Transparency data

Chief Regulator’s report: 8 October 2025

Updated 30 April 2026

Applies to England

Date

8 October 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. I am pleased to report that overall the 2025 summer series of exams and formal assessments went smoothly, with standards and public confidence in regulated qualifications successfully maintained.

3. On 18 September the Department for Education (DfE) announced the appointment of new members to the Ofqual Board. Kurt Hintz and Andrea Rigamonti will serve from 1 October, Conor Ryan will serve from 1 November and Jill Duffy will serve from 1 January 2026. The appointments are for a period of 3 years. Kurt and Andrea will be joining our October meeting.

4. We now look ahead to what we expect to be a busy period for Ofqual, as we support the government’s reforms arising from the Curriculum and Assessment Review and 2 autumn White Papers – one on Skills, with a focus on FE, and another on Schools, with a focus on securing stronger progress from all students as they move through school, as well as on SEND.

5. The board will be aware of the ministerial changes that took effect in September. I have had a positive introductory call with Georgia Gould MP, the new Minister for Schools. Olivia Bailey MP will be responsible for early years education. Ministerial responsibility for skills is explained in detail at paragraph 10 below.

Ofqual Strategy 2025 to 2028 

6. We have made progress across all 5 objectives.

Qualification Reform

7. We are expecting the Skills White Paper, Curriculum and Assessment Review and a Schools White Paper to be published this autumn, all of which will reference Ofqual. DfE also intends to publish a government response to the Curriculum and Assessment Review and a Post-16 Pathways consultation within the same timeframe. Taken together, these documents will set out a clear policy direction for qualifications under this administration.

8. As part of these announcements, we are expecting specific proposals to reform GCSEs and A Levels to be brought forward. Ofqual has been advising on these developments and continues to do so as DfE moves towards implementation.

9. DfE will also be setting out next steps for vocational and technical qualifications for the 16 to19 cohort at levels 2 and 3, as well as proposals on English and maths post-16. This will draw a line under the current Post-16 Qualifications Review and set out a different path. DfE continues its commitment to T Levels but acknowledges that further developments on a ‘middle pathway’ are needed.

10. Preparation for a coherent programme of change to implement these developments is underway, including a request for implementation funding. We are already in dialogue with DfE on this matter.

Machinery of Government changes 

11. Board members will be aware of the recently announced Machinery of Government changes, which will see the brief for adult skills and apprenticeships moving out of DfE and into the Department for Work and Pensions (DWP), under Secretary of State Pat McFadden. Minister Smith remains in post as the Minister for Skills working across the 2 departments.

12. As a consequence of these changes, Skills England will be moving into the DWP and will have less to do with qualifications such as T Levels, which will remain under the remit of DfE. This aligns with the changes made to the AO T Level contracts, which novated to DfE when IfATE closed. We will be working through the practicalities of these changes with DfE as part of the reform programmes referenced above.

Apprenticeships

13. Ofqual’s consultation on a revised regulatory framework for apprenticeship assessment concluded on 27 August with 192 responses. These proposals followed the publication of DfE’s new principles for apprenticeship assessment in February. We are extremely pleased with the positive engagement with our consultation and the constructive responses received. We are working through the analysis in detail, but we do not foresee the need for major adjustments to our plans as a consequence of the consultation feedback.

14. The next step in the reforms to apprenticeship assessment will be Skills England’s publication of the first 5 assessment plans that they have adapted in line with DfE’s new principles. These will give a clear indication to AOs of the degree of change they might expect as a consequence of the reforms.

15. DfE also intends to publish a ‘Companion Document’ alongside the first 5 assessment plans that will set out further detail on the changes that the sector can expect. This will include transition and funding arrangements. The Companion Document and first 5 plans are expected to be published in October.

Summer series 2025

General Qualifications

16. The summer series of GCSE, AS and A Level exams went reasonably smoothly, with the typical range of issues arising. Marking and associated activity was completed, and results released to students, on time.

17. To date, event notifications overall are tracking at broadly the same level as in 2024, with assessment material errors below 2024 levels and security breaches above. The latter were primarily the result of centre staff failing to adhere to exam regulations or distributing papers in error.

18. We continue to monitor the delivery of reviews of marking and moderation. No exam boards have raised concerns about capacity, and all priority reviews appear to have been completed by the UCAS advisory deadline.

19. We are now undertaking reviews of individual boards’ delivery in preparation for the post-summer meetings in October where we will feed back on performance, scrutinise preventative measures and identify areas for development and/or potential regulatory action.

Vocational and Technical Qualifications

20. Event notifications overall for VTQ and T Levels are broadly in line with summer 2024.

21. Arrangements for the delivery of results for level 3, and level 1 and 2 VTQs taken alongside GCSEs and A Levels and used for progression to further education and higher education are now successfully embedded as business-as-usual processes. AOs noted improved engagement from centres this year.

22. Assessment delivery for Technical Qualifications within T Levels went smoothly, with no significant issues reported. T Levels in agriculture, land management & production, and legal were awarded for the first time.

