Board minutes: 8 October 2025
Updated 30 April 2026
Applies to England
© Crown copyright 2026
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This publication is available at https://www.gov.uk/government/publications/ofqual-board-minutes-for-2025/board-minutes-8-october-2025
This document has been subject to redactions.
Date
8 October 2025
Time
9:15 am
Attendees
Board
Susan Barratt
Sir Ian Bauckham CBE, Chief Regulator
Hardip Begol CBE
Mark Farrar
Kurt Hintz
Cindy Leslie
Dr Catherine McClellan
Chris Paterson
Andrea Rigamonti
Matt Tee (V)
Dr Susan Tranter, Chair
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 (V), Executive Director, General Qualifications
Matt Trimmer, Executive Director, Strategy
Also Present
Matthew Humphrey, Director of Legal Moderation and Enforcement (Item 24/25)
Board Secretary
Emma Scott, Director of Operations for Vocational and Technical Qualifications (Item 25/25)
Lydia Waine, Director of Legal Affairs and Governance
Mary Webb, Head of Private Office
Private Secretary
(V) denotes virtual attendance
16/25 Welcome and apologies for absence
The Chair welcomed everyone to the meeting. In particular, the Chair welcomed 2 new board members, Kurt Hintz and Andrea Rigamonti.
Apologies for absence were received from Clare Pelham.
17/25 Declarations of Interest
i. Declarations of Interest
There were no declarations of interest for this meeting.
ii. Gifts and Hospitality Register
The General Counsel advised the board that this item was being brought to the meeting following a recommendation from an internal audit. The register had also been presented at the recent Audit and Risk Assurance Committee (ARAC) meeting. The board was asked to consider whether to delegate oversight of the register to ARAC for review on an annual basis.
RESOLVED
The board agreed that oversight of the Gifts and Hospitality Register be delegated to the Audit and Risk Assurance Committee.
18/25 Minutes and matters arising
i. Approval of minutes of meeting held on 2 July 2025
With no amendments, the minutes of the board meeting held on 2 July 2025 were approved.
ii. Matters arising from previous board meetings
All 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 noted that this meeting had considered the post-consultation recommendations for the regulations and final proposed wording of the Subject Level Conditions, Requirements and Guidance for GCSE British Sign Language.
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 noted the extent of the work being undertaken within Data, Digital and Technology and, in particular, the future technology programme. The committee felt that this should be shared with the wider board. Ofqual would consider the best way to do this. The paused People Strategy would be presented at the next PRF meeting as the People Plan. The committee had welcomed the annual Value for Money report.
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 advised that there had been a useful discussion on the audit and the high external audit fees. The National Audit Office (NAO) had agreed that Ofqual would pay the accrued amount with the NAO absorbing the additional costs. Two completed internal audit reports had been presented. The board was asked to note that an update on the number of complaints received by Ofqual was presented. No concerns had been raised. The discussions concerning strategic risk would be covered during the item to appear later on the agenda.
iv to vi. 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.
19/25 Decisions taken by electronic business
The board noted one item of electronic business since the previous Board meeting:
i. E01/25: Re-appointment of board committee members (approved 15 September 2025)
20/25 Chief Regulator’s report
The board received an update from the Chief Regulator.
The board was presented with an update on the delivery of Ofqual’s strategy during Q1 2025 to 2026. Progress had been made across all 5 objectives.
The recently announced Machinery of Government changes were outlined by the Chief Regulator. Practicalities of the changes would be worked through with the DfE as part of the qualification reform programme. The board was advised that the leadership of Skills England would remain the same so the good working relationship already developed would continue.
The Chief Regulator advised that Ofqual was pleased with the positive engagement with its consultation on a revised regulatory framework for apprenticeship assessment following publication of the DfE’s principles for apprenticeship assessment. Constructive responses had been received. No major adjustments were anticipated as a consequence of the consultation feedback. The board was advised that the next step would be Skills England’s publication of the first five assessment plans.
The board was advised that delivery of the GQ summer series had been reasonably smooth. Standards had been maintained. Event notifications for the series were tracking at a broadly similar level to previous years with assessment material errors below 2024 levels and security breaches above. The latter were largely errors by centre staff. Media reporting had been good. Overall, there were no serious concerns regarding delivery.
