7 employers
• 9 other organisations that did not identify with any of the categories above

Most respondents took the opportunity to express concerns about permitting awarding organisations to allow providers to mark some assessment, and whether the 40% indicative figure for marking by the awarding organisation was sufficient. Some of those respondents wanted clarity on how 40% marking by the awarding organisation should be determined.

Respondents commented on risks related to reliability and comparability of assessment if centre marking is permitted and there is a lack of independence of assessment. There was concern that this represented a backward step for apprenticeship assessment.

Awarding organisations only offering EPA said that permitting centre marking should be optional and not mandatory. Awarding organisations in general were concerned about the capability and capacity of providers to manage marking effectively and questioned whether the reforms were adding burden and cost without any clear benefit.

Many respondents commented on the proposed indicative figure of 40% marking by the awarding organisation. They said that 40% was too low to be ‘substantial’ and that 100% awarding organisation marking should remain permissible. Respondents also asked what was meant by 40% and how this could be calculated.

There was broad support for Ofqual issuing guidance in relation to the marking of assessments, and respondents provided a range of areas that they thought would be helpful to include:

• clarification on what is meant by awarding organisations providing ‘appropriate oversight’ of centre marking
• clarification on the type of training that should be undertaken by provider staff – this was considered vital for awarding organisations unfamiliar with centre marking
• a focus on smaller providers and support for smaller employers
• guidance on the use of digital assessment methods, including broader considerations around the risks of artificial intelligence (AI)

Some respondents asked for guidance on how awarding organisations could tailor assessments to different employers for the same standard, while remaining compliant with Ofqual’s rules, although this was out of scope for this particular question.

Question 22
To what extent do you agree or disagree with the proposal to require awarding organisations to have regard to any marking approach specified in an apprenticeship assessment plan published by Skills England?

Choice	Respondents
Strongly agree	60
Agree	91
Neither agree nor disagree	22
Disagree	9
Strongly disagree	4
Did not answer the question	6

There were 186 responses to this question. Of these, 151 respondents either strongly agreed or agreed with the proposal to require awarding organisations to have regard to any marking approach specified in an apprenticeship assessment plan published by Skills England. There were 86 responses made on behalf of an organisation, with 41 coming from awarding organisations, 13 of which offer EPA only.

Of the 13 respondents who disagreed or strongly disagreed with the proposal, 9 of these were organisation responses. These included responses from 4 awarding organisations (2 offering EPA only), 3 employers, and 2 representative or interest groups.

Of the 22 respondents that neither agreed nor disagreed with the proposal, 12 were organisation responses. Three of these were from awarding organisations, none of which offer EPA only.

Question 23
Do you have any comments on the proposal to issue Ofqual guidance in relation to Condition H2 (Centre Assessment Standards Scrutiny where an assessment is marked by a Centre)? Please specify any areas that you think that it would be helpful to include in the guidance.

There were 101 comments in response to this proposal. Of these, 70 responses were made on behalf of organisations and 31 from individuals responding in a personal capacity.

Organisation responses comprised:

• 37 awarding organisations, including 11 which offer EPA only
• 11 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 8 representative or interest groups
• 8 employers
• 6 other organisations that did not identify with any of the categories above

When answering this question, respondents often re-stated points made in answer to previous questions regarding their preference for awarding organisation marking of assessments rather than centre marking, citing the risks associated with that.

Some respondents commented on DfE’s assessment principles in relation to centre marking, expressing the view that it should be permitted in apprenticeship assessment plans but not mandated.

Employers who responded generally did not support centre marking and expressed views that this could introduce too much variability in the way assessment takes place which could have a negative effect on the performance standards required by their respective industries.

Awarding organisations offering only EPA expressed uncertainty about whether Centre Assessment Standards Scrutiny (CASS) requirements would be mandatory, even in cases where centre marking was not specified in the apprenticeship assessment plan. Concerns were consistently raised about the potential disproportionate cost and administrative burden of implementing CASS, particularly for smaller awarding organisations.

Awarding organisations that already use CASS for other qualifications were generally confident about applying the CASS requirements to apprenticeship assessment, although they recognised they would still need to adapt their processes. Awarding organisations also commented on the potential disruption for providers as well as for apprentices that might arise from unfamiliarity with CASS.

Respondents were supportive of Ofqual’s proposal to issue guidance on CASS and suggested a range of areas that could be included, such as:

• templates that could be readily adapted by awarding organisations for providers new to centre marking and the CASS requirements
• further detail on CASS sampling requirements, particularly in relation to frequency and scope
• case studies to support understanding and compliance with CASS requirements including the use of positive and negative indicators for compliance
• clarity on how marking responsibilities should be managed when both the awarding organisation and a provider are carrying out aspects of the apprenticeship assessment marking together
• clarity on how CASS requirements might be applied across multiple apprenticeship standards delivered by the same provider

There were a mix of responses about what form the guidance might take. Some respondents suggested a significant level of prescription to take account of less detailed apprenticeship assessment plans, while others commented that the guidance should be high level and avoid duplicating existing CASS guidance. There was a consensus that any guidance should not overwhelm smaller awarding organisations.

Question 24
Do you have any comments on the proposal to issue Ofqual guidance in relation to Condition C2 (Arrangements with Centres)? Please specify any areas you think that it would be helpful to include in the guidance.

There were 78 comments in response to this proposal. Of these, 63 responses were made on behalf of organisations and 15 from individuals responding in a personal capacity.

Organisation responses comprised:

• 36 awarding organisations, including 10 which offer EPA only
• 8 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 7 employers
• 5 other organisations that did not identify with any of the categories above

Again, respondents took the opportunity to raise concerns about centre marking in general, and restated comments made in response to previous questions in this section. A common theme in the responses was the impact and cost of the shift to centre marking, with suggestions that this had not been sufficiently factored into DfE’s reform proposals.

Respondents had a range of ideas on what it would be helpful to include in guidance. Awarding organisations suggested that the guidance includes:

• templates or example agreements since this would be particularly helpful for smaller awarding organisations that may not have worked with providers previously
• detailed, apprenticeship-specific guidance, which clearly identifies risks linked to centre marking and how these could be effectively mitigated
• detail on appropriate sanctions where providers fail to comply with agreements.

Some respondents were particularly concerned that the guidance should clearly address conflicts of interest, including how these should be identified and effectively managed.

Most employers who responded said they preferred that awarding organisations marked the assessment. However, they supported the proposal for additional guidance and emphasised the importance of safeguarding and data security to be included in any apprenticeship-specific guidance.

Representative and interest groups expressed support for guidance, while emphasising the importance that it remains proportionate, and not unduly burdensome.

Question 25
Do you have any further comments on the proposals contained in this section?

There were 65 further comments on the proposals contained in the marking assessments section. Of these, 50 responses were made on behalf of organisations and 15 from individuals responding in a personal capacity.

Organisation responses comprised:

• 23 awarding organisations, including 6 which offer EPA only
• 7 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 10 representative or interest groups
• 5 employers
• 5 other organisations that did not identify with any of the categories above

Of those respondents who provided comments, a majority expressed support for the proposals contained in the marking assessments section.

There were comments about the implementation timetable for the reforms and the challenges the current uncertainty was posing for the market.

