Transparency data

Board minutes: 2 July 2025

Updated 30 January 2026

Applies to England

This document has been subject to redactions

Date

Wednesday 2 July 2025                                                                                          

Time

9:30 am

Attendees

Board

Susan Barratt 

Sir Ian Bauckham CBE, Chief Regulator

Hardip Begol CBE  

Mark Farrar

Cindy Leslie 

Dr Catherine McClellan (V)

Chris Paterson  

Clare Pelham (V) 

Matt Tee (V)

Dr Susan Tranter, Chair

Frances Wadsworth CBE            

Ofqual

David Bowden, Executive Director, Finance and Operations

Tom Bramley, Executive Director, Research and Analysis

Daniel Gutteridge, General Counsel

Michael Hanton, Deputy Chief Regulator 

Catherine Large OBE, Executive Director, Vocational and Technical Qualifications

Dr Ian Stockford, Executive Director, Standards

Amanda Swann, Executive Director, General Qualifications

Matt Trimmer, Executive Director, Strategy

Also Present

Tom Barcham, Associate Director, Risk and Markets (Item 09/25 and 10/25)

Richard Garrett, Director of Policy and Strategic Relationships for General Qualifications (Item 12/25)

Jo Handford, Associate Director, Strategic Projects and Innovation (Item 11/25)

Pippa Hall, Director of Strategy and Markets (Items 09/25, 10/25 and 11/25)

Board Secretary

Lydia Waine, Director of Legal Affairs and Governance

Mary Webb, Head of Private Office

Private Secretary

Frances Wilson, Associate Director, Vocational and Technical Qualifications Standards and Issues (Item 11/25)

(V) denotes virtual attendance

02/25         Welcome and apologies for absence

The Chair welcomed everyone to the meeting. 

There were no apologies for absence.

03/25         Declarations of interest

i.       Register of interests 2025 to 2026

The board was presented with the register of interests following on from the annual declaration of interests. One amendment to the interests was noted.

The register of interests for 2025 to 2026 was approved.

ii.      Declaration of interests

There were no declarations of interest for this meeting. 

04/25         Minutes and matters arising

i.       Approval of minutes of meeting held on 19 March 2025

With no amendments, the Minutes of the board meeting held on 19 March 2025 were approved.

ii.      Matters arising from previous board meetings

One matter remains open:

a.     In relation to matter 12/24, the board was advised that the document had been sent to HM Treasury and Ofqual is awaiting their response. The document will be circulated to the board once it is approved by the Treasury. 

All other matters arising have been closed.

iii.     Reports and recommendations from board committees

The chair of the Technical Committee gave a brief oral update to the board on the most recent meeting. The board was recommended to note this meeting considered amendments to the proposed regulatory framework for apprenticeship assessment. 

The chair of the People, Resources and Finance Committee (PRF) gave a brief oral update to the board on the most recent meeting. The board was recommended to note the pause on the People Strategy 2025+ due to the change in senior HR leadership. An interim Director for HR had now been appointed. The discussions concerning the Annual Report would be covered during the item to appear later on the agenda. 

The chair of the Audit and Risk Assurance Committee (ARAC) gave a brief oral update to the board on the most recent meeting. The board was recommended to note the Committee’s discussion on the presumed risk of management override of controls and expenditure limits for RDEL/CDEL. The new Cabinet Office guidance on declarations of interest had been discussed and the Committee had requested a review of the relevant policies for the next meeting. The discussions concerning the Annual Report and strategic risk would be covered during the items to appear later on the agenda. 

iv to vii.        Minutes from board committee meetings

The approved minutes from all previous board committee meetings that had taken place since the last board meeting were received and noted.

05/25         Decisions taken by electronic business

No decisions had been taken by electronic business since the previous board meeting. 

06/25         Chief Regulator’s report

The board received an update from the Chief Regulator.

The board was advised that Ofqual’s strategy for the next 3 years had been successfully launched and well received by stakeholders.

The interim report from the Curriculum and Assessment Review (CAR) had been published on 18 March. The final report is expected to be published in the autumn. 

The Chief Regulator advised that the formal transfer of IfATE’s functions to the Secretary of State and accordingly Skills England had taken place on 1 June. Ofqual’s good working relationship with the new leadership continues. The board noted that the new priorities set out by Skills England align well with Ofqual’s remit. 

As mentioned in the oral update by the chair of the Technical Committee, the Committee had met twice since the last board meeting to discuss apprenticeship assessment reform, including how foundation apprenticeships could be accommodated within the regulatory framework. The second meeting had been convened under the urgency arrangements following additional information received from the DfE on their developing policy intentions for apprenticeship assessment reform. The consultation was now live. The board was advised that the consultation proposals were mentioned in his keynote speech at the AELP National Conference in June. 

