Chief Regulator’s report: 2 July 2025
Updated 30 January 2026
Applies to England
This document has been subject to redactions
Date
2 July 2025
Title
Chief Regulator’s report
Report by
Sir Ian Bauckham, Chief Regulator
Paper for information and discussion
Recommendations
1. The board is asked to note the matters reported.
Overview
2. This has been a busy period for Ofqual. Since the board last met, we have successfully launched Ofqual’s strategy for the next 3 years, and we have made good progress on a number of key policy areas. We have also overseen delivery of the summer exam series by awarding organisations and I am pleased to report this has gone relatively smoothly to date.
3. Ofqual continues to work closely with DfE on the government’s priorities for education, including the establishment of Skills England, apprenticeships reform and the Curriculum and Assessment Review (CAR).
4. Work is progressing well on plans for the regulation of on-screen assessment. Our proposals will be considered under a separate agenda item.
5. A separate paper is also to be considered on the decisions arising from our consultation to introduce a ‘Principles’ condition into Ofqual’s regulatory framework. The proposals the board is being asked to consider follow careful analysis of the consultation responses, and extensive internal test and challenge.
6. For a third year we hosted a successful Symposium for AOs. Becky Francis attended to speak about the work of CAR. A further forum focusing on our expectations of effective governance in regulated AOs is planned for the autumn. The aim of these events is to strengthen AOs’ Capacity, Capability and Governance (CCG). We plan to bring to the board an update on the wider CCG programme later this year.
Corporate Plan 2022 to 2025 and the launch of the new Strategy for 2025 to 2028
7. In April we transitioned from Ofqual’s 2022 to 2025 Corporate Plan to our Strategy for 2025 to 2028.
8. Ofqual’s new strategy was published in May and has been well received by stakeholders. Quarterly reporting will evolve to align to the new strategy and will continue to be shared with board.
Curriculum and Assessment Review
9. CAR published its interim report on 18 March setting out initial findings. The report positively reflected Ofqual’s response to the Call for Evidence and our subsequent advice on specific policy areas.
10. Ofqual’s attention now turns to supporting development of proposals to inform the final CAR report.
11. Ofqual’s contributions have been well received by the CAR panel. We expect engagement will continue over the summer with a view to a final report being published in the autumn.
12. Ofqual has begun preparing for implementation.
13. The DfE is expected to publish a skills strategy in July. The extent to which this will reflect emerging CAR priorities is still being worked through.
Skills England
14. The IfATE Transfer of Functions Bill received Royal Assent on 15 May, including the power for the Secretary of State to permit Ofqual to accredit specific technical qualifications from 1 June 2025. The formal transfer of IfATE’s functions (and staff) to Skills England took place on 1 June. Skills England announced their new board on 2 June, several of whom are known to us.
15. The new Skills England priorities set out by the Secretary of State, published on 2 June, align well with Ofqual’s remit.
16. We continue to engage with DfE officials on long-term system improvements to ensure that the technical education system functions effectively and efficiently.
Apprenticeships
17. Ofqual’s Technical Committee has met twice to discuss apprenticeship assessment reform. The second meeting was convened under the urgency arrangements following additional information from DfE on the policy intention on apprenticeship assessment reform. The Committee has agreed proposals for a revised regulatory framework for apprenticeship assessment following the publication of DfE’s new principles for apprenticeship assessment in February.
18. DfE has announced the introduction of foundation apprenticeships. Occupational standards and assessment plans have been developed for 7 new foundation apprenticeships, and DfE intends these to become available from August. The Technical Committee has agreed that the regulatory framework for apprenticeship assessments will also apply to foundation apprenticeships.
19. I and the Chair agreed the final wording of the apprenticeships assessment consultation document, in line with the Committee’s delegation. The consultation was launched on 20 June and will close on 27 August.
Level 3 Post 16 review
20. The spring submission window commenced on 21 March.
21. Ofqual will provide high level feedback to Skills England and DfE on the submissions in late July, with detailed reports to follow by 7 August. DfE expects to announce funding decisions in September 2025 for enrolments from August 2026.
Summer series 2025
General Qualifications
22. The GQ series has gone reasonably smoothly to date. At the time of writing, Event Notifications (ENs) to Ofqual regarding assessment material errors and breaches are in line with 2024. Delivery failures are tracking lower than in 2024. Approximately half of ENs relate to assessment material errors that were identified and addressed before learners sat papers.
23. The last GCSE was sat on 19 June and GCE on 23 June. The general qualification (GQ) series concluded on 24 June with the sitting of Pearson’s Advanced Extension Award in maths.
24. Exam boards have not reported any concerns about examiner recruitment or availability in particular subjects entering the marking period. Marking is progressing well, with all exam boards on track or ahead of where they were at the same point last year.
Vocational and Technical Qualifications
25. The Vocational and Technical Qualification (VTQ) series has also gone smoothly to date, with ENs overall tracking slightly below volumes at the same point in 2024. As for GQs, assessment material errors are the highest event type being reported.