Respondents re-stated several of the concerns and risks raised in previous responses to proposals on marking assessments which included:

• concerns about the proposed 40% indicative marking figure by awarding organisations which was considered too low to safeguard the reliability of apprenticeship assessments
• the risks related to centre marking and the impact this could have on public confidence in apprenticeship assessments
• concerns about the impact on employers particularly in relation to any role they might have in marking assessments

As with previous responses, there was an emphasis on the need to support smaller and specialist awarding organisations who it was thought would face challenges adapting to the reforms. We were also asked to provide support for smaller providers, to support them to build capacity and capability in marking assessments, and employers, to support them in engaging competently and confidently in assessment processes.

Assessment design

Question 26
Do you have any comments on the proposal to issue Ofqual guidance in relation to assessment design? Please specify any areas you think that it would be helpful to include in the guidance.

There were 121 comments on this proposal. Of these, 80 responses were made on behalf of organisations and 41 were personal responses.

Organisation responses comprised:

• 39 awarding organisations, including 11 which offer EPA only
• 13 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 12 representative or interest groups
• 8 employers
• 8 organisations that did not identify with any of the categories above

A recurring theme in the responses to this question was that any Ofqual issued guidance could be a useful tool to promote consistency across awarding organisations in relation to their apprenticeship assessment design decisions.

Respondents also said that any guidance that Ofqual issues should be fully aligned and compatible with any other guidance issued by Skills England about its apprenticeship assessment plans.

Respondents suggested areas that could be included in guidance in addition to those areas that Ofqual had included in its consultation (consideration of content, assessment structure, when assessment takes place and the approach to marking, including in relation to ensuring the authenticity of assessment evidence). The following areas were proposed for inclusion in guidance:

• determining valid and reliable assessment methods – for example, when knowledge-based assessments, practical demonstrations, and professional discussions might be used
• sampling knowledge and skills statements – both in terms of frequency and how this might operate in practice
• assessment methods – similar to the first point, guidance was sought on selecting appropriate and inappropriate methods based on the nature of the knowledge and skills being assessed
• assessment resits and resubmissions – having clear and consistent resit or resubmission policies were seen by some as essential since unlimited attempts at assessment are seen to undermine apprenticeship outcomes and can increase costs
• on-programme assessment – advice on how the synoptic element of apprenticeship assessment could be designed to be a natural culmination of the on-programme journey, rather than a disconnected final hurdle

Some respondents said that guidance alone would be insufficient or would not address the risk of inconsistent approaches to assessment design across awarding organisations. A few respondents said that apprenticeship assessment should take the form of end-point assessment only.

Some respondents made comments that were out of scope of the question, many referring to the need for guidance in relation to Skills England’s apprenticeship assessment plans.

Question 27
To what extent do you agree or disagree that awarding organisations must comply with any requirements related to assessment design in an apprenticeship assessment plan published by Skills England?

Choice	Respondents
Strongly agree	78
Agree	86
Neither agree nor disagree	12
Disagree	4
Strongly disagree	3
Did not answer the question	9

There were 183 responses to this question. Of these, 164 respondents either strongly agreed or agreed with the proposal that awarding organisations must comply with any requirements related to assessment design in an apprenticeship assessment plan published by Skills England. There were 92 responses made on behalf of an organisation, with 42 coming from awarding organisations, 14 of which offer EPA only.

Of the 7 respondents who disagreed or strongly disagreed with the proposal, 6 of these were organisation responses. These included responses from 2 awarding organisations (one offering EPA only), 2 employers, and 2 representative or interest groups.

Of the 12 respondents that neither agreed nor disagreed with the proposal, 6 were organisation responses. Three of these were from awarding organisations, none of which offer EPA only.

Question 28
Do you have any further comments on the proposals contained in this section?

There were 69 further comments on the proposals contained in the assessment design section. Of these, 55 responses were made on behalf of organisations and 14 were personal responses.

Organisation responses comprised:

• 28 awarding organisations, including 8 which offer EPA only
• 6 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 11 representative or interest groups
• 6 employers
• 4 organisations that did not identify with any of the categories above

There were 3 common themes in the responses to this question, outlined below.

1. Skills England’s apprenticeship assessment plans should be more prescriptive than the example provided in the consultation. This was to support consistency across awarding organisations in terms of their assessment design, to support comparability across awarding organisations (especially when more than one awarding organisation is offering apprenticeship assessment for the same occupational standard), and that more prescriptive apprenticeship assessment plans would support reliability and robustness of assessments.

2. Inconsistent approaches across awarding organisations in relation to their apprenticeship assessment design decisions, could lead to unfairness for apprentices depending on the approach taken by their awarding organisation.

3. There should be less ambiguity and more clarity on some of the requirements included in the new style apprenticeship assessment plan. Skills England should put in place clear boundaries and guidance to prevent excessive variation, thereby undermining comparability and equity across different awarding organisations in their assessment design, with some respondents referencing the 7 foundation apprenticeship assessment plans already published by Skills England when raising concerns about a lack of clarity.

Some respondents made comments that were out of scope of the question, many expressing disagreement with the DfE’s policy decision to move away from the EPA model.

Grading and standard setting

Question 29
To what extent do you agree or disagree that awarding organisations must comply with the grading scale and description of the characteristics of a pass grade (and any other grade) included in an apprenticeship assessment plan published by Skills England?

Choice	Respondents
Strongly agree	84
Agree	82
Neither agree nor disagree	12
Disagree	5
Strongly disagree	4
Did not answer the question	5

There were 187 responses to this question. Of these, 166 respondents either strongly agreed or agreed with the proposal that awarding organisations must comply with the grading scale and description of the characteristics of a pass grade (and any other grade) included in an apprenticeship assessment plan published by Skills England. There were 94 responses made on behalf of an organisation, with 40 coming from awarding organisations, 14 of which offer EPA only.

Of the 9 respondents who disagreed or strongly disagreed with the proposal, 6 of these were organisation responses. These included responses from 3 awarding organisations (one offering EPA only), 2 employers, and one representative or interest group.

Of the 12 respondents that neither agreed nor disagreed with the proposal, 8 were organisation responses. Five of these were from awarding organisations, none of which offer EPA only.

Question 30
Do you have any comments on the proposal to issue Ofqual guidance to support awarding organisations to take consistent approaches to standard setting? Please specify any areas you think that it would be helpful to include in the guidance.

There were 103 comments in response to this proposal. Of these, 71 responses were made on behalf of organisations and 32 from individuals responding in a personal capacity.

Organisation responses comprised:

• 37 awarding organisations, including 10 which offer EPA only
• 7 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 12 representative or interest groups
• 8 employers
• 7 other organisations that did not identify with any of the categories above

There were 2 related themes in the responses to this question:

• the need to have robust performance descriptors on which reliable standards can be based
• that all necessary steps are taken to reduce variability and to promote consistency to standard setting.

Respondents said that guidance should be robust enough to support consistent and reliable standard setting across awarding organisations offering apprenticeship assessment for the same occupational standard. It was also suggested that the guidance should be tailored to different sectors, occupational standards and assessment methods.

Guidance from Ofqual was seen as just one way of helping to achieve comparability. Respondents also pointed out the role of Skills England in helping to achieve consistent approaches to standard setting, with some respondents referencing the foundation apprenticeship assessment plans that had been published, stating that they currently lack sufficient detail for awarding organisations to reliably set standards.