The board was advised the general qualification (GQ) summer series had now finished and had been reasonably smooth. Event Notifications (ENs) received to date were in line if not tracking slightly lower than 2024. 

The board noted there were no concerns about examiner recruitment and marking was progressing well. 

The board was advised the aim of awarding for general qualifications in summer 2025 was to carry forward standards from summer 2024. However, the absence of key stage 2 (KS2) prior-attainment data, due to the cancellation of KS2 tests in 2020, would require a slight difference in the process for predicting grade boundaries than in previous years. Work had been led by the exam boards to explore the use of Aggregate Common Centres (ACC). This was found to be an appropriate approach as it was a well-established technique in educational assessment and used both in specific contexts in England and in other jurisdictions.

The board was reminded that the National Reference Tests in English language and maths had been administered in February and March. Ofqual had now been briefed on the results. The decision as to whether to require adjustments to grading standards in English and maths would be made by the Chief Regulator and published alongside the GCSE results. 

The board was advised that significant work had been undertaken to review evidence relating to the use of access arrangements including reasonable adjustments. Preliminary findings had suggested a discrepancy in the access arrangements data that informs Ofqual’s official statistics. Potential areas for wider action had been identified. 

With regard to the regulation of National Assessments, the board was advised that KS2 delivery had gone smoothly and marking was now complete. Return of results would be on 8 July and no concerns had been raised. 

The board was advised that Ofqual had responded to the DfE consultation on the proposed changes to the Early Years Foundation Stage Profile assessment (EYFSP). 

The board was given an update on the development of a GCSE in British Sign Language and was advised the technical consultation had now closed. Despite some areas of challenge, in most cases relating to the intended audience for the qualification, the response had been mostly positive. Recommendations for decisions on the consultation would return to the Technical Committee as previously delegated by the board. 

The board was advised the consultation on the proposed amendments to the ‘Taking Regulatory Action’ policy had now closed. The board would be presented with recommendations arising from the analysis at the October meeting. 

The Chief Regulator advised that the regulation of Awarding Organisations’ (AOs’) use of AI continues to be of significant interest. Ofqual is currently scoping work to consider further how to mitigate risks around students’ use of AI in non-exam assessment (NEA). A series of workshops would be held with AOs in the autumn. The board was advised that Ofqual continues to develop the use of AI internally with the aims of driving efficiency and effectiveness. 

The board was advised that Ofqual had published its annual Qualification Price Statistics in late June. The board asked if there were any specific themes driving the price increases. The board was advised there were no specific themes; price increases were just above consumer price inflation for the reporting period but had been below consumer price inflation across a 4-year period. 

The Chief Regulator was pleased to advise the board that Ofqual had gained ISO27001 accreditation which was the international standard focused on information security. 

07/25         Ofqual annual report and accounts 2024 to 2025 

i.       Finance update

The board was presented with the completed position for the financial year 2024 to 2025.

At the end of the financial year, the board was advised that the figures showed a Resource Departmental Expenditure Limit (RDEL) underspend of £91,000 and a Capital Departmental Expenditure Limit (CDEL) underspend of £1,000. The total outturn of £30,956,000 was comfortably within the 2% threshold of the 2024 to 2025 Supplementary Estimate of £31,048,000. In accordance with HM Treasury’s financial performance metrics, financial outturn is required to be within 1% of the forecast in period 6 (September) and this had been delivered.

The board was advised that, going into the audit process, RDEL underspend was at approximately £300,000. However, the holiday pay accrual as originally forecast had excluded the full calculation of on costs which had arisen due to the large amount of manual reconciliation which had been required. After all adjustments had been made, RDEL underspend was at just under £100,000 against the control limit. 

The ED, Finance and Operations gave an oral update on the current financial position which was broadly in line with budget.

The board was updated on the conclusion of the spending review. Ofqual had been given a flat cash settlement which would mean some efficiencies would have to be found but it was, overall, a good outcome. The board was advised that Ofqual had not received any direct funding for potential work resulting from CAR. 

ii.      Receive the annual report on governance, risk management and control 

Following the Audit and Risk Assurance Committee meeting on 20 June 2025, the board received the annual report on governance, risk management and control from the chair of ARAC.

The report provided assurance to the board on the scale and scope of ARAC’s activities during the period 01 April 2024 to 31 March 2025. The report also provided an overview of the scale and scope of the assurance activity undertaken during that period.

iii.     Ofqual Annual Report and Accounts

The executive director (ED), Finance and Operations advised that the Ofqual Annual Report and Accounts had been presented to ARAC on 20 June 2025 and that it had also been endorsed for consistency with financial performance through the year by the People, Resources and Finance Committee at its meeting on 18 June 2025. 

