Notice

Notice of Monetary Penalty on the Associated Board of the Royal Schools of Music (ABRSM)

Published 14 October 2026

Applies to England

Introduction

1. 1. This notice sets out the final decision, made by The Office of Qualification and Examinations Regulation’s (“Ofqual”) Enforcement Panel on 7 October 2026, to issue ABRSM with a monetary penalty under section 151A of the Apprenticeships, Skills, Children and Learning Act 2009 (“ASCLA”) in the sum of £150,000 for breaches of Ofqual’s General Conditions of Recognition.

2. 2. In accordance with section 151A (4) of ASCLA, Ofqual served ABRSM with a Notice of Intention to impose a monetary penalty on 1 October 2026. Ofqual determined it was not necessary to publish the Notice of Intention. On 5 October 2026, and in accordance with the settlement agreement, ABRSM confirmed it had no further representations to make and was content for Ofqual to proceed to final decision.

Executive Summary

1. 3. ABRSM has been recognised by Ofqual since 1 April 2010. ABRSM delivers a range of regulated music qualifications through face-to-face and digitally assessed qualification products.

2. 4. Between 2024 and 2025, ABRSM notified Ofqual of four separate incidents relating to the retention of assessment evidence, the operation of reviews of marking and appeals, the investigation of suspected malpractice, and the accuracy of certificates issued to learners.

3. 5. Following investigation and regulatory engagement, Ofqual concluded that ABRSM’s arrangements gave rise to breaches of the General Conditions of Recognition. ABRSM has accepted that it failed to retain assessment evidence which affected a small number of reviews of marking and a malpractice investigation and that it issued certificates containing inaccurate qualification titles.

4. 6. As a result of the matters described above, ABRSM accepts that it has breached its Conditions of Recognition in the circumstances set out below.

Background

1. 7. ABRSM has been recognised by Ofqual since 1 April 2010 and delivers a range of regulated music qualifications. The delivery, marking, review and certification of those qualifications require the creation, retention and retrieval of assessment evidence, including audio and video recordings.

2. 8. Between February and August 2024, Ofqual were notified by ABRSM of three separate incidents impacting ABRSM’s assessment and certification arrangements. The first arose following a Learner complaint concerning a review of marking, during which ABRSM discovered that the supporting audio recording was unavailable and the review could not be completed. Subsequent investigation identified a wider issue relating to the retention of supporting audio recordings.

3. 9. During the same period, ABRSM also notified Ofqual that 72,064 learners had been issued certificates containing an incorrect qualification title, and that in a separate incident ABRSM had become aware that assessment recordings and mark forms relating to 16 learners had been unintentionally deleted and could not be recovered.

4. 10. In October 2024, Ofqual met with ABRSM for a scheduled Evaluative Review meeting and raised concerns regarding the incidents and the underlying systems and controls that had given rise to them. Following that engagement, Ofqual exercised its information gathering powers and issued a B4 notice requiring ABRSM to provide further information about the actions it had taken to remediate them. ABRSM provided responses between December 2024 and February 2025.

5. 11. While those matters were under consideration, ABRSM submitted a further Event Notification concerning suspected malpractice involving a single applicant, based outside the UK, responsible for entering 710 Learners for Performance Grade qualifications. ABRSM’s investigation identified evidence of duplicated assessment recordings being used in support of multiple Learner entries. However, because 231 assessment recordings had been deleted in accordance with its data retention policy, ABRSM was unable to conduct a full investigation in these cases.

6. 12. Following regulatory engagement with Ofqual’s VTQ AO Performance Team, Ofqual concluded that there was evidence indicating potential breaches of the Conditions of Recognition and referred the matters for collective enforcement action, in relation to the following allegations:

Allegation 1 - Inadequate Record Keeping, Data Retention and Assessment Controls

1. 1.1. Between December 2023 and October 2025, ABRSM failed to establish and maintain adequate systems and controls for the retention, management and availability of assessment evidence and associated records.

2. 1.2. As a consequence of those failures:

   1. a. On up to 8,539 occasions between December 2023 and April 2025, ABRSM failed to retain audio recordings of completed Learner assessments;

   2. b. As a consequence of the failure at paragraph 1.2(a), ABRSM was unable to conduct a review of marking or appeal on up to 20 occasions when Learners requested such a review;

   3. c. In or around June 2024, assessment recordings and marking records relating to 16 Learners were unintentionally deleted and irretrievably lost, causing a delay to these results and preventing effective review arrangements; and

   4. d. ABRSM failed to collect, retain and/or promptly access Learner identification evidence and assessment recordings relating to a malpractice investigation involving 231 Learners, thereby restricting its ability to undertake a comprehensive and effective malpractice investigation.