Some respondents made comments that were out of scope of the question, including commenting on the grading scales referred to in Skills England’s apprenticeship assessment plans, rather than to standard setting.

Question 31
Do you have any further comments on the proposals contained in this section?

There were 59 further comments on the proposals in this section. Of these, 44 responses were made on behalf of organisations and 15 from individuals responding in a personal capacity.

Organisation responses comprised:

• 19 awarding organisations, including 10 which offer EPA only
• 5 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 7 employers
• 6 other organisations that did not identify with any of the categories above

Many of the comments made in response to the previous question were repeated for this question.

The most common themes in responses to this question were:

• the need for robust and transparent standard setting and grading descriptors if apprenticeship outcomes are to be reliable and retain user and public confidence
• the need for robust guidance that promotes consistency of approach across awarding organisations and across sectors to support this.

Some respondents made comments that were out of scope of the question, including commenting on the grading scales in the current assessment plans, not about Ofqual’s approaches to grading and standard setting. These respondents, often employers and representative groups, said that a ‘pass or fail’ grading scale should be used for apprenticeship assessment because it is assessing competence. Other grading scales were seen as undermining safety and quality, particularly in roles where public trust and confidence is paramount.

Assessment strategy requirements

Question 32
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 for each apprenticeship assessment they offer?

Choice	Respondents
Strongly agree	70
Agree	87
Neither agree nor disagree	16
Disagree	6
Strongly disagree	8
Did not answer the question	5

There were 187 responses to this question. Of these, 157 respondents either strongly agreed or agreed with the proposal to require awarding organisations to develop, follow, and keep under review an assessment strategy for each apprenticeship assessment they offer. There were 92 responses made on behalf of an organisation, with 45 coming from awarding organisations, 15 of which offer EPA only.

Of the 14 respondents who disagreed or strongly disagreed with the proposal, 8 of these were organisation responses. These included responses from 2 awarding organisations (neither of which offer EPA only), 2 employers, 2 representative or interest groups, one educational institution, and one other organisation that did not identify with any of these categories.

Of the 16 respondents that neither agreed nor disagreed with the proposal, 8 were official responses. One organisation response was from an awarding organisation, which is not offering EPA only.

Question 33
Do you have any comments on the areas proposed to be covered in assessment strategies?

There were 83 comments in response to the proposed areas to be covered in assessment strategies. Of these, 61 responses were made on behalf of organisations and 22 from individuals responding in a personal capacity.

Organisation responses comprised:

• 33 awarding organisations, including 8 which offer EPA only
• 10 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 8 representative or interest groups
• 5 employers
• 5 other organisations that did not identify with any of the categories above

Many respondents highlighted the importance of there being sufficient detail about what an assessment strategy should include, and that until the full guidance is published, it would be difficult to understand the extent of what will be required.

Respondents suggested specific areas where they would welcome additional guidance, including:

• illustrative examples, templates and guidance on the expected structure and length of assessment strategies – awarding organisations said that similar guidance to that which Ofqual publishes for other qualifications would be helpful
• clarity on expectations relating to the use of centre marking, including the use of guidance and exemplification materials for providers, minimum expectations for quality assurance and how and when awarding organisations can overrule centre decisions, and expectations around centre training and standardisation
• how awarding organisations should explain their approach to accessibility and inclusivity as part of their assessment design, as well as their approach to reasonable adjustments
• how awarding organisations should explain their approaches to managing AI risks and the impacts of this on assessment authenticity – there were also requests for guidance on the use of digital tools and workplace technologies more generally
• what an assessment strategy should explicitly cover to demonstrate how assessment secures accurate judgements of occupational competence and how an awarding organisation should set standards
• how awarding organisations should use data to monitor assessment performance
• expectations around resits and retakes

Some respondents made comments about how assessment strategies might be structured, and how occupation-specific aspects should be covered. These comments included:

• requests for clarity about the ‘level’ at which assessment strategies should be written – standard, sector, or assessment method (some awarding organisations suggested assessment strategies should be overarching, with separate annexes for each occupational standard, with others suggesting they should be developed for groups of occupational standards or assessment methods and applied to apprenticeships as relevant, and a small number of respondents [most of whom were not awarding organisations] suggesting assessment strategies should be developed for each apprenticeship, and information should not simply be copied across between occupational standards)
• that assessment strategies should be developed in conjunction with specialists from education and industry, with awarding organisations explaining how employers, providers, and apprentices will be consulted during the design and review stages

Some respondents also made comments relating to consistency and/or comparability between awarding organisations, and how to ensure the quality and accountability of apprenticeships. These included that:

• assessment strategies could support quality and accountability, and that requiring awarding organisations to explain their approach would enable better scrutiny, quality assurance, and strengthen delivery
• assessment strategies could help secure consistency – respondents said this would be even more important with the introduction of centre-led assessment
• writing an assessment strategy would provide assurance that an awarding organisation’s assessments are adequately mapped against the requirements set out in the occupational standard – respondents said the need to keep the assessment strategy under review would ensure that apprenticeship assessments remain current and responsive to changes to standards
• assessment strategies would provide Ofqual an opportunity to compare approaches across awarding organisations, which would be important given the removal of detail from apprenticeship assessment plans – some respondents asked how Ofqual would review assessment strategies and how Ofqual would monitor assessment data to identify inconsistencies across awarding organisations

Some respondents made comments about the potential burden of the assessment strategy requirement. Comments included:

• that developing, following and keeping under review an assessment strategy would be a significant administrative burden, particularly if separate strategies are required for each occupational standard and the awarding organisation offers multiple occupational standards – respondents said the burden could be mitigated to some extent by having high-level, rather than prescriptive requirements
• that while assessment strategies would impose a significant burden, they would also force awarding organisations to consider vital elements of design, delivery and award
• that requiring assessment strategies, combined with a reduction in the level of detail in apprenticeship assessment plans, shifts the burden of assessment considerations onto awarding organisations
• that the burden would be greater on smaller awarding organisations with fewer resources, and on awarding organisations offering EPAs only, who may not be used to such requirements

Some respondents made comments that were out of scope of the question, including comments on Skills England’s plans for higher-level apprenticeship assessment plans.

Question 34
Do you have any further comments on the proposals contained in this section?

There were 50 further comments in response to the proposals contained in the section on assessment strategy requirements. Of these, 42 responses were made on behalf of organisations and 8 from individuals responding in a personal capacity.

Organisation responses comprised:

• 25 awarding organisations, including 8 which offer EPA only
• 3 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 5 employers
• 2 other organisations that did not identify with any of the categories above

Of those respondents who provided further comments, a majority expressed support for the proposals on assessment strategy requirements.

Many respondents (including most awarding organisations) suggested examples, guidance or support they would like to see regarding assessment strategies. These included:

• requests for as much guidance as possible, along with templates and an indication of the level of detail required in each section of the assessment strategy – there was also a request for any expectations to be high-level and principles-based, rather than detailed and prescriptive
• a ‘frequently asked questions’ section for each occupational standard to help awarding organisations develop their assessment strategies
• a suggestion that guidance should align where possible with that already in place for other qualifications
• training and support from Ofqual for those awarding organisations who are new to assessment strategies, including feedback on draft assessment strategies (while recognising it would be unmanageable for Ofqual to review all assessment strategies up front)
• early monitoring which focusses on supporting compliance and providing additional support
• information about the level of evidence Ofqual would require from an awarding organisation where it wishes to amend its assessment strategy

Some respondents, most of whom were awarding organisations, said that if all assessment strategies were not reviewed up front, there was a risk of non-compliance in reformed apprenticeship assessments. Suggested mitigations were for Ofqual to put in place early monitoring activities to support compliance.