Delivery of Vocational and Technical Qualifications (VTQs) results was on time and the board was advised that there were no concerns about standards.
The board was reminded that, as usual, a report on the delivery of the 2025 exam series would be published in December. This would also be sent to the Education Select Committee.
The outcome of the 2025 National Reference Test (NRT) was published on GCSE results day. The NRT gives a reliable indication as to whether standards are changing over time. The board was advised that this year’s data showed some small variations but there were no significant upward or downward trends. The Chief Regulator had made the decision that there was no requirement for exam boards to make adjustments to grading standards in light of the NRT results.
The board was reminded that Ofqual had withdrawn its official statistics on access arrangements for 2014 to 2024. It had identified that the prevalence of access arrangements had been significantly overstated due to the way data had been recorded. Ofqual was currently working with the exam boards to secure long-term improvements to data quality and reporting. The 2024 to 2025 statistics would be published in late autumn.
The board was advised that delivery of national assessments in 2025 had been successful. Delivery was moving to a new provider next year and transition risks would be monitored.
The board discussed the Early Years Foundation Stage Profile (EYFSP) consultation. It had been agreed that changes would not be implemented this year but from September 2026. It was noted, however, that changes would not include EYFSP data being used directly for external school accountability. Schools would receive the data and be able to compare their pass rates with similar schools. The board was advised that Ofqual would continue to engage with DfE EYFS colleagues as well as other stakeholders on the uses of this data.
The board was informed of a variety of work undertaken around Artificial Intelligence (AI). A series of successful engagement sessions with AOs and subject matter experts to share and test work on principles of AI use in marking had been held with positive feedback and strong support for Ofqual’s research and approach. Ofqual had presented at an OECD panel discussion on responsible AI use in education assessment. The first in a 5-part series of online workshops for AOs had also taken place which focused on innovative use of AI in the design and delivery of qualifications and assessments.
Ofqual had hosted a one-day conference entitled ‘What is the future of Outcome-Based Qualification Design’. Ofqual’s CASLO research was promoted along with the importance of debate and capacity building in this area. The board was advised that the event had been very well attended and was an indication of both Ofqual’s convening power and the importance of Ofqual’s ongoing leadership in VTQ assessment research.
The board was advised that Ofqual was not scheduled to give oral evidence at the COVID-19 Inquiry – the inquiry had informed Ofqual that it did not wish to hear from Ofqual in person. A written statement had been submitted to the inquiry and it was possible that a further written statement at the end of the process might be submitted.
21/25 Structure refresh – preparing for reform
The board was reminded that Ofqual was structured as a number of distinct directorates. Currently, there was one overseeing General Qualifications and one overseeing Vocational and Technical Qualifications. With the expected government proposals for reform, Ofqual had concluded that a refresh to its current structure would enable better deployment of resource to balance Ofqual’s role in reform with its business as usual regulatory work. The refresh and consequential changes would also serve to reduce the number of points of contact for stakeholders and AOs and reduce burden accordingly.
The key changes were outlined. These were the creation of a new Policy directorate and a new Delivery directorate replacing the existing GQ and VTQ directorates. A further change was to combine strategic relationship management with communications within the existing Strategy directorate.
With board approval, the intention was to brief the organisation and put in place a full communications and change plan with appropriate support for colleagues across the organisation.
RESOLVED
The board agreed to the changes to the executive structure of Ofqual.
22/25 Finance update
The board was presented with the financial position at Period 4. This was forecasting a full year Resource Department Expenditure Limit (RDEL) overspend of £217,000 and a Capital Department Expenditure Limit (CDEL) in line with allocation at £450,000.
An oral update was given by the Executive Director, Finance and Operations. The forecast at Period 5 was similar to that at Period 4. However, the forecast at Period 6 was expected to show RDEL at about £100,000 underspend and back on track.
The board asked about costs that might arise from reform. The Chief Regulator advised that Ofqual had already discussed likely reform costs with the DfE and would continue to engage closely to ensure the best possible outcome.
23/25 Strategic Risk and Risk Tolerance
The Executive Director, Strategy, reported that the Risk Register had received its first update since the summer awarding period and highlighted the key changes since the last meeting.