3. 1.3. In consequence of the matters referred to above, ABRSM failed to:

   1. a. maintain adequate resources and arrangements for the retention of assessment evidence, contrary to Conditions A5.1 and A5.2;

   2. b. adequately identify, manage and mitigate risks capable of adversely affecting Learners and qualifications, contrary to Conditions A6.1 and A6.2;

   3. c. take all reasonable steps to prevent, mitigate or correct adverse effects arising from those failures, contrary to Condition A7.1;

   4. d. effectively prevent and investigate malpractice, contrary to Conditions A8.1, A8.2 and A8.3;

   5. e. ensure that evidence relied upon in assessment was generated by the relevant learner, contrary to Condition G8.1;

   6. f. ensure that assessments were delivered effectively and efficiently, contrary to Condition G9.1;

   7. g. issue results in a timely manner, contrary to Condition H6.1; and

   8. h. comply effectively with arrangements for reviews of marking and appeals, contrary to Condition I1.1.

Factual Background

Missing Assessment Recordings – Review of Marking

1. 13. In April 2024 ABRSM notified Ofqual that it had become aware of issues affecting its ability to access assessment recordings for Practical Grade examinations. Those assessments were recorded using the Marcato application, a third-party application installed on examiner-issued iPads. Examiners were required to upload recordings through the application, after which the recordings would be removed from the device under ABRSM’s data retention policy.

2. 14. Following investigation, ABRSM identified that audio recordings for approximately 8,539 learner assessments had not been uploaded. The issue arose because, on some occasions, recordings appeared to have uploaded successfully, and examiners received confirmation messages indicating that the upload process had completed. In fact, the recordings had not been successfully transferred and stored within ABRSM’s system.

3. 15. Consequently, recordings were deleted from examiners’ devices in the belief that they had been successfully uploaded and securely stored. The result was that assessment evidence was lost, notwithstanding that the examiners had followed the process prescribed by ABRSM.

4. 16. As a direct result of those failures, twenty learners who requested a review of marking were unable to receive a review based upon all of the original assessment evidence.

5. 17. ABRSM worked with the software developer to identify and rectify the underlying defect, including removing the automatic deletion feature and introducing enhanced retention arrangements. ABRSM introduced an amended appeals process that would apply to instances where an audio recording could not be accessed.

Missing Assessment Recordings – Marking and Issuing Results

1. 18. In August 2024, ABRSM notified Ofqual of an incident involving the loss of assessment evidence relating to a private examination tour in Scotland. Examiner A had conducted assessments for sixteen learners between 17 and 21 June 2024. The assessments had been recorded on Examiner A’s iPad in accordance with ABRSM’s standard processes. However, at the time of the incident, the recordings and associated mark forms had not yet been backed up to cloud storage and remained on the local device.

2. 19. Examiner A subsequently became ill and was unable to conduct a scheduled examination session on 21 June 2024. To ensure that the remaining assessments could proceed, a member of ABRSM staff sought to reallocate the remainder of the examination tour to another examiner. During that process, an incorrect action was taken within ABRSM’s examination management system which resulted in the deletion of the recordings and mark forms associated with the sixteen assessments already completed by Examiner A.

3. 20. At the same time, Examiner A became locked out of their iPad on which the recordings remained stored. In order to access the device, ABRSM’s safeguarding procedures required a factory reset, which permanently deleted the contents of the device, including the stored assessment recordings.

4. 21. The recordings and completed mark forms for the learners could not be recovered and ABRSM was required to determine results using Examiner A’s written notes rather than the full assessment record. The loss of evidence meant that learners could not access a review of marking based upon their original performances and could not challenge whether higher grades such as Merit or Distinction may have been warranted.

5. 22. ABRSM received complaints from four of the affected Learners. ABRSM refunded all affected learners and offered resits, some of which were subsequently completed.

Missing Assessment Recordings - Malpractice Investigations

1. 23. In October 2025, ABRSM notified Ofqual of suspected malpractice involving a single applicant, based in China, responsible for submitting assessment evidence for 710 Learners undertaking Performance Grade qualifications. Examiners raised concerns regarding the authenticity of a number of Learner submissions and the adequacy of Learner identification procedures associated with that applicant.