Some respondents, most of whom were awarding organisations or representative or interest groups, commented on potential regulatory burden, stating that:

• assessment strategy requirements would be particularly burdensome for those awarding organisations offering EPA only and that they could serve as a barrier to entry for new, smaller or niche awarding organisations (it was thought requiring separate strategies for each occupational standard would be burdensome, with some respondents thinking awarding organisations should be permitted to create an overarching assessment strategy, with any standard or assessment-specific aspects appended as annexes and others expressing the opposite view that there should be a separate assessment strategy for each apprenticeship)
• requiring assessment strategies, but not doing up front checks, subjects awarding organisations offering apprenticeship assessment to the same level of burden as for non-apprenticeship qualifications, but without the advantages of an Ofqual review prior to delivery

A small number of respondents suggested that awarding organisations should be required to share assessment strategies with providers and employers.

Several respondents made comments which did not directly relate to the proposals for assessment strategy requirements, commenting instead on overall changes to the apprenticeship assessment model and timelines for introducing the changes.

Employer engagement

Question 35
To what extent do you agree or disagree with the proposal not to disapply Condition E1 for apprenticeship assessments?

Choice	Respondents
Strongly agree	43
Agree	71
Neither agree nor disagree	35
Disagree	19
Strongly disagree	20
Did not answer the question	4

There were 188 responses to this question. Of these, 114 respondents either strongly agreed or agreed with the proposal not to disapply Condition E1 for apprenticeship assessments. There were 75 responses made on behalf of an organisation, with 30 coming from awarding organisations, 8 of which offer EPA only.

Of the 39 respondents who disagreed or strongly disagreed with the proposal, 17 of these were organisation responses. These included responses from 12 awarding organisations (5 of which offer EPA only), 2 employers, one representative or interest group, one educational institution, and one other organisation that did not identify with any of these categories.

Of the 35 respondents that neither agreed nor disagreed with the proposal, 17 were organisation responses. Six organisation responses were from awarding organisations, 2 of which offer EPA only.

Question 36
Do you have any comments on the proposal to issue Ofqual guidance to support awarding organisations to engage with employers effectively when designing apprenticeship assessments? Please specify any areas you think that it would be helpful to include in the guidance.

There were 123 comments in response to this proposal. Of these, 83 responses were made on behalf of organisations and 40 from individuals responding in a personal capacity.

Organisation responses comprised:

• 39 awarding organisations, including 11 which offer EPA only
• 13 providers, including private training providers, schools, colleges, higher education institutions and local authorities

14 representative or interest groups

• 9 employers
• 6 other organisations that did not identify with any of the categories above

There were 4 themes in responses to this question:

• the need to ensure that small and medium-sized enterprises (SMEs) are included in employer engagement processes – respondents noted that SMEs are often underrepresented and face barriers to participation
• Trailblazer groups and industry sector skills bodies that already provide employer input and should be leveraged more effectively – some suggested that additional engagement at the assessment design phase would be ineffective
• there was concern that requiring awarding organisations to demonstrate ongoing employer engagement would add unnecessary complexity, cost, and regulatory burden especially when employer input is already embedded in apprenticeship assessment plans
• queries on how sufficient employer engagement would be demonstrated, measured and enforced

While there was broad agreement that employer involvement is critical for apprenticeships, concerns were raised by awarding organisations about how this should be implemented. Comments included:

• most employers are not assessment specialists, and that Ofqual guidance should set out practical expectations around the nature and level of engagement required to ensure that it is meaningful, consistent and proportionate across sectors
• existing Trailblazer groups and industry sector and professional bodies, co-ordinated by Skills England should be utilised as this approach avoids duplication and reduces burden
• the requirement for individual awarding organisations to engage employers separately could undermine the credibility of national standards and lead to fragmented interpretations of assessment outcomes
• that employer engagement is costly, time-consuming and burdensome, particularly for smaller employers and awarding organisations

Ofqual was asked to provide exemplars of best practice when helping awarding organisations to engage effectively with employers when designing assessments.

Representative or interest groups said that it was important to ensure that engagement is meaningful, proportionate, consistent, representative and manageable across sectors, especially for SMEs. Respondents commented that:

• guidance alone is not sufficient – there must be formal expectations around the number of employers to be consulted, their representativeness across the sector, and what constitutes sufficient employer engagement
• engagement processes must be simple and accessible, especially for SMEs, since complex or resource-heavy engagement risks excluding SMEs
• sector skills bodies represent employers across sectors, both large and small, and are well-placed to be able to engage in strategic and technical discussions about the nature of assessment – their involvement can help ensure timely and informed engagement without overburdening individual employers

Employer respondents commented that:

• Trailblazer groups should be the starting point for awarding organisations to ensure assessments are credible and efficient
• employers possess deep industry knowledge and have historically contributed to occupation standards and assessment plans, and should be provided with the opportunity to engage in ways that allow meaningful contribution

Question 37
Do you have any further comments on the proposals contained in this section?

There were 64 further comments in response to the proposals on employer engagement. Of these, 48 responses were made on behalf of organisations and 16 from individuals responding in a personal capacity.

Organisation responses comprised:

• 18 awarding organisations, including one which offers EPA only
• 5 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 14 representative or interest groups
• 6 employers
• 5 other organisations that did not identify with any of the categories above

There were 3 themes in the responses to this question, that were similar to the responses in the previous question:

• that the Trailblazer and industry sector skills bodies that already provide employer input should be leveraged more effectively
• that requiring awarding organisations to demonstrate ongoing employer engagement would add unnecessary complexity, cost, and regulatory burden, especially when employer input is already embedded in apprenticeship assessment plans
• queries about how sufficient employer engagement would be demonstrated, measured and enforced

As with the previous question, there was also broad agreement that employer involvement is critical for apprenticeships, and several suggestions were provided on how this could be implemented. Awarding organisations highlighted the following areas – not all within the purview of Ofqual:

• the need for detailed guidance on how apprenticeship assessment plans will be reviewed and refreshed over time – it was thought that a cyclical review process, developed in collaboration with awarding organisations and employer representatives, would help ensure assessments remain current and aligned with industry needs
• challenges related to reconciling the diverse views of employers and managing conflicts of interest
• inconsistent engagement across awarding organisations could lead to a lack of standardisation, with different assessment designs emerging for the same apprenticeship

While the importance of employer involvement in assessment design was acknowledged and supported, there was some opposition to mandating employer engagement specifically at the assessment design stage.

