Notice

Notice of Chief Regulator’s Rebuke: Pearson

Published 2 July 2026

Applies to England

Date: 11 May 2026

To: Cath Jadhav, Responsible Officer

Awarding Organisation: Pearson Education Limited (‘Pearson’)

Subject: Non-compliance in relation to the setting and delivery of A Level maths assessments in 2025 summer series

This notice issues Pearson with a formal rebuke from Ofqual’s Chief Regulator, following a determination that it has failed to comply with its conditions of recognition.

This action is taken under Ofqual’s Supporting Compliance and Taking Regulatory Action Policy as a non-statutory enforcement response, where the seriousness of the failings requires a formal public outcome, but the circumstances do not warrant a financial penalty.

Background: development of the 2025 Assessment Papers

1. 1. Between 2020 and 2021, Pearson created and approved its A Level maths papers for the 2022 summer series (‘the 2022 Assessment Papers’). On or around 30 September 2021, the Department for Education (DfE) and Ofqual announced that advance information would be provided by exam boards to support student revision for June 2022.
2. 2. Between September 2021 and May 2022, Pearson created a set of reserve papers for the 2022 summer series, for use in the event that the content of the original papers was somehow compromised (‘the 2022 Contingency Papers’). By necessity those reserve papers reflected the same advance information as was stipulated for the original 2022 papers.
3. 3. The 2022 summer series passed without incident and Pearson did not need to use the 2022 Contingency Papers.
4. 4. In 2023 Pearson made the decision to re-purpose the 2022 Contingency Papers for the 2025 summer series (hence they became ‘the 2025 Assessment Papers’). Some additional reviews took place prior to delivery in 2025, but significant reliance was placed on the quality assurance process that had been completed in 2022.
5. 5. Alongside this, Pearson was developing assessment materials for the 2026 assessment series. These were ultimately brought forward for use as Contingency Papers in 2025 (‘the 2025 Contingency Papers’) when issues arose with the 2025 Assessment Papers.
6. 6. Pearson’s A Level mathematics exam consists of three papers. Papers 1 and 2 are designed as a pair to ensure appropriate coverage of the pure mathematics subject content in any one exam series. Paper 3 separately assesses applied mathematics (statistics and mechanics).

Paper 1 of the 2025 Assessment Papers: Level of Demand

1. 7. Students sat paper 1 of the 2025 Assessment Papers on 4 June 2025. There followed comments on social media that the assessment was similar to the now published paper 1 of the 2022 Assessment Papers, creating a potential advantage for students who were familiar with the 2022 papers from their revision. This was consistent with complaints received by Ofqual from stakeholders.
2. 8. Pearson admits that it failed to consider the inherent risk in repurposing unused assessment materials in circumstances where:
   1. a) Paper 1 and paper 2 are designed as a pair to cover the pure maths content set out in the A Level maths specification
   2. b) The advance information published in 2022 meant that the 2025 Assessment Papers (which started out as the 2022 Contingency Papers) were more similar to the 2022 papers than would normally be the case across different series
   3. c) once the similarity between the 2022 paper 1 and the 2025 paper 1 was identified, there was an inherent risk that students might be more readily able to predict the likely focus of questions on paper 2, a risk that was mitigated by Pearson’s action to replace paper 2.
3. 9. With that context in mind and following a detailed review of the 2022 and 2025 Assessment Papers, Pearson has accepted that some of the content within the 2025 Assessment Papers was unreasonably similar to that contained within the 2022 Assessment Papers.
4. 10. Pearson accepts that, as a result, the Level of Demand for paper 1 of the 2025 Assessment Papers was likely to be reduced for any Learner who had a strong familiarity with the 2022 Assessment Papers. Pearson admits that it has no way of identifying which students were familiar with the 2022 Assessment Papers and could therefore have received an advantage in 2025.
5. 11. However, Pearson undertook a detailed analysis in July 2025 that allows it to offer assurances that, if any student did receive such an advantage, the extent of that advantage was not statistically significant, and the number of any such students was so small as to have had no material impact on the Validity and Reliability of results across the wider cohort. Ofqual accepts Pearson’s assurances in this regard.