23. Ofqual has completed its review of a sample of T Level assessment materials from summer 2025 and found no concerns that would have affected the validity or reliability of the results issued. We will be issuing letters to the AOs confirming the outcome of the reviews and highlighting any areas that need to be addressed ahead of the next assessment series.

Summer series reporting

24. As usual, we will publish in December a report on the delivery of the 2025 exam series.

25. We will also be publishing equalities analysis for A Level and level 3 qualifications. In the absence of key stage 2 (KS2) data we cannot this year conduct our usual GCSE, level 1 and 2 equalities analysis, and we explained this in our results day publications.

Awarding in summer 2025

26. Grading continued as normal in 2025 with standards being maintained from summer 2024. There were no strategically significant issues that arose through this process, including in relation to the awarding of GCSEs in the absence of KS2 prior attainment data.

National Reference Test 2025

27. On GCSE results day we published the outcome of the 2025 NRT. This showed the following:

  • In maths: At grades 5 and 4, there was no statistically significant difference between 2025 and 2017; at grade 7, the results were statistically significantly higher in 2025 than 2017.

  • In English language: At grade 4, the results were statistically significantly lower in 2025 compared with 2017. At grade 5, however, the previously observed statistically significant lower performance compared to 2017 was no longer present. At grade 7, there was no statistically significant difference between 2025 and 2017.

28. I decided not to require exam boards to make adjustments to grading standards in light of the NRT results. The reasons for this were set out in the NRT annual statement published on GCSE results day.

November GCSE resits

29. In the November resit series for GCSE English language and maths, exam boards will carry forward the standard from the summer series in these subjects.

Access arrangements

30. We have continued to review evidence relating to approvals for, and use of, access arrangements in GCSE, AS and A Level, including 25% extra time.

31. Our analysis of the underlying data for access arrangements approvals identified that Ofqual’s previously published official statistics significantly overstated the prevalence of access arrangements, due to the way the data is recorded and aggregated. In July we withdrew our official statistics for 2014 to 2024, supported by communications and engagement activity to explain our reasons for this.

32. We are now working with the exam boards to secure long-term improvements to data quality and reporting. We are also preparing the 2024 to 2025 statistics for publication in late autumn, using a disaggregated dataset supplied by the exam boards. These will be classified “official statistics in development”, and will include confidence ranges rather than absolute values, given the continued limitations of the available data.

33. We are preparing a regulatory report to explain our work in this area, and we are also finalising research reports into extra time and time in assessment. We expect to publish these reports in early 2026.

Communications and stakeholder engagement

34. Our summer delivery communications were impactful and positive. Evaluation against our objectives is ongoing, but our initial analysis suggests that we contributed to a maintenance of confidence in qualifications.

35. On results days we carried out media engagements from centres we visited in London. Our press release and quotes were widely carried (for example: our level 1 and 2 results day ‘passports to opportunity’ message had a potential reach of around 44 million). An update to how we use digital communications improved the impact of our digital products, such as blogs.

36. With the proactive announcement in July on issues with previously published access arrangements data, any discussion of this topic around results that may have undermined public confidence was significantly reduced.

37. Broadly speaking, the reaction of most stakeholders to the delivery of results this year, particularly teacher and head teacher unions, school and college representative groups, and subject associations, was measured and quiet. They had few issues or concerns to raise and, in general, said their and their members’ experience of qualifications delivery and results was as expected. As such, most were positive when asked about their views on the delivery of qualifications this year. There was also positive feedback about the value of Ofqual’s publications about results, particularly the statistical release that was published for the first time in 2025.

38. Looking ahead, our strategic focus for communications activity will be the on-screen assessment consultation, strengthening understanding of grading, as well as delivery of proactive campaigns on cyber security and qualifications fraud.

39. In support of our communications objectives, I am speaking at a number of external conferences and events this autumn, including the CST annual conference, Schools and Academies Show and FAB conference.

Regulation of National Assessments

Development and delivery of national assessments, including KS2 tests

40. The development of the 2025 KS2 assessments, the new Reception Baseline Assessment (RBA) and the Phonics Screening Check followed the Standards and Testing Agency’s (STA) published processes. STA’s governance provided evidence to support STA’s claims about the validity of these assessments. KS2 standards were successfully maintained in 2025.

41. Delivery of national assessments in 2025 was successful. Over 99.9% of KS2 results were returned to schools on time. The Phonics Screening Check and the Multiplication Tables Check were also delivered effectively.

Change of contractor for KS2 test delivery

42. STA has provided assurance to Ofqual regarding Capita’s orderly exit from the KS2 delivery contract.

Early Years Foundation Stage Profile (EYFSP) consultation

43. As I reported to the board previously, in spring 2025 DfE shared with us their proposals for making school-level EYFSP data available to schools, Ofsted, and local authorities. Given the key features of the EYFSP assessment, Ofqual provided regulatory feedback to DfE regarding some of the risks associated with the additional purpose.