An overview of the strategic risk profile over a 12-month period from September 2024 to August 2025 had been shared with ARAC. This showed all the risks that had been opened and closed and changes in overall assessment rating during that period.
24/25 Regulatory approaches for on-screen assessment
The Executive Director, Strategy, reminded the board of the importance for Ofqual to determine policy positions to address the risks of on-screen assessment to ensure clarity for schools, colleges and awarding organisations. It was noted that this would require balancing Ofqual’s role as guardian of standards and its objective to promote public confidence in qualifications with its duties to facilitate innovation and have regard to the desirability of promoting economic growth. The board noted and welcomed the government’s commitment to digital innovation in education but recognised the need for it to be carefully managed.
The board was advised that the Secretary of State (SoS) intended to send a ministerial steer letter to Ofqual setting out considerations and principles for the use of on-screen exams.
The board discussed the new proposals. The board expressed the importance of ensuring that on-screen assessment would not create additional inequity in the education system. Ofqual’s proposals were designed so that standards and confidence in qualifications could be maintained. Ofqual was committed to conducting further research on mode effects and digital divide during this period. The board asked to be kept advised on plans for this research.
With apologies, Amanda Swann left the meeting at 12:00 p.m.
RESOLVED
The board agreed to:
i. Consult on a managed approach for on-screen assessment.
ii. Consult on Ofqual’s high-level policy positions.
iii. Consult on proposals in relation to reasonable adjustments.
iv. Delegate the sign-off of the policy consultation to the Chief Regulator, in consultation with the Chair.
v. Note the proposed timings and communications approach.
With apologies, Matt Tee left the meeting at 12:15 p.m.
25/25 Taking Regulatory Action Policy
The board was reminded of the previously agreed proposals to changes to the Taking Regulatory Action (TRA) policy from meetings in March 2024 and December 2024. The proposed changes were subject to public consultation which ran from February 2025 to May 2025.
The board was advised that there had been 28 responses to the consultation. One of the respondents had been the Federation of Awarding Bodies (FAB). They had held a well-attended meeting of their members to generate one collective response. The majority of the respondents had agreed with the proposals.
RESOLVED
The board agreed to:
i. Create an appeal route, to the Enforcement Panel, in relation to determinations of non-compliance and rebukes, as proposed.
ii. Change how Ofqual uses the Notice of Intention in fining cases:
a. Publication of the Notice to be at the discretion of the decision-maker.
b. Permitting the Notice to be issued by a Director in the Legal Team.
iii. Remove the proposed section of the policy relating to Centre Concern Notices.
iv. Delegate final decisions as to the wording the TRA policy, and the analysis and decisions document to the Chief Regulator, in consultation with the Chair of the Board and the Chair of the Strategic Enforcement Committee.
26/26 Qualification Fraud update
The board was given a presentation on the work being undertaken by Ofqual on the prevention of fraud in the sector. The aim was to build resilience across the qualification sector with a view to reducing the opportunity for qualification fraud to take place as well as improving understanding and awareness, and reducing the harm caused.
The board was advised that this was a multi-year project. Initiatives such as the Fraud Prevention advice note had been launched, which a large number of AOs had signed up to. A second summit of sector leaders, chaired by Ofqual, had taken place a few days before the board meeting. The Chief Regulator advised that this had shown a strong appetite for collaborative working.
The board welcomed the work being carried out in this area and recognised the leadership role being taken by Ofqual.
27/25 Publication of papers
The board agreed to publish the Open Papers.
28/25 Any other business
i. Board and committee meeting dates
A schedule of dates for the board and committee meetings for the next year’s meetings was presented to the board for approval.
RESOLVED
The board approved the schedule of board/committee meeting dates for 1 April 2026 to 31 March 2027.
ii. Appointments to board committees
It was proposed that the board consider a proposal for Andrea Rigamonti to be appointed to the People, Resources and Finance Committee and for Kurt Hintz to be appointed to the Audit and Risk Assurance Committee. This was approved.
RESOLVED
The board approved the appointment of Andrea Rigamonti to the People, Resources and Finance Committee and the appointment of Kurt Hintz to the Audit and Risk Assurance Committee.
Next board meeting:
The next board meeting will be held in Coventry on Wednesday 10 December 2025.
The meeting ended at 1:00 pm.