2. 24. ABRSM’s investigation identified widespread irregularities within the cohort. ABRSM confirmed that in 247 cases video submissions were used more than once by the applicant in support of other Learners. All 247 Learners were disqualified after ABRSM made malpractice findings against each Learner.

3. 25. ABRSM confirmed that, of the 247 entries which were confirmed to use duplicate videos, a total of 32 different videos had been used across the entries, with the number of uses ranging from 77 to 2.

4. 26. ABRSM reacted to the incident by implementing software to detect duplicate video submissions at the point of marking, and analysing its record of c150,000 historical exam submissions.

5. 27. ABRSM investigated potential malpractice for all 710 Learners within the cohort, but its ability to do so was constrained by its own safeguarding-driven data-retention arrangements, which retained recordings for 130 days post release of results.

6. 28. ABRSM concluded:

   1. a. There were 231 Learners where assessment evidence was not retained.  The results for these Learners have been released.  Only limited malpractice investigations could take place due to the lack of a recording.

   2. b. There were 479 Learners where evidence was retained.  Of those: 

      1. a. Overall ABRSM was able to make 261 findings of malpractice after positive confirmation that the video was a duplicate.  ABRSM revoked all affected certificates.

      2. b. For the 218 remaining cases, ABRSM undertook extensive malpractice investigations that involved the careful manual review of the assessment recordings to establish authenticity and speaking to Learners to re-verify their identities. ABRSM was able to safely conclude that malpractice had not occurred on those occasions.

7. 29. Prior to October 2025, ABRSM did not operate systems capable of automatically detecting duplicate video submissions and relied upon manual detection by staff and examiners. Additionally, concerns arose regarding compliance with Learner identity verification processes.

Analysis

1. 30. Ofqual considers that these incidents are not isolated operational failures, in that they share a failure to retain, safeguard and retrieve assessment evidence required for ABRSM’s assessment, appeals, certification and malpractice processes.

2. 31. In the first incident, assessment recordings were lost because ABRSM’s systems allowed assessment evidence to be treated as successfully uploaded and subsequently deleted from local devices when, in fact, the recordings had not been securely uploaded. Ofqual considers that the incident demonstrated that the controls governing the retention of critical assessment evidence were not sufficiently robust. While ABRSM took steps to remedy the issue on discovery, its impact by then was already significant for the 20 affected Learners.  However, it is Ofqual’s position that if any of the other 8539 Learners had required a review of marking, ABRSM would have been unable to facilitate that request.

3. 32. In the second incident, assessment recordings and mark forms were irretrievably lost because the safeguards, backups and recovery arrangements in place did not ensure the preservation of assessment evidence.  The incident demonstrated a failure to ensure that critical assessment evidence was securely retained, protected from loss and accessible when required.  While user error was inherent, these issues were avoidable and had a significant impact upon the 16 affected Learners.

4. 33. In the third incident, the fact that identical recordings were capable of being submitted repeatedly, including the reuse of a single recording on 77 separate occasions, before concerns were identified, demonstrates shortcomings in the arrangements prior to October 2025 designed to ensure that assessment evidence was generated by, and attributable to, the learner claiming credit for it. ABRSM’s retention arrangements meant that evidence required to investigate suspected serious malpractice no longer existed when required. The inability to access recordings relating to 231 learners constrained ABRSM’s investigation by limiting its ability to establish the full extent of malpractice associated with the Applicant.

5. 34. Taken together, these incidents demonstrate that ABRSM’s arrangements for the retention and management of assessment evidence were inadequate to ensure that critical information remained available for regulatory purposes. Such evidence is essential to the operation of reviews of marking, appeals, malpractice investigations, certification decisions and the maintenance of public confidence in regulated qualifications.

6. 35. It is accepted that, particularly in relation to the first and second incidents, ABRSM was reliant in part on systems operated by third parties. However, it is ABRSM’s responsibility under Conditions A5.1 and 5.2 to establish and maintain “arrangements for the retention of data which will ensure that adequate information is available to it at all times”.

7. 36. The incidents also demonstrate deficiencies in ABRSM’s management of risk. The possibility that assessment evidence may be lost, corrupted, deleted, become inaccessible or be required for future regulatory investigations is inherent within any qualification system that relies upon digital assessment records. Appropriate controls should therefore have existed to prevent these particular risks materialising, or to mitigate their consequences where they did occur.