The board noted this was not the final version of the report but a mature draft. It reflected the financial results presented earlier in the meeting.

The board was advised that there had been some detailed feedback from both committees which had already been incorporated into the draft. 

iv.     Receive the audit completion report and management representation letter

The board received the audit completion report and was advised by the ED, Finance and Operations that this was largely complete. Three additional risks had been identified by the auditors which had resulted in extra work being required but, to date, no mismanagement or misstatements had been identified in relation to these new risks. 

Subject to completion of any outstanding procedures, the 2024 to 2025 financial statements would be certified with an unqualified audit opinion without modification in respect of both regularity and the true and fair view on the financial statements.

The board noted the deadline for presentation of the annual report and accounts was 17 July. 

The Chief Regulator, as Accounting Officer, confirmed to the board that there were no material matters of which Ofqual was aware that had not been disclosed to the board, as well as to the external auditors.

The board noted the draft management representation letters. 

v.      Receive the recommendation of the Audit and Risk Assurance Committee to approve the annual report and accounts

The chair of ARAC communicated the committee’s recommendation that the board approve the draft annual report and accounts.

RESOLVED

The board agreed to:

i.       Note the financial position presented.

ii.      Note the scale and scope of the Audit and Risk Assurance Committee’s activity during the year.

iii.     Note the scale and scope of the assurance activity undertaken by the Audit and Risk Committee during the year.

iv.     Receive and approve the annual report on governance, risk management and control.

v.      Receive the draft annual report and accounts 2024 to 2025.

vi.     Receive the audit completion report from the external auditors and the management representation letters.

vii.    Receive the recommendation from the Audit and Risk Assurance Committee on the draft annual report and accounts 2024 to 2025.

viii.   Approve the draft annual report and accounts 2024 to 2025.

ix.     Delegate final sign-off of the annual report and accounts 2024 to 2025 to the Chief Regulator prior to publication. 

08/25         Annual report on health and safety

The annual Report on health and safety was presented to the board by the ED, Finance and Operations. 

The board asked about health and safety for people who work from home. The board was assured that all appropriate care was taken for staff working from home. Mandatory health and safety training for all staff includes a self-assessment of the home working environment. Appropriate advice would be given should any recommendations arise. In addition, on joining Ofqual, enquiries are made to ensure staff have the correct equipment at home and this can be acted upon if necessary and help given.

The board asked how Ofqual receives assurance that statutory regulation has been complied with where third parties are responsible for the wider office building. The board was advised that Ofqual has a good working relationship with the management of Friargate and holds regular meetings with them. Any certificates required for building maintenance were carried out by the Government Property Agency (GPA) and Ofqual would be aware if anything was not in place. In addition, Ofqual was responsible for its own floor maintenance and would ensure compliance. 

RESOLVED

The board resolved to approve the annual report on health and safety.

09/25         Strategic risk and risk tolerance

The Associate Director, Risk and Markets presented the strategic risk register to the board. 

RESOLVED

The board noted the changes in the Risk Register and approved the proposed risk tolerances.

10/15         Supporting growth: Regulatory efficiency report

The Director of Strategy and Markets presented the report to the board.

The board was reminded that Ofqual has a legislative duty to keep its regulatory functions under review and to not impose or maintain any unnecessary regulatory burden. The board was advised that this year’s report had been refocused from ‘reducing burden’ to ‘increasing efficiency’ and this had been emphasised by the change of name of the report. The publication date had also been moved to coincide with the publication of the annual report and accounts.

The board was advised that the report related to Ofqual’s new Corporate Strategy 2025 to 2028 and in particular to the ‘strengthen’ objective. The report also reflected HM Treasury’s new approach to ensure regulators and regulation support growth. 

The board was advised this was not the final version of the report but a mature draft.

The board acknowledged the change of title of the report and the refocused approach as outlined above. 

RESOLVED

The board agreed to:

i.       Endorse the Supporting Growth: Regulatory Efficiency Report 2025, acknowledging that this is a substantive draft which is subject to the further amendments as discussed.

ii.      Delegate to the Chief Regulator, in consultation with the Chair, final approval for publication of the statement. 

11/25         Regulatory approaches for on-screen assessment

Following previous discussions with the board, Ofqual was seeking the board’s agreement that the principles before them reflected deliberations so far; endorsement of the direction of travel; and approval of a set of detailed recommendations arising from the previous discussions. 

The board was supportive of the recommendations and direction of travel. It requested that when proposals are brought back to the board in October, a communications plan is included. 