Representative or interest groups re-stated that employer engagement in apprenticeship assessment must be meaningful, proportionate, anchored in sector standards and guided by clear boundaries. It was argued that this would mitigate against inconsistency and administrative burden. Comments included:

• Trailblazer groups should remain central to apprenticeship assessment, as they already represent a balanced mix of employers and ensure alignment with occupational standards
• mandating broad employer consultation risks inconsistency, administrative burden, and conflict of interest; especially without clear guidance or safeguards
• Ofqual must provide clear, proportionate guidance on employer engagement, emphasising meaningful input, avoiding tokenism, and ensuring consistency across sectors and different sizes of organisation
• while retaining Condition E1 aligns with proposed changes to apprenticeship assessment, it is essential to recognise that apprenticeships are fundamentally different from qualifications; they are jobs with training – it was thought that Ofqual should carefully consider the impact of applying qualification-style regulation to apprenticeships, ensuring that any changes preserve their unique value to employers and apprentices

Employers commented that:

• Trailblazer groups have already designed assessments collaboratively with employers, providers, awarding organisations, and professional bodies thus ensuring consistency, efficiency, and stakeholder confidence
• not disapplying Condition E1 could duplicate existing work, strain employer resources, and introduce risks of inconsistency in assessment approaches
• the current EPA model provides a unified statutory framework and supports professional recognition, aligning assessment with nationally and internationally defined competence outcomes

Disapplication of General Conditions

Question 38
To what extent do you agree with the proposal to disapply General Condition E7 (Total Qualification Time) with respect to apprenticeship assessment?

Choice	Respondents
Strongly agree	49
Agree	83
Neither agree nor disagree	41
Disagree	5
Strongly disagree	6
Did not answer the question	8

There were 184 responses to this question. Of these, 132 respondents either strongly agreed or agreed with the proposal to disapply General Condition E7 (Total Qualification Time) with respect to apprenticeship assessment. There were 79 responses made on behalf of an organisation, with 45 coming from awarding organisations, 13 of which offer EPA only.

Of the 11 respondents who disagreed or strongly disagreed with the proposal, 7 were organisation responses. These included responses from an awarding organisation offering EPA only, 3 employers, 2 representative or interest groups, and one other organisation that did not identify with any of these categories.

Of the 41 respondents that neither agreed nor disagreed with the proposal, 19 were organisation responses. Two organisation responses were from awarding organisations, one which is offering EPA only.

Question 39
To what extent do you agree with the proposal to disapply General Condition E8 (Component credit) with respect to apprenticeship assessment?

Choice	Respondents
Strongly agree	47
Agree	79
Neither agree nor disagree	43
Disagree	9
Strongly disagree	4
Did not answer the question	10

There were 182 responses to this question. Of these, 126 respondents either strongly agreed or agreed with the proposal to disapply General Condition E8 (Component credit) with respect to apprenticeship assessment. There were 75 responses made on behalf of an organisation, with 45 coming from awarding organisations, 13 of which offer EPA only.

Of the 13 respondents who disagreed or strongly disagreed with the proposal, 11 of these were organisation responses. These included responses from 3 employers, 3 representative or interest groups, 2 educational institutions, and 3 other organisations that did not identify with any of these categories. There were no awarding organisations that disagreed or strongly disagreed with this proposal.

Of the 43 respondents that neither agreed nor disagreed with the proposal, 18 were organisation responses. Three organisation responses were from awarding organisations, 2 of which offer EPA only.

Question 40
To what extent do you agree with the proposal to disapply General Conditions I3 and I4 (Certification) with respect to apprenticeship assessment?

Choice	Respondents
Strongly agree	41
Agree	76
Neither agree nor disagree	56
Disagree	6
Strongly disagree	4
Did not answer the question	9

There were 183 responses to this question. Of these, 117 respondents either strongly agreed or agreed with the proposal to disapply General Conditions I3 and I4 (Certification) with respect to apprenticeship assessment. There were 73 responses made on behalf of an organisation, with 41 coming from awarding organisations, 12 of which offer EPA only.

Of the 10 respondents who disagreed or strongly disagreed with the proposal, 5 of these were organisation responses. These included responses from an awarding organisation that does not offer EPA only, one employer, 2 representative or interest groups, and one other organisation that did not identify with any of these categories.

Of the 56 respondents that neither agreed nor disagreed with the proposal, 27 were organisation responses. Six organisational responses were from awarding organisations, 3 which offer EPA only.

Question 41
Do you have any comments on the proposals contained in this section?

There were 48 comments on proposals in this section. Of these, 33 responses were made on behalf of organisations and 15 from individuals responding in a personal capacity.

Organisation responses comprised:

• 14 awarding organisations, including 6 which offer EPA only
• 6 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 5 representative or interest groups
• 5 employers
• 3 other organisations that did not identify with any of the categories above

Respondents noted that the proposed disapplications would reduce administrative burden on awarding organisations, support a streamlined and coherent regulatory framework, and align regulation with how apprenticeships are delivered and funded.

Condition E7 was widely seen as redundant, as apprenticeship duration is already defined by occupational standards and funding rules. For Condition E8, most agreed that credit systems are incompatible with the holistic, synoptic nature of apprenticeship assessment. For Conditions I3 and I4, respondents noted that apprenticeship certification is already managed by the DfE, and disapplication avoids duplication.

A few respondents questioned why Condition E9 (Qualification and Component levels) was not proposed for disapplication, since it is already disapplied under EPA. It was pointed out that Skills England sets the level of the apprenticeship in the occupational standard, and that this arrangement would not be changing.

A recurring concern from respondents, particularly from employers, was the lack of recognition for partial achievement of an apprenticeship. Several respondents advocated for processes to acknowledge progress if an apprentice does not complete the full programme, especially for long-duration apprenticeships or where apprentices leave due to circumstances beyond their control.

Guidance in the current EPA regulatory framework

Question 42
Do you have any comments on whether Ofqual should carry forward any of the EPA guidance into the regulatory framework for apprenticeship assessment? Please specify which guidance you think that it would be helpful to carry forward.

There were 103 comments on whether Ofqual should carry forward any of the EPA guidance into the regulatory framework for apprenticeship assessment. Of these 73 responses were made on behalf of organisations and 30 from individuals responding in a personal capacity.

Organisation responses comprised:

• 43 awarding organisations, including 12 which offer EPA only
• 7 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 8 representative or interest groups
• 7 employers
• 8 other organisations that did not identify with any of the categories above

There was broad consensus across respondents that the following areas of the current EPA guidance should be carried forward:

• Compliance with assessment plans – respondents viewed this as critical for ensuring assessments align with occupational standards
• Conflict of interest – respondents emphasised this is essential to maintain assessment integrity, particularly if providers are more involved in assessment delivery
• Transitioning between versions of assessment plans – respondents highlighted the importance for managing change without disadvantaging apprentices
• Qualification titling and specifications – respondents said that consistent titling and specifications maintain clarity and comparability with other qualifications
• Issuing results – respondents said that timely and transparent result processes are valued for apprentice progression and employer confidence
• Reviewing approach – respondents said that it encourages regular updates to assessment strategies to reflect sector needs

Many respondents called for a comprehensive review and update of the existing guidance to ensure it aligns with the evolving apprenticeship assessment model and that it avoids duplication.

Some respondents said that they needed further clarity on the draft regulatory framework before they could offer informed comments about what should be included the guidance.

Some respondents commented that guidance would be important in maintaining consistency across awarding organisations to ensure fairness for apprentices.

There were also requests for further guidance and clarity, especially around scrutiny of centre-marking and centre arrangements.

Some responses were out of scope of the question, focusing on broader issues such as the separation of training and assessment, the role of Gateway, and expressing general support for independent assessment.

Transition arrangements

Question 43
Do you have any comments on the proposed approach to transition arrangements?

There were 110 comments on the proposed approach to transition arrangements. Of these, 77 were responses made on behalf of organisations and 33 were personal responses.