8. 37. Ofqual further considers that shortcomings in identity-verification arrangements and the absence of duplicate-detection controls contributed to failures to ensure that assessment evidence was genuinely generated by the learner to whom it was attributed. Those weaknesses increased the risk of malpractice and undermined confidence in the integrity of assessment outcomes.

9. 38. Taken together, the effect of these failures was significant. Up to 20 Learners were unable to access reviews of marking, 16 assessment outcomes were delayed, malpractice investigations were restricted by the absence of key evidence. ABRSM was unable to review evidence relating to 231 learners because the relevant recordings had been deleted in accordance with ABRSM’s published data retention policy. The outcomes demonstrate the importance of retaining assessment evidence for regulatory purposes and illustrate the adverse impact that retention arrangements can have on an awarding organisation’s ability to protect the integrity of its qualifications.

10. 39. Ofqual considers that the conduct described above amounts to failures to maintain adequate data-retention arrangements, to identify and mitigate regulatory risks, to prevent and investigate malpractice effectively, to ensure the authenticity of learner evidence, to deliver assessments effectively and efficiently, to operate effective reviews and appeals arrangements, and to protect learners from adverse effects arising from those failures.

Allegation 2 - Inaccurate Certificates

1. 2.1. Between 30 April 2024 and 10 July 2024, ABRSM issued approximately 72,064 certificates containing inaccurate qualification titles, contrary to Condition I4.1.

2. 2.2. Following identification of that error, ABRSM failed promptly to take all reasonable steps to mitigate and correct the adverse effects arising from the issue of inaccurate certificates, contrary to Condition A7.1, in that it:

   1. a. did not promptly notify affected Learners of the error; and/or

   2. b. did not promptly implement a comprehensive process for the correction and replacement of affected printed certificates.

Factual Background

1. 40. The error arose when an obsolete qualification title was incorporated into certificate templates used by ABRSM. As a result, approximately 72,064 certificates contained incorrect qualification titles.  For example, affected certificates read:

ABRSM Level 3 Certificate in Graded Examination in Music Performance (Grade 8)

when they ought to have been titled 

ABRSM Level 3 Certificate in Music Performance (Grade 8)” or ABRSM Level 3 Certificate in Practical Music (Grade 8).  

1. 41. The unit title on the certificates referred to the correct qualifications, but the qualification title was incorrect. The qualification title wording on affected certificates did not accurately distinguish between a Music Performance or Practical Music qualification.

2. 42. ABRSM identified the root cause as human error arising from the use of an outdated certificate template when implementing a separate certificate title amendment.

3. 43. Condition A7.1 required ABRSM to take all reasonable steps to prevent the Adverse Effect from occurring and, where any Adverse Effect had occurred, to mitigate it as far as possible and correct it.

4. 44. ABRSM confirmed that a fix was introduced to the system on 13 July 2024, meaning that any certificates printed from that point onwards would contain the correct title. Ofqual asked ABRSM to “explain its rationale behind [its] decision not to reissue certificates”.  On 01 August 2024, ABRSM replied that it had reviewed the following factors:

   1. a. the unit title on the certificates referred to the correct qualifications, even if the qualification title was incorrect

   2. b. only two customers had noticed the wording and requested a reprint.

   3. c. its experience was that on prior occasions where it had reprinted certificates, that exercise had introduced more customer confusion than it had solved.

   4. d. it did not believe that the costs of reprinting all certificates were proportionate to the confusion or ambiguity within the certificates.

   5. e. From 22 August 2024 all learners worldwide would have access to a correct digital certificate for all their qualifications dating back to January 2020, which can be used for validation purposes.

5. 47. Ofqual queried whether ABRSM intended to notify Learners of the issue, even if it did not intend to reissue physical certificates. On 13 August 2024, ABRSM confirmed it did not intend to notify learners of this error. 6. In a letter dated 30 August 2024, ABRSM reversed that position stating:

[it was ABRSM’s] belief that, in line with Condition I4.E, ABRSM has taken reasonable steps to remedy… by correcting all certificates issued after 11 July, and by providing digital certificates for all affected learners… 

Whilst we do not think any further action is necessary to address any adverse effect or to maintain public confidence in the value and integrity of the qualification, we will start to contact Learners in a phased way to explain the difference between their printed and their digital certificate.