26. The last external VTQ exam was on 25 June.
27. Centre understanding of the terminal rule for Tech Awards appears to have improved and no issues have been identified to date.
28. The VTQ Results Group of AOs and sector stakeholders continues to meet regularly to monitor progress towards the timely delivery of VTQ results in August. All AOs submitted term-time checkpoint data on time and this has indicated no issues so far.
T Levels
29. Delivery of assessments for Technical Qualifications in T levels has gone smoothly to date, with no significant issues arising.
30. Reviews of a sample of assessment materials taken this summer continue. Pathways have been targeted due to risk, entry size, or where these are being sat for the first time. No significant issues have been reported so far.
31. The last T Level assessment – NCFE Science – was sat on 20 June.
Post series review
32. As in every year, we will conduct a full analysis of delivery after the summer series and will report final data in our annual delivery report in December.
Engagement with DfE
33. We held meetings on exam delivery with DfE senior officials and ministers in advance of the exam series. These meetings have been constructive and well received.
Awarding in summer 2025
34. The aim of awarding for general qualifications in summer 2025 is to carry forward standards from summer 2024.
35. The absence of key stage 2 (KS2) prior-attainment data for this year’s GCSE 16-year-old cohort (due to the cancellation of KS2 tests in 2020) requires a change to the analysis most commonly used to support the awarding of GCSEs and that Ofqual uses for the purposes of monitoring. Technical work led by the exam boards, to explore the use and refinement of Aggregate Common Centres (ACC) analysis for these purposes, is complete, and has found it to be an appropriate approach. ACC is a well-established technique which features as a potential source of evidence to support awarding even in years where KS2 data are available. Other aspects of the awarding process will remain unaffected.
National Reference Test 2025
36. The National Reference Test (NRT) 2025 was successfully delivered in schools in February and March. Ofqual has been briefed on NRT results and I have taken a decision on whether to require adjustments to grading standards in English and maths. Details of the decision will be published alongside the release of GCSE results on 21 August 2025.
Access arrangements
37. We are progressing work to review evidence relating to use of access arrangements, including 25% extra time. This includes work to better understand the GCSE and A level access arrangements data set that informs Ofqual’s official statistics.
38. We have briefed senior DfE officials on our work in this area and plan to brief ministers ahead of the parliamentary recess.
Communications and stakeholder engagement
39. Implementation of our 2025 to 2026 communications strategy is underway. This includes pre series work to enhance cyber security and to reduce malpractice, and the commencement of our campaign to improve understanding of grading.
40. The grading campaign included a mini campaign on social media to promote a teacher-facing toolkit, which was well received and resulted in media coverage, and a background briefing to Schools Week with the aim of improving the editorial team’s understanding of how grading works.
41. We have launched a new visual identity, including updated brand guidelines, templates for internal documents, and look and feel for external communications products (such as social media content).
42. Our regular engagement with stakeholders continues. I delivered a speech in May to FAB’s board and senior leaders of their membership organisations on a range of topics including Ofqual’s new strategy, ongoing reforms, and advances in AI. I am due to give a keynote speech at FAB’s conference in November. I also spoke at an AELP national conference in June, focusing largely on apprenticeships reform, and will be speaking to an audience at Wellington Festival of Education on 3 July on Ofqual’s perspectives on the future of assessment.
43. As usual, we will be pre briefing journalists ahead of August results with the aim of supporting well informed reporting on results days.
Regulation of National Assessments
KS2 delivery
44. Scanning and on screen marking of KS2 tests has come to an end on schedule with c3,750,000 scripts marked at the time of writing (equal to 99.6% of all scanned scripts marked). Handover of marking data from Capita to the Standards and Testing Agency (STA) was achieved by 18 June.
45. Formal standards maintenance is due to take place on 3 July, with Ofqual and unions in attendance. Return of results is on 8 July. STA is not raising any concerns regarding return of results.
46. This is the last year of Capita’s contract to deliver the KS2 tests, with Pearson taking over from September 2025. Ofqual will be monitoring this transition closely.
Phonics Screening Check
47. The Phonics Screening Check for year 1 pupils was administered in schools until 20 June. No issues have been reported to us to date.
Reception Baseline Assessment (RBA)
48. A new version of RBA will be rolled out by STA in late August 2025. Two touchscreen devices will be used to deliver the assessment: one for the practitioner (to administer the assessment) and one for the pupil to give their answers.
49. Ofqual held a readiness review with STA in March where they provided assurances on the functioning of the assessment and the digital system based on trialling and testing, as well as user research.
50. The platform went live on 2 June to allow schools to familiarise themselves with the technology. STA has not reported any issues regarding schools’ experiences of using the platform so far. Ofqual continues to monitor closely.
Development of GCSE in BSL
51. Our technical consultation on the draft conditions, requirements and guidance for GCSEs in British Sign Language (BSL) was launched on 30 April and closes on 25 June. The consultation is available in English and BSL, and arrangements are in place to receive consultation responses in BSL, too.