Organisation responses comprised:

• 40 awarding organisations, including 13 which offer EPA only
• 9 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 14 representative or interest groups
• 8 employers
• 6 other organisations that did not identify with any of the categories above

Many respondents made comments relating to the timeline for the implementation of DfE’s reform as well as about Ofqual’s proposed transition arrangements. The main themes that emerged included:

• the need for clear and achievable timelines, allowing sufficient time for awarding organisations to design and implement new assessments, complete internal quality checks, and ensure compliance with the new regulatory framework, as well as for providers to plan delivery, resourcing and staff allocation – suggestions for what this timeline should be varied from 6 months to a minimum of 2 years, as well as a suggestion that the new approach should be piloted first
• the need to consider breaks in learning as part of the timeline (for example, due to redundancy, illness or pregnancy), and that some apprenticeships are delivered over more than 2 years, so could require a longer transition period
• that the timing within the year of implementing new arrangements should coincide with when fewer apprentices start their courses, to make it manageable for providers – it was noted that the more standards a provider offers, the greater the impact of the changes
• mixed views on how soon the new regulatory framework should be implemented – a small number of respondents argued that the implementation date should be sufficiently far in the future so that current apprentices have time to complete the version of the apprenticeship on which they enrolled, whereas providers tended to prefer the new regulatory framework being implemented as soon as possible (with a hard cut-off), with the ability to switch apprentices to the new model as soon as it is available

Many respondents also made comments about the impact of the transition on apprentices. These included:

• requests for guidance and support on timelines, and clarification on the circumstances under which apprentices would be able to switch from EPA to the new model of apprenticeship assessment
• requests for safeguards to prevent apprentices being switched on-programme from EPA to the new model of apprenticeship assessment to meet the interests of awarding organisations, employers or providers rather than those of the apprentice
• the risk (raised mainly by awarding organisations), that while 2 versions of apprenticeships are available during the transition, students could be mistakenly entered and assessed against the wrong one

Many respondents (including many awarding organisations) made comments relating to running dual frameworks and the potential confusion this could cause.  While recognising the approach to transition was a pragmatic one for a complex scenario, concerns highlighted included:

• the complexity and administrative burden (including costs) for awarding organisations, employers and providers of operating two frameworks at the same time
• that the burden will disproportionately fall on awarding organisations, who will have to redesign assessments to align with new apprenticeship assessment plans and Ofqual’s regulatory framework, as well as producing or updating substantial amounts of documentation
• delivery risks and costs of operating 2 sets of assessments (potentially more for standards with recently updated EPA assessment plans) under 2 models during transition, and the potential confusion of this for employers and providers
• the costs for providers and awarding organisations of potentially marking assessments under the new model
• the potential need to renegotiate contracts between employers, providers and awarding organisations to reflect new arrangements
• concerns for longer duration apprenticeships (which can take between 3 to 5 years to complete), leading to the need for a significant transition period

There was support for Ofqual providing guidance on how to manage transitions between versions of assessment plans, including how to determine when a new version requires a new qualification entry on the Register of Regulated Qualifications.

A small number of respondents made comments which were out of scope of this question about Ofqual’s regulation of the transition from EPA to apprenticeship assessment. These included comments that employers and Trailblazer groups had not been sufficiently engaged in the overall changes, a lack of alignment with wider qualifications reform, and concerns that the proposed changes are being implemented too quickly. Respondents also commented on the importance of alignment between Skills England, DfE and Ofqual, when ensuring funding rules align with the transition.

Impact assessments

Equality impact assessment

Question 44
Are there any other potential equality impacts (positive or negative) on apprentices 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.

There were 65 comments on the potential equality impacts on apprentices because of the proposals outlined in the consultation. Of these, 45 were responses made on behalf of organisations and 20 were personal responses.

Organisation responses comprised:

• 23 awarding organisations, including 5 which offer EPA only
• 8 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 5 representative or interest groups
• 3 employers
• 6 other organisations that did not identify with any of the categories above

Of the respondents who provided comments, roughly equal proportions considered there could be positive equality impacts and potentially negative equality impacts arising from our proposals. In some cases, the same respondents identified both positive and negative impacts.

The most common theme in responses concerned the potential impacts of increased assessment flexibility. Some respondents stated this should have a positive impact, making assessments more accessible and appropriate for apprentices – especially for apprentices with special educational needs and disabilities and for the neurodiverse community – and would improve assessment deliverability and manageability. However, some other respondents thought this flexibility could risk inconsistency in awarding organisations’ approaches, which they thought would disproportionately affect apprentices with disabilities, learning difficulties, or those from disadvantaged backgrounds.

Respondents also highlighted the risk that awarding organisations could move towards greater use of knowledge tests, which respondents thought could negatively impact apprentices who had chosen an apprenticeship as having a significant element of practical assessment, more suited to their learning style. 

Another theme that arose in responses was concern that giving greater flexibility in assessment design and delivery could lead to an inconsistent experience for apprentices, including in the application of reasonable adjustments for disabled apprentices. However, other respondents also thought that this greater flexibility has the potential to benefit apprentices who have not performed as well in the current EPA model. There was also concern about increased risk of bias if employers or providers are permitted to deliver and mark assessments themselves.

Some respondents thought there was potential for increased employer engagement to deliver a positive impact, by way of ensuring that assessments are more reflective of diverse workplace contexts.

A small number of respondents raised concerns about the proposal for awarding organisations to include synoptic assessment. Some suggested that this would have a negative impact on apprentices who are neurodivergent or who are experiencing mental health difficulties, due to the increased cognitive load of these tasks. Others suggested it would have a negative impact on disabled apprentices as it would make the assessments less accessible.

Question 45
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 apprentices who share a particular protected characteristic or are from a lower socioeconomic background?

There were 55 comments on the additional steps that Ofqual could take to mitigate any potential negative impacts of its proposals for apprenticeship assessment. Of these, 39 were responses made on behalf of organisations and 16 were personal responses.

Organisation responses comprised:

• 20 awarding organisations, including 2 which offer EPA only
• 4 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 4 employers
• 4 other organisations that did not identify with any of the categories above

Around a third of respondents suggested that Ofqual and/or awarding organisations should conduct data analysis to monitor equality impacts. It was also suggested that Ofqual should collect data on the prevalence of different assessment methods and evaluate the impact of the change of assessment methods compared to EPA. Some of the same respondents further suggested that Ofqual should also require awarding organisations to submit the results of satisfaction surveys they undertake with apprentices. Eight respondents suggested that Ofqual collect and publish outcomes data broken down by protected characteristics and socio-economic status. However, an awarding organisation noted the additional regulatory burden reporting this data would bring to awarding organisations.

A similar proportion of respondents suggested Ofqual should produce or endorse guidance with practical examples for awarding organisations to understand how to make assessments more accessible, both for disabled apprentices who require reasonable adjustments, as well as for apprentices from lower socio-economic backgrounds who may lack access to resources to prepare for or take assessments (such as reliable devices and broadband).

Some respondents thought Ofqual should do more to drive consistency in the application of reasonable adjustments, especially as assessment may no longer be delivered directly or marked by the awarding organisation.