1. 47. Ofqual reminded ABRSM of its obligations under General Condition A7 and encouraged ABRSM to consider a more robust response, which included providing Learners with the opportunity to have a re-printed certificate.

2. 48. On 25 September 2024, ABRSM informed Ofqual it would be notifying all Learners, clarifying where the error is on the certificate, reminding them they always have access to a correct digital certificate, and making a time-bound offer for a free reprint.

3. 49. On 15 January 2025, ABRSM confirmed it had received requests for 3,982 certificates to be reprinted and by March 2025 these had all been distributed to customers and no follow-up complaints were received.

4. 50. While 3982 learners requested that the physical certificate was reprinted, that left approximately 68,000 Learners where ABRSM assumed that, in the absence of any response to their explanation, the Learner did not want a physical certificate and was happy to replace their erroneous physical certificate with the new digital certificate. ABRSM did not follow up to check whether learners had accessed and understood the communication.

5. 51. Further, while ABRSM updated all of the digital certificates, it took no steps to request that Learners returned the incorrect certificates, allowing them to remain in circulation notwithstanding the error.

Analysis

1. 52. Ofqual accepts that ABRSM took significant steps to correct the issue. However, those actions were introduced only after regulatory engagement and were not part of ABRSM’s initial response.

2. 53. The scale of the issue was substantial, affecting approximately 72,064 certificates across a range of regulated qualifications. The error was not merely typographical. It related to the description of the qualification and had the potential to affect the understanding of learners, employers, education providers and other users of qualifications. Ofqual considers that making corrected digital certificates available, without proactively notifying affected learners or offering replacement certificates at the outset, was insufficient in the circumstances of the incident. A correct digital certificate would only be of use to a Learner if they knew that their existing physical certificate was erroneous, or when the need next came for the Learner to access the digital certificate.

3. 54. Ofqual considers that one possible approach for ABRSM to take after it had explained the error, drawn attention to the correct digital certificate and offered a replacement paper certificate free of charge, might have been to seek positive confirmation from learners that they had received the digital certificate and did not require a physical certificate, and then sending physical certificates to the remaining learners to ensure that all learners had access to the corrected certificate.

4. 55 Ofqual considers that ABRSM breached Condition I4.1 by issuing inaccurate certificates at scale and breached Condition A7.1 by failing promptly to take all reasonable steps to mitigate and correct the adverse effects arising from that error.

Failure to comply with Conditions

1. 56. ABRSM admits that the evidence establishes breaches of Conditions A5.1, A5.2, A6.1, A6.2, A7.1, A8.1, A8.2, A8.3, G8.1, G9.1, H6.1, I1.1 and I4.1 of its Conditions of Recognition.

Determination of a Monetary Penalty

1. 57. On [DATE], Ofqual’s Enforcement Panel considered the evidence relating to the breaches set out above, together with ABRSM’s representations throughout the enforcement process. The Enforcement Panel determined that ABRSM has breached its Conditions of Recognition in the manner set out in Allegations 1 and 2 above.

2. 58. In determining whether a Monetary Penalty is an appropriate regulatory outcome in this case and, if so, the amount of any such penalty, the Enforcement Panel has had regard to Ofqual’s Supporting Compliance and Taking Regulatory Action Policy (2025).

3. 59. The Enforcement Panel notes the aggravating and mitigating factors set out below.

Aggravating Factors

1. 60. The following factors, as identified within Ofqual’s Supporting Compliance and Taking Regulatory Action Policy, are relevant in this case:

   1. a. the seriousness of the breaches, particularly in relation to their impact upon the integrity of regulated qualifications, and public confidence in qualifications;

   2. b. the effect of the breaches on learners and users of qualifications, including the number of Learners affected;

   3. c. whether the breaches were prolonged, repeated or indicative of systemic weaknesses;

   4. d. the behaviour of the awarding organisation in relation to the breaches, including whether the conduct reveals deficiencies within its governance, systems of control or risk management arrangements;

2. 61. Allegation 1 concerns a series of failings relating to record keeping, data retention and assessment controls which occurred over a prolonged period and in three different operational contexts. Whilst each incident arose from different circumstances, they collectively demonstrate weaknesses in ABRSM’s arrangements for retaining, protecting and retrieving assessment evidence.