Paper 2 of the 2025 Assessment Papers: content coverage

1. 12. Pearson undertook an immediate review to identify the extent of any similarities between the 2022 Assessment Papers and 2025 Assessment Papers, with paper 2 due to be delivered on 12 June.
2. 13. On 6 June 2025, Pearson made the decision to replace paper 2 of the 2025 Assessment Papers with paper 2 from the 2025 Contingency Papers.
3. 14. Students sat paper 2 of the 2025 Contingency Papers on 12 June 2025, save for 69 students who sat paper 2 of the 2025 Assessment Papers in modified printed format. For these students, Pearson took the decision not to print modified papers at short notice, based on an assessment of the balance of risk, including the risk that modifications could not be completed to the required standard in time, and the risk to quality in attempting to do so.
4. 15. There followed media (predominantly via social media) and stakeholder reports that the content of paper 2 of the 2025 Contingency Papers was too similar in some regards to paper 1 of the 2025 Assessment Papers, and in other ways it omitted to assess certain topics that were not assessed in paper 1 of the Assessment Papers.
5. 16. After careful review, Pearson admits that while papers 1 and 2 of the 2025 Assessment Papers ensured appropriate content coverage as a pair, and papers 1 and 2 of the 2025 Contingency Papers ensured appropriate content coverage as a pair, it was the case that when paper 1 of the 2025 Assessment Papers was combined with paper 2 of the 2025 Contingency Papers, the resultant pair did not ensure the same degree of content coverage as the original pairings, with some topics over-assessed and some under-assessed. Although Pearson maintains that the resultant pair nonetheless provided coverage that was in line with the specification, it acknowledges that the Level of Demand was not as clearly comparable with previous assessment series as it otherwise would have been.
6. 17. In a similar vein to the admissions at paragraph 10, Pearson admits any students sitting paper 2 of the 2025 Assessment Papers who had a strong familiarity with the 2022 Assessment Papers were likely to benefit from a reduced Level of Demand arising from that familiarity. A total of 69 students sat paper 2 of the 2025 Assessment Papers, albeit in modified form.
7. 18. Pearson has produced detailed analysis to demonstrate that, if any Learner did receive such an advantage, the extent of that advantage was not statistically significant, and the quantity of any such students was so small as to have had no material impact on the Validity and Reliability of results across the cohort. Ofqual accepts Pearson’s analysis in this regard.
8. 19. The above in theory gives rise to potential disparity between students who sat paper 2 of the 2025 Assessment Papers and students who sat paper 2 of the 2025 Contingency Papers. However, Pearson produced detailed analysis, conducted at the time of the award, to demonstrate insofar as is possible given the numbers involved, that any disparity was not statistically significant and had no material impact on the Validity and Reliability of results across the cohort. Ofqual accepts Pearson’s analysis in this regard.
9. 20. Pearson states that it took prompt action to mitigate potential risks associated with delivery of paper 2 of the 2025 Contingency Papers, but it admits that it did not give due consideration at the point of commissioning the 2022 Contingency Papers as the 2025 Assessment Papers to the inherent difficulty in substituting one of the Assessment Papers when those Assessment Papers were designed as a pair, particularly in the context of advanced information. Without proper planning there is a significant risk that the content coverage and Level of Demand for the assessment may be compromised.

Pearson’s response and admissions

1. 21. Pearson has:
   1. a) accepted the facts as set out at paragraphs 1-20
   2. b) accepted the allegations of non-compliance set out at paragraph 22
   3. c) accepted that the failures arise primarily from its failure to properly identify and consider the risks associated with its decision to repurpose its 2022 Contingency Papers in the circumstances described above
   4. d) accepted that while the statistical evidence suggests that there was no adverse impact upon the Validity and Reliability of results, it cannot rule out the possibility that a small number of students benefitted from a reduced Level of Demand as a result of the issues identified
   5. e) accepted that the incident had the potential to undermine public confidence in the Validity of its regulated qualifications.
2. 22. The allegations referred to at paragraph 21(b) and admitted by Pearson are as follows:

Allegation 1

1. 1. Pearson failed to ensure that the 2025 A Level mathematics assessments were commissioned and delivered in accordance with its Conditions of Recognition, in that:
   1. a) It failed to ensure that the Level of Demand across paper 1 and paper 2 was consistent with previous assessments, contrary to General Condition G1.2
   2. b) It failed to adequately minimise predictability of one or more assessments, contrary to Subject Level Condition GCE (Mathematics) 2.1
   3. c) It failed to ensure coverage of subject content across the assessments was consistent with previous assessment series, contrary to Subject Level Condition GCE (Mathematics) 2.1
   4. d) it did not deliver all assessments effectively and efficiently, contrary to General Condition G9.1

Allegation 2

1. 2. During the commissioning process for the 2025 A Level mathematics assessments, Pearson failed to take all reasonable steps to identify, manage, and mitigate foreseeable risks associated with its decision to repurpose its 2022 Contingency Papers, which were developed to incorporate advance information, for use as the 2025 Assessment Papers, which did not incorporate advance information, contrary to General Condition A6.