Other suggestions for additional steps included:

• piloting new assessment models with a representative and diverse sample of apprentices
• stakeholder engagement, especially with employers, to understand diverse perspectives and identify potential barriers to accessibility
• ensuring that assessments can be flexible to accommodate apprentices with English as a second language and those with additional support needs

We also received several comments which did not specifically address negative equality impacts but highlighted concerns about the cost of our proposals in general, and whether Ofqual’s monitoring of equality impacts would increase regulatory burden on awarding organisations.

Regulatory impact assessment

Question 46
Are there any regulatory impacts that have not been identified as arising from the proposals, either individually or in combination? If yes, what are the impacts and are there any additional steps that could be taken to minimise the regulatory impact of the proposals?

There were 72 comments on this question. Of these, 54 were responses made on behalf of organisations and 18 were personal responses.

Organisation responses comprised:

• 32 awarding organisations, including 8 which offer EPA only
• 7 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 8 representative or interest groups
• 3 employers
• 4 other organisations that did not identify with any of the categories above

Most comments confirmed the regulatory impacts that Ofqual had already identified. These were in relation to:

• developing new assessments or adapting existing ones
• introducing centre marking (which Ofqual permits, but does not require in its proposals)
• the disproportionate impact on newer, smaller or niche awarding organisations
• introducing Centre Assessments Standards Scrutiny (CASS) requirements

Most respondents noted that the apprenticeship sector is already a complex environment, and that DfE announcements earlier this year and resulting proposals from Skills England and Ofqual have not reduced those complexities.

All but one awarding organisation commented thought there would be regulatory impacts arising from our proposals, but only a few suggested any additional impacts that we had not already identified.

Three key themes emerged in responses that all set out the key risks to the apprenticeship sector.

Shorter-term versus longer-term regulatory burden

Most respondents highlighted a lack of information on the implementation arrangements (including lead-in times) and detailed guidance as key concerns. Although seen more as a short-term concern, it was thought that there would be significant burden placed on awarding organisations, providers and employers as new systems were introduced to comply with new regulatory arrangements.

In the shorter-term especially, awarding organisations highlighted increased staff costs for activities like employer engagement, centre-marking and internal quality assurance. It was thought these costs would arise because of upskilling existing staff and/or recruiting new staff.

Awarding organisations also mentioned the increased everyday administrative costs associated with running a dual system of centre and awarding organisation marking. Some awarding organisations suggested these costs would likely be passed onto providers. Providers mentioned increased recruitment costs when preparing for marking assessments since many do not have access to personnel with these skills. Employers were concerned that making changes to apprenticeship assessment without having effective monitoring mechanisms in place risked quality issues with the new approach to apprenticeship assessment going unchallenged, ultimately leading to a lack of confidence by employers in apprenticeships. Employers also mentioned a heightened conflict of interest risk whereby providers deliver and assess apprenticeships.

It was generally thought however that, in the longer-term, the regulatory burden would not be that much different compared to that imposed by EPA.

Disproportionate regulatory burden

Many respondents noted that the proposed changes would be felt more keenly by awarding organisations that:

• are smaller or more niche
• may only currently offer EPA for one or 2 apprenticeships
• may be the sole provider of EPA for an apprenticeship standard

It was argued that such awarding organisations are unlikely to have the knowledge and skills necessary or the multi-disciplinary teams available to prepare for the introduction of the new approach to apprenticeship assessment such as, developing assessment and CASS strategies and introducing quality assurance mechanisms. It was argued that these awarding organisations would be at higher risk of delivering apprenticeship assessment that is non-compliant under the new regulatory framework, which might ultimately make them withdraw from the market altogether.

Respondents hoped that Ofqual guidance on developing assessment and CASS strategies would go some way to reassure awarding organisations, especially those smaller and more niche awarding organisations, when designing and developing apprenticeship assessment.

Employer engagement challenges

Many respondents, particularly awarding organisations, acknowledged that while employer involvement in apprenticeship assessment is critical when ensuring occupational relevance (unless the employer operates as an employer-provider), then awarding organisations might struggle to remain compliant with the new regulatory framework if employer engagement is mandated. Again, respondents hoped that detailed guidance would be forthcoming on this, setting out expectations on the level and depth of engagement with employers that awarding organisations would be expected to undertake when designing and developing apprenticeship assessments.

Many respondents also made comments that were out of scope of the question. They referred to the equality impact, commented on the assessment of safety within apprenticeships, as well as more general concerns around quality and standards.

Question 47
To what extent do you think the overall financial impact on awarding organisations of the regulatory framework will be positive or negative? Please provide estimated figures where possible.

There were 132 comments on this question. Of these, 87 were responses made on behalf of organisations and 45 were personal responses.

Organisation responses comprised:

• 46 awarding organisations, including 14 which offer EPA only
• 17 providers, including private training providers, schools, colleges, higher Education institutions and local authorities
• 9 representative or interest groups
• 7 employers
• 8 other organisations that did not identify with any of the categories above

As in the case of those answering the previous question, many respondents re-stated that the overall financial impact on awarding organisations would be negative during the shorter-term. Some mentioned that it might lead to awarding organisations questioning their place in the apprenticeship market, with others mentioning that it might ultimately lead to a loss of public confidence in apprenticeships should withdrawal from the market happen at scale. In the longer-term, many respondents saw delivery of the new apprenticeship assessment arrangements as being roughly equivalent in terms of cost as for the current EPA regulations. A few respondents thought that apprenticeships might become cheaper to deliver in the longer term because of increased competition, and by removing duplication of testing that sometimes happens under EPA.

Many respondents said they were unable to say whether costs would increase or not, noting that they wanted to see more detail in terms of the guidance on synoptic assessment, centre marking and/or CASS arrangements. They stated that the level of complexity contained within the totality of regulatory guidance would help determine whether costs are likely to rise or fall.

Providers generally saw the opportunities for cost reductions, whereas awarding organisations tended to comment on cost increases, especially in the shorter-term, and saw potential challenges posed by the changes. Centre marking was expected by both groups to lead to an increase in costs, mostly due to the acquisition of extra staff or upskilling current staff to implement DfE’s assessment principles and the proposed regulatory framework.

Two awarding organisations stated that some private training providers view the overarching reforms as a potential cost-saving measure, creating a mismatch between potentially rising costs for awarding organisations and expectations of reduced pricing.

Question 48
Are there any costs, savings or other benefits associated with the proposals, either individually or in combination, which have not been identified? Please provide estimated figures where possible.

There were 67 comments on this question. Of these, 47 were responses made on behalf of organisations and 20 were personal responses.

Organisation responses comprised:

• 25 awarding organisations, including 9 which offer EPA only
• 9 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 3 employers
• 3 other organisations that did not identify with any of the categories above

Respondents tended to repeat answers given to the previous 2 questions when considering this question. They commented on the shorter-term preparation costs they would encounter during the transition period, and the additional costs incurred when running dual regulatory frameworks. For the longer-term, some awarding organisations mentioned potential benefits like efficiency gains arising from end-to-end assessment design and delivery. However, some awarding organisations gave a contrary opinion saying that the new flexibilities and variations introduced under the new regulatory framework would not be conducive to delivering cost effective solutions to the assessment process.

Of the 16 awarding organisations that offer qualifications other than EPA, 6 that expressed an opinion thought their costs would increase, 4 thought they would make savings and 4 could not make a forecast either way. Of the 9 awarding organisations offering EPA only, 3 that expressed an opinion thought their costs would increase, one thought it would make savings and 4 said they could not make a forecast either way.