3. 62. The consequences of those failures were significant. Assessment recordings for approximately 8,539 Learners were not retained, resulting in 20 Learners being unable to access a review of marking based upon their original assessment evidence. In a separate incident, assessment evidence relating to 16 learners was permanently lost, resulting in delays to the issue of results and depriving the 16 affected Learners of access to normal review arrangements.  In the third incident, ABRSM’s investigation into suspected malpractice involving 710 Learner entries was limited because assessment evidence for 231 Learners had already been deleted, when concerns arose, preventing ABRSM from undertaking a full investigation into those 231 entries. Ofqual considers that the inability to investigate suspected malpractice because the relevant evidence no longer exists represents a serious regulatory failing.

4. 63. The failures identified under Allegation 1 extended beyond individual learner detriment. The ability of an awarding organisation to retain and access assessment evidence is fundamental to the operation of assessments, reviews of marking, appeals, malpractice investigations and certification decisions. The loss or absence of assessment evidence had the potential to undermine confidence in the integrity of ABRSM’s qualifications and regulatory arrangements.

5. 64. The investigation nevertheless identified extensive malpractice, including at least 247 learner entries supported by duplicated videos and 261 resulting findings of malpractice. One video was found to have been reused on 77 separate occasions. The scale of those findings highlights the importance of maintaining assessment records for sufficiently long periods to enable effective malpractice investigations. and heightens the seriousness of ABRSM’s failure to do so.

6. 65. Ofqual further notes that the malpractice investigation exposed weaknesses in learner identity verification procedures. Ofqual considers that these matters demonstrate shortcomings in ABRSM’s assessment control framework and contributed to the risk that learners could be certificated based on evidence that was not genuinely their own.

7. 66. Allegation 2 concerns the issue of approximately 72,064 certificates containing inaccurate qualification titles. The scale of the incident was substantial. Whilst the certificates related to qualifications validly achieved by learners and learners would have been aware of which assessment they had completed, the error had the potential to create confusion regarding the nature of the qualification awarded and to undermine confidence in the accuracy of regulated certification.

8. 67. Ofqual accepts that the incident arose through human error. However, it is concerned by ABRSM’s initial response after the issue was identified. ABRSM’s original position was that affected learners would not be proactively notified and that replacement hardcopy certificates would not generally be issued. Ofqual considers that this approach did not adequately recognise the scale of the incident or the potential impact upon learners and users of qualifications.

9. 68. The breaches identified in this case reveal recurring weaknesses in ABRSM’s operational controls, record-management arrangements and regulatory assurance processes.

10. 69. The case highlights the importance of maintaining robust controls over assessment evidence, malpractice detection, learner protection and certification processes, particularly where qualifications rely on digital systems and digital assessment evidence.

Mitigating Factors

1. 70. Ofqual acknowledges that ABRSM identified each incident itself and made prompt notifications to Ofqual. ABRSM engaged constructively with Ofqual throughout the regulatory process and provided detailed and timely information in response to Ofqual’s enquiries and statutory information requests.

2. 71. Ofqual has not found any evidence that ABRSM acted intentionally in committing the breaches.

3. 72. Ofqual accepts that the first aspect of Allegation 1 arose from a defect within a third-party software application used by ABRSM to manage assessment recordings. The evidence does not suggest that assessment evidence was deliberately destroyed or that examiners knowingly failed to comply with ABRSM’s processes. Rather, examiners relied upon upload confirmations generated by the application and believed recordings had been successfully uploaded.

4. 73. While it ultimately took close to 17 months for the software issues to be resolved, Ofqual accepts that, following identification of the issue, ABRSM worked proactively with the software developer to implement system changes, including the removal of the automatic deletion feature, and the introduction of enhanced retention controls.

5. 74. In relation to the second incident, Ofqual accepts that the deletion of assessment evidence arose from an unusual combination of events, including examiner illness, administrative error and the subsequent loss of access to the examiner’s device. Ofqual also notes that ABRSM promptly provided refunds, additional funding for exam preparation, and offered resits to affected learners.

6. 75. In each case, Ofqual has found no suggestion that recordings were not stored securely or that sensitive learner data was placed at risk. ABRSM confirms that it takes the protection of Learner information seriously, particularly given its safeguarding responsibilities and the nature of the data it holds. Ofqual accepts that there is no suggestion that ABRSM has at any stage ‘lost’ sensitive information.  ABRSM has offered an undertaking to Ofqual that it will commission an audit to provide evidence that the record keeping issues identified at Allegation 1 have been resolved.