Why a rebuke has been issued

1. 23. Ofqual considers the circumstances of non-compliance to be sufficiently serious for a rebuke. In reaching this decision, Ofqual has had regard to:
   1. a) Public confidence: this was a high stakes qualification being sat by circa 75,000 students. There was a significant risk to public confidence in regulated qualifications arising from both the issues with paper 1 of the 2025 assessment materials and the steps taken by Pearson to replace paper 2 of the 2025 assessment materials.
   2. b) Public confidence: the uncertainty arising from the well-publicised concerns about the standard, comparability and coverage of the assessments, together with the mid-series substitution of paper 2, was liable to cause significant anxiety and distress for students. Such anxiety, and the perception that outcomes may potentially have been affected by factors beyond a student’s control, risks undermining confidence in regulated qualifications.
   3. c) Public confidence: having made the decision to replace paper 2 of the 2025 assessment materials, Pearson introduced paper 2 of the Contingency Papers which itself introduced issues of content coverage. The risk to public confidence arising from the potential mishandling of the incident was significant.
   4. d) Admissions and cooperation: Pearson self-reported the incident, made early admissions, has been fully cooperative with Ofqual and has taken urgent steps to improve its processes and reduce the risk of recurrence.
   5. e) Risk management: the issues were entirely avoidable, but Pearson did not adequately identify or consider the inherent risks associated with repurposing assessment materials originally designed to incorporate advanced information for delivery in a series where no such information was intended.
   6. f) Internal controls: significant reliance was placed on quality assurance processes completed in 2022, without appropriately reassessing the materials in light of the different regulatory and contextual circumstances in 2025.
   7. g) Internal controls: similarities between the 2022 and 2025 papers were only recognised following direct stakeholder feedback and social media attention, indicating deficiencies in Pearson’s internal scrutiny mechanisms. The prevalence of social media coverage meant that there was significant awareness amongst students and teachers.
   8. h) Risk management: Pearson had not anticipated or planned for the difficulty of substituting one part of a paired assessment, contributing to content coverage and comparability issues.
   9. i) Scale and duration of the failings: this failure was isolated to the 2025 assessment series and has been promptly remedied.

Other regulatory options considered

1. 24. Ofqual has considered whether to simply record the non-compliance without taking further action, however it considers that this would not:
   1. a) sufficiently reflect the seriousness of the breaches
   2. b) adequately promote public confidence in regulated qualifications
   3. c) deter future non-compliance by Pearson or the wider regulated community
2. 25. Ofqual does not consider that a financial penalty is necessary in the specific circumstances of this case, including having had regard to:
   1. a) Integrity: there is no evidence to suggest that the failures were deliberate or indicative of a general disregard for Pearson’s regulatory obligations.
   2. b) Validity and Reliability: while the allegations are inherently serious, the evidence suggests that any impact upon results was so small as to be statistically insignificant. This was in part due to the steps that Pearson took to act promptly when issues were first identified in relation to paper 1 of the 2025 Assessment Papers.
3. 26. Ofqual therefore considers that a rebuke is the most proportionate and appropriate outcome in the circumstances of this case.

Right to appeal

1. 27. Pearson may appeal this rebuke in accordance with Ofqual’s published Appeal Rules which set out the procedure for appeals to the Ofqual Enforcement Appeal Panel.
2. 28. The rebuke will remain confidential until the appeal period expires. Where an appeal is submitted, the rebuke will not be published until the appeal is concluded. If the appeal is dismissed, Ofqual will normally publish both the rebuke and the appeal outcome.

Publication of the rebuke

1. 29. If no appeal is submitted, Ofqual will publish the rebuke after the appeal period has expired or on such earlier date as may be agreed with Pearson.

Conclusion

1. 30. These failings represent serious breaches of Ofqual’s General and Subject Level Conditions. Although Pearson has taken steps to remedy the issue, the incident was entirely avoidable had Pearson identified the risks associated with repurposing its 2022 Contingency Papers at the time of commissioning the 2025 Assessment Papers. Even then, the application of fresh quality assurance would have allowed Pearson to identify and address the issues that ultimately arose.
2. 31. While Ofqual accepts Pearson’s assurances as to the Validity and Reliability of its results, the fact that a sound outcome was achieved does not diminish the seriousness of the failures identified. This rebuke serves both as a formal expression of regulatory concern and as a clear expectation that Pearson must strengthen its regulatory compliance processes.

Signed:

Sir Ian Bauckham CBE,

Chief Regulator, Ofqual