Of the 9 centres (including private training providers, schools, colleges, higher education institutions and local authorities) that expressed an opinion, 5 anticipated their costs would increase and 2 expected savings.

No respondents provided estimated figures when answering this question.

Question 49
Is there any additional information that Ofqual should consider when evaluating the costs and benefits of the proposals?

There were 70 comments on this question. Of these, 48 were responses made on behalf of organisations and 22 were personal responses.

Organisation responses comprised:

• 21 awarding organisations, including 8 which offer EPA only
• 13 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 4 representative or interest groups
• 6 employers
• 4 other organisations that did not identify with any of the categories above

Respondents tended to repeat answers given to the previous 3 questions when answering this question. They repeated comments about the shorter-term preparation costs incurred during the transition period, and when running dual regulatory frameworks. For the longer-term, some awarding organisations mentioned again potential benefits like efficiency gains arising from the ability to have an end-to-end assessment design and delivery process. However, many respondents said they preferred to wait until they saw the full detail of the regulatory framework, its associated guidance, and the timelines and transition arrangements, before they gave more considered views on the costs and benefits of the proposals. 

When respondents did mention increased costs, these mostly focused on the costs incurred by upskilling and/or recruiting staff to enable them to implement the proposed regulatory framework. Respondents also spoke of capacity issues with all the other proposed changes that are anticipated for the education sector.

Question 50
Do you have any comments on the impact of the proposals for the regulatory framework for apprenticeship assessment on innovation by awarding organisations?

There were 69 comments on this question. Of these, 57 were responses made on behalf of organisations and 12 were personal responses.

Organisation responses comprised:

• 32 awarding organisations, including 10 which offer EPA only
• 8 providers, including private training providers, schools, colleges, higher education institutions and local authorities
• 7 representative or interest groups
• 3 employers
• 7 other organisations that did not identify with any of the categories above

Of those respondents who provided comments, a majority thought that the proposed regulatory framework for apprenticeship assessment would have impacts potentially both positive and negative – on assessment innovation by awarding organisations.

Overall, respondents indicated that reduced prescription in apprenticeship assessment plans could support creativity and innovation. However, respondents also said that a more flexible approach brings with it risks to consistency, quality and fairness – all of which require balanced oversight, targeted support (especially for smaller and specialised awarding organisations), appropriate safeguards, and considered planning when implementing the changes.

Respondents indicated that granting awarding organisations greater autonomy for assessment design decisions could encourage new assessment models that allow for greater flexibility. They said that this could encourage awarding organisations to try out new assessment approaches, for example in designing context-specific assessments, experimenting with digital tools and AI, and better tailoring assessment methodologies to sector and employer needs.

However, respondents caveated this by saying that variability could also undermine trust in apprenticeship outcomes and have a negative impact on fairness and apprentice experience. It could potentially lead to diverse assessment methodologies across apprenticeships, with a reduction in consistency and comparability in apprenticeship outcomes, thereby negatively impacting on public confidence in apprenticeships. Hence, it was argued that innovation would only work if underpinned by clear and sufficient regulatory oversight. A few respondents suggested the introduction of pilot schemes in low-risk areas to test new assessment models as part of the innovation process.

Respondents made similar comments to those made in relation to regulatory impact, highlighting the resource burden, especially for smaller and more specialist awarding organisations, in terms of implementation and operational challenges, and called for proportionate support.

Annex A: List of organisational respondents

When completing the consultation, 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 response.

Where the content of the response was requested as being either fully or partially confidential, or where the response was submitted to our consultation mailbox and did not indicate if any part of the response should be confidential, these have been marked accordingly as a confidential response:

• 1st Awards
• A2A Training Limited
• Aboriculture, Forestry, Horticulture and Landscaping Trailblazers Management Group
• Academy for Project Management
• Accelerate People
• Asda Stores Limited
• Assessed Education Limited (Assessu)
• Association of Accounting Technicians (AAT) (confidential response)
• Association of Colleges (AoC)
• Association of Employment and Learning Providers (AELP)
• Association of School and College Leaders (ASCL)
• Autoexel Limited
• BAE Systems plc
• Bauer Academy
• BCS, The Chartered Institute for IT
• Blue Lights Digital
• British Army
• British Association of Landscape Industries
• British Marine Federation
• British Woodworking Federation
• Bromford Flagship
• Buckinghamshire Council
• Chartered Governance Institute (confidential response)
• Chartered Institute of Credit Management (CICM)
• Chartered Institution of Wastes Management
• Chrysos HR Solutions
• Chartered Institute of Horticulture
• Chartered Institute of Legal Executives (CILEX)
• Chartered Management Institute
• Chartered Institute of Marketing
• CICM
• CIPD
• City & Guilds
• Cogent Skills
• Construction EPA Company
• Construction Industry Training Board
• Construction Skills Certification Scheme (CSCS) (confidential response)
• Corndel
• DNA Awarding
• DSW
• Dudley College of Technology
• EAL
• ECITB
• Education and Training Foundation
• Education for Industry Awards (confidential response)
• Energy & Environment Awards (confidential response)
• Engineering Council
• Federation of Awarding Bodies (FAB)
• Federation of Small Businesses (FSB) (confidential response)
• Food and Drink Qualifications Limited (FDQ)
• Finishes and Interiors Sector (confidential response)
• First Intuition Cambridge Limited
• Fitch Learning
• Gateway Qualifications Limited
• Gatsby
• Genius Software Solutions T/A Genius Education/People
• Greater Manchester Learning Provider Network (GMLPN)
• GTA England
• Highfield Qualifications
• Humberside Engineering Training Association Limited (HETA)
• iCQ
• Innovate Awarding
• Institute of Chartered Accountants in England and Wales
• Institution of Civil Engineers
• Institution of Mechanical Engineers (IMechE)
• Landex – Land Based Colleges and Universities UK
• Lantra (confidential response)
• Learning Curve Group
• Luminate Education Group
• Momentum Training and Consultancy
• Multiverse
• National Council for the Training of Journalists (NCTJ)
• National Federation of Builders
• National Hair and Beauty Federation
• National Skills Academy for Nuclear
• NCFE
• NOCN Group
• Occupational Awards Limited
• Oldham College
• Open Awards
• Peak Accountancy Training
• Pearson Education Limited
• Port Skills & Safety (confidential response)
• Professional Assessment Limited (PAL)
• ProTech Education and Assessment
• Quantum Awards Limited
• Royal Botanic Gardens, Kew
• Royal Society of Chemistry
• SFJ Awards (confidential response)
• Skills Federation (confidential response)
• Skipton Properties Ltd (confidential response)
• Sheffield Hallam University
• Simian Risk Management Limited
• Sizewell C
• South West Councils (confidential response)
• Steadfast Training Limited
• Technical Apprenticeship Consortium
• The British Psychological Society
• The Chartered Institute of Housing
• The Institute of the Motor Industry (IMI)
• The Lift and Escalator Industry Association
• The Real Consultancy Company
• The Worshipful Company of Farriers (confidential response)
• TQUK (Confidential response)
• Trades Union Congress (TUC) (confidential response)
• UHL (confidential response)
• UK Fashion and Textile Association Limited (UKFT)
• Verge EPA (confidential response)
• Vet Skill Limited
• VTCT Skills (confidential response)
• Weston College