RESOLVED

The board agreed to consult on the following:

i.       Configuration of specifications:

         a.    On-screen assessment should be offered as a separate specification from paper-based assessment.

         b.    Specifications may include both paper and on-screen components, but choice between modes within a specification is not allowed.

         c.    Identical questions across on-screen and paper-based assessments should be avoided to manage expectations around grade boundaries, though limited overlap may support standards.

ii.      Paper-based provision:

         a.    Ofqual should not require awarding organisations to offer a paper-based version where an OSA specification is introduced, though access and equity implications will be tested through consultation.

iii.     Platforms and devices:

         a.    Use of a common single OSA platform will not be mandated.

         b.    Statutory guidance should be developed to support consistency, accessibility, security, familiarisation and manageability across platforms and devices.

         c.    Bring Your Own Device (BYOD) should not be permitted.

         d.    Dual-use devices (for both learning and assessment) should be allowed, provided security is robust.

12/25         Introducing Principles into Ofqual’s Regulatory Framework – consultation outcomes

The Director of Legal Affairs and Governance reminded the board that at its meeting in July 2024 it had agreed to consult on introducing 6 Principles into the General Conditions of Recognition (GCR). The board was advised that consultation had taken place between November 2024 and February 2025. 

The board was reminded that Ofqual’s current regulatory framework was largely outcomes-focused. The introduction of the Principles was intended to bring about a number of benefits, including increasing clarity in Ofqual’s framework, strengthening the framework to protect the interests of students and driving better behaviours from AOs. It was noted that principles-based approaches were used to good effect by many other regulators and would ensure Ofqual has a modern framework with the tools available to meet its objectives. 

The board was advised that Ofqual had received a range of views from the consultation. There had been clear agreement to the intent behind the Principles and that they reflect appropriate behaviours and standards that should be expected of AOs, with support from some respondents for the approach proposed. The concerns expressed were mainly about duplication of, or overlap with, existing requirements, the perceived difficulty and additional regulatory burden that it was felt would arise for AOs in evidencing compliance, and the view the Principles were ‘subjective’ in nature. There were concerns expressed from some about what this might mean for regulatory action and/or enforcement. This all informed a view from some respondents that the Principles should not be a Condition of Recognition. Overall, there were slightly more negative than positive responses. The majority of the more negative reaction came from AOs.

The Director of Policy and Strategic Relationships for General Qualifications noted that this feedback had been reflected in the proposed approach to implementation of the Principles. It was proposed that Ofqual would take steps to minimise any reporting burdens placed on AOs and phase the implementation of the introduction of the Principles to make sure AOs have time to adjust to their introduction. It was also planned that Ofqual would take steps to build AOs’ understanding of Ofqual’s approach and decision-making processes, particularly through the introduction of new ‘advice notes’ on the Principles and enforcement. 

The board discussed the feedback from the consultation and the steps being taken to address this. It was noted that some of the feedback highlighted a lack of understanding. The board agreed that one of the ways to address this would be through the proposed advice notes which, whilst not binding, could be used to help AOs understand their obligations and to shape and influence behaviours.

The board asked whether Ofqual had considered implementing the Principles as additions to the GCR, rather than as an additional layer of regulation. It was noted that there was one Principle in particular where the wording was very similar to an existing Condition. Ofqual advised that it had given this option considerable thought but had judged such an approach would see amendment to a large number of rules and guidance across the framework and would be more disruptive and burdensome. The similarity in wording between the Principle and Condition was intentional and, in part, a consequence of the Principles not having been built into the regulatory framework from the start of Ofqual’s existence.

It was agreed that where consultation feedback had not been implemented, it was important to communicate the reasons for this and it was noted that Ofqual planned to do this when setting out the reasons for its decisions. 

The board expressed its positive support for the introduction of the Principles into Ofqual’s regulatory framework.

RESOLVED

The board agreed:

i.       That Ofqual should implement, into the regulatory framework, the Principles Condition, which includes the principles as consulted on, and the associated statutory guidance.

ii.      To delegate the sign-off of the Principles Condition, statutory guidance and the analysis and decisions documents that detail the outcomes of the consultation to the Chief Regulator in consultation with the Chair.

13/25         Publication of papers

The board agreed to publish the Open Papers.

14/25         Any other business

i.       End of term of office

The Chair advised the term of office for Frances Wadsworth CBE was due to end on 30 September 2025 and this would therefore be her last meeting. The Chair and Chief Regulator both warmly thanked Frances for her contribution to the board and Ofqual’s work during her 3 terms of office, including one year as interim Chair.

Next board meeting:

The next board meeting will be held in London on Wednesday 8 October 2025.

The meeting ended at 12:55 pm.