7. 76. In relation to the malpractice investigation, Ofqual recognises that ABRSM identified substantial malpractice by one applicant, revoked a significant number of certificates and undertook an extensive review. In this case, ABRSM says that it was a victim of bad actors in an environment where methods of committing online fraud are becoming increasingly sophisticated. Relevant recordings were only unavailable for review as part of this investigation owing to ABRSM’s safeguarding practices, and not as a result of technical failures.

8. 77. In relation to Allegation 2, Ofqual accepts that ABRSM corrected the certificate templates, notified affected learners, provided corrected digital certificates and offered replacement physical certificates free of charge. 3,982 replacement certificates were subsequently issued. ABRSM states that its response to this incident was motivated by a desire to act in the best interests of learners and was based on its industry expertise and analysis of learner behaviour.

9. 78. Ofqual has taken into account the remedial action undertaken by ABRSM following each incident, including changes to data-retention arrangements, appeals processes, malpractice controls and certification processes. Remedial action was commenced by ABRSM prior to Ofqual contemplating enforcement action. These incidents occurred during a defined period of time and have been brought to a conclusion, with actions taken to prevent reoccurrence in the future.

10. 79. Ofqual also notes that ABRSM has no comparable recent regulatory history involving the imposition of formal enforcement sanctions of this nature.

11. 80. ABRSM has presented an action plan to Ofqual detailing substantial investment in its records management processes and wider regulatory improvements.  The action plan indicates a strengthening of procedures and processes to reduce the risk of future breaches.

Other Factors

1. 81. The Enforcement Panel has also considered:

   1. a. the need to deter ABRSM and other awarding organisations from similar failings in the future;

   2. b. the need to promote public confidence in regulated qualifications through visible, proportionate and effective regulatory action;

   3. c. the nature and circumstances of these breaches when compared with other cases in which monetary penalties have been imposed by Ofqual;

   4. d. the degree of learner impact arising from the breaches;

   5. e. the steps taken by ABRSM to remediate the issues identified and strengthen its systems and controls; and

   6. f. the extent to which ABRSM fully engaged with Ofqual during the investigation and enforcement process.

Settlement

1. 82. ABRSM cooperated with Ofqual’s investigation, made admissions in respect of aspects of the allegations and entered into a voluntary settlement agreement in which it agreed to accept Ofqual’s decision.  If ABRSM decides to appeal the final decision, ABRSM agrees that Ofqual may rely on evidence of this settlement in any appeal.

2. 83. Considering that settlement, Ofqual has decided to impose a lower penalty than it would otherwise have imposed in a fully contested case.

3. 84. ABRSM has agreed to pay a monetary penalty in the sum of £150,000.

4. 85. ABRSM has also agreed to pay the sum of £10,000 in full and final settlement of Ofqual’s investigation and enforcement costs. A separate Notice of Costs gives effect to that agreement.

5. 86. ABRSM has agreed to commission, at its own expense, an independent audit of its arrangements for the retention of learner assessment data.

Final Decision

1. 87. Taking all the above matters into account, the Enforcement Panel has determined that the imposition of a Monetary Penalty is a proportionate and appropriate regulatory response to the breaches identified in this Notice.

2. 88. The Enforcement Panel imposes a Monetary Penalty in the sum of £150,000.

3. 89. The Enforcement Panel is satisfied, pursuant to section 151B of the Apprenticeships, Skills, Children and Learning Act 2009, that the amount of the Monetary Penalty does not exceed 10% of ABRSM’s annual turnover.

Payment

1. 90. The Monetary Penalty must be paid within 28 days of the date of this Notice in accordance with the payment instructions accompanying this Notice.

2. 91. In the event of non-payment, interest may be charged and the outstanding amount recovered as a debt in accordance with section 151D of the Act.

Appeals

1. 92. An awarding organisation may appeal to the First-tier Tribunal in respect of Ofqual’s decision to impose the Monetary Penalty and/or the amount of that penalty in accordance with section 151C of the Act.

2. 93. An appeal may be made on the grounds that:
   1. a. the decision was based on an error of fact;
   2. b. the decision was wrong in law; or
   3. c. the decision was unreasonable.
3. 94. Any appeal must be made within 28 days of the date of this Notice. Further information is available from HM Courts and Tribunals Service.

Name: Susan Barratt, Chair of the Enforcement Panel

Date:   7 October 2026

Enforcement Panel:  Susan Barratt, Hardip Begol CBE, David Bowden

NOTE: Ofqual will publish this Notice on its website