52. We have carried out a range of stakeholder engagement to support awareness and understanding of the proposals and Ofqual’s role in the development process. This has included sessions facilitated by the BSL Advisory Board and British Deaf Association covering key stakeholder groups in the deaf community, teachers of the Deaf roundtable, and a public session with approximately 200 attendees.
53. Within these sessions, and as reflected in media commentary, there continues to be debate about who the qualification has been designed for, with some calls for it to be designed for first language BSL users. We have confirmed that DfE’s subject content is designed for students with no prior knowledge of BSL. We have explained our proposals, which are designed to be appropriate for new learners, while also being as accessible as possible for students who use BSL as their first or primary language.
54. There continues to be criticism around the perceived delay in the qualification being launched following the previous government’s indication that it would be ready for September 2025. We have confirmed that, subject to the outcomes of the consultation, Ofqual expects to publish the rules in the autumn and from that point, any interested exam board(s) will need time to develop their qualification.
55. Despite these areas of challenge, we have had a positive response from stakeholders – and particularly from the BSL Advisory Board – about the careful consideration that has been given to the arrangements for this new qualification, and for the way in which we have made the consultation accessible.
56. We will return to the Technical Committee with recommendations for decisions on the consultation in September.
Consultation on Taking Regulatory Action
57. The consultation on the proposed amendments to the ‘Taking Regulatory Action’ policy closed on 15 May. 28 responses were received, and analysis of those responses is ongoing. The board will be presented with recommendations arising from the analysis at the October board meeting.
Qualification Fraud action plan
58. We continue to progress our counter-fraud programme. A third taskforce against qualification fraud took place in May. Representatives from 40 awarding organisations (AOs) delivering qualifications in high-risk sectors attended, alongside interested stakeholders including the National Hair and Beauty Federation, Security Industry Authority (SIA), Construction Industry Training Body (CITB), DfE and the Public Sector Fraud Authority.
59. Having considered different sources of intelligence, qualifications in adult care and cosmetics have now been included in the core group of in-scope qualifications. Analysis will continue on a rolling basis to consider what other groups of qualifications should be brought in.
60. We have spoken with a range of higher education representative bodies and universities about counter-fraud, highlighting how qualifications may be fraudulently used for the purposes of demonstrating English language proficiency to progress to higher education.
61. We will bring a substantive update on this work to the board later this year.
Artificial Intelligence
Regulation of AOs’ use of AI
62. We are currently scoping work to consider further how to mitigate risks around students’ use of AI in non-exam assessment (NEA).
63. We are also sharing and testing the principles we have developed for use of AI in marking with stakeholders internally and externally, including AOs, academics and AI technology experts. The research and approach have so far been well received. Once engagement with stakeholders has finished, we will develop the work further and consider next steps.
64. We have developed high-level plans for the next phase of engagement with awarding organisations on innovative uses of AI.
65. We recently provided updates on our work on AI to the Department of Science, Innovation and Technology as part of a commission related to the AI Action Plan.
Internal use of AI
66. Ofqual continues to explore its internal use of AI, with the project integrated into wider work aimed at driving efficiency and effectiveness.
Qualification Price Statistics
67. We are publishing our annual Qualification Price Statistics in late June with headlines that show the price of GCSEs increased compared with 2024 by 4.7%, A levels by 5.3% and VTQs by 4.1% - figures that are above the consumer price inflation comparison of 3.7%, though below wage inflation. The average price of End Point Assessments of just over £1,000 are reported for the first time in the report.
68. The publication provides longer term context, explaining that qualification price inflation for VTQs and GQs has been below consumer price inflation and wage inflation across a 4-year period. We anticipate, and are preparing for, sector interest in the publication given budgetary challenges in schools and colleges. Exam boards are likely to publish their 2026 fees from late June.
Corporate and people matters
Finance update
69. The financial year 2024 to 2025 concluded with an RDEL underspend of approximately £90k and CDEL in line with control total, with accounts presented for approval separately.
70. The 2025 to 2026 financial year has started largely in line with expectations, with the exception of the pay remit guidance being higher than was originally budgeted for (see People Update below).
71. Ofqual’s Spending Review (Phase 2) settlement has been agreed in principle with HM Treasury and is largely favourable, with a cash flat RDEL award over the 3-year period to 2028 to 2029.
72. Ofqual’s settlement does not include any funding for work arising from the Curriculum and Assessment Review.
People update
73. Pay remit guidance has been received from Cabinet Office. The standard award for both delegated grades and Senior Civil Servants is set at 3.25%, with an additional 0.5% to be applied flexibly. This compares to budget in line with previous guidance at 2.8%.
74. Following the departure of the Director, People and Culture in April, an offer has been made and accepted to an interim to cover the position for the next 6 to 9 months to enable a rigorous recruitment process to take place for a permanent replacement.
Publication of paper: Paper to be published: Yes.