44. In September, the EYFS policy team confirmed to Ofqual that the changes would be implemented from September 2026 (not September 2025, as originally planned). However, the changes do not include EYFSP data being used directly for external school accountability.

Delivery of the new Reception Baseline Assessment (RBA)

45. Ofqual conducted a readiness review with STA in March 2025 ahead of the rollout of the new RBA in September. Implementation has been broadly successful, with many schools using the platform to administer the updated assessment. STA have notified Ofqual that some schools have, however, experienced technical issues and we continue to monitor delivery closely during the remainder of the assessment window (RBA must be undertaken within the first 6 weeks of a child starting reception, so for the majority of pupils, by 10 October).

National assessments regulation annual report

46. In December we will publish our annual report on the regulation of national assessments in 2025.

Development of a GCSE in BSL

47. Our technical consultation on the draft Conditions, Requirements and Guidance for GCSEs in British Sign Language (BSL) closed on 25 June. There were 30 formal responses to the consultation, from individuals as well as organisations representing individuals in the deaf and hearing communities.

48. We presented recommendations for the consultation outcome to the Technical Committee at the beginning of September, and the Technical Committee agreed that the finalised Subject Level Conditions, Requirements and Guidance should be published alongside those outcomes. We are currently preparing the materials for publication in the autumn, including those that will be translated into BSL.

GCSE in Natural History

49. DfE has resumed work to review and update the draft subject content for a proposed GCSE in natural history. Ofqual is reviewing and providing feedback to DfE, as well as reviewing our proposed assessment arrangements in light of the content changes.

Introduction of Principles to Ofqual’s General Conditions of Recognition

50. Following the board discussion in July, we published our consultation decisions on 4 September confirming we would be introducing Principles to the General Conditions of Recognition. We also published statutory guidance and non-statutory advice notes containing case studies aimed at helping AOs understand how they can achieve compliance. The Principles Condition was unchanged following consultation, though we did make changes to the guidance to Principle 2 to ensure the concept of ‘fairness’ is interpreted correctly and not too broadly. The Principles Condition and supporting guidance will come into force on 4 December 2025, to allow time for familiarisation.

51. On publication there was minimal media interest, with just one FE week article. We have received little feedback on the Principles from AOs and the wider sector since publication. FAB have indicated that some members remain concerned that the Principles will bring additional and unwelcome regulatory burden. We have engaged extensively with FAB to explain why we consider the burden to be proportionate, and we set out our rationale in detail in our decisions.

52. In September we presented at a regulator’s briefing, attended by awarding organisations, FAB and JCQ, to address any questions and remaining concerns. We are working with FAB to identify opportunities to speak at their member events. We plan to host an in-person event for AOs in late January 2026 which will focus on outlining the decisions made, answering any questions that AOs have once the Principles are in force and discussing how we might further develop the advice notes in future.

Artificial Intelligence

Regulation of AOs’ use of AI 

53. We have successfully completed a series of engagement sessions with AOs and subject matter experts to share and test our work on principles of AI use in marking. Feedback has been positive, with strong support for our research and approach. A paper is planned for publication later this year.

54. In October, we will present our work at an OECD panel discussion, contributing to international dialogue on responsible AI use in educational assessment and engaging with policy makers from across the globe.

55. Also in October, we will launch the first in a 5-part series of online workshops for AOs, focused on innovative use of AI in the design and delivery of qualifications and assessments. The workshops aim to support shared understanding across AOs and generate insights to strengthen Ofqual’s evidence base, ensuring our regulatory approach remains appropriate, proportionate and responsive to emerging technologies.

Internal use of AI

56. Ofqual’s project to explore internal use of AI continues to support wider efficiency and effectiveness goals.

Confirming the Acquisition of Specified Learning Outcomes (CASLO) Event

57. On 25 September, Ofqual hosted a one-day conference, entitled: ‘What is the future of Outcome-Based Qualification Design?’ Our intention was to engage a range of stakeholders in debate over how best to design technical and vocational qualifications, in a context that has been dominated by outcome-based approaches since the 1970s. We promoted the CASLO research that we published in November 2024, and also the importance of debate and capacity building in this area, given that active research and scholarly debate has declined significantly in recent years. The event was very well attended by a mix of academics in the field, representative organisations and other stakeholders.  It was a strong public demonstration of Ofqual’s important convening power and of our important research work.

COVID-19 Inquiry

58. Following on from the update in July, our corporate statement was finalised and submitted to the Inquiry. Module 8 of the Inquiry will have commenced by the time of the board meeting, and the inquiry have indicated that they do not wish to call Ofqual to give oral evidence.

Corporate and people matters

Finance update

59. As reported in the Finance Paper, at the end of July a revenue overspend of just over £200k was forecast.

60. Separately, we are in dialogue with HM Treasury with a view to unlocking additional funding to cover anticipated legal costs resulting from the COVID-19 Inquiry.

People update

61. A pay award of 3.25% has been implemented for all delegated grades and SCS in the September payroll, backdated to April 2025, in line with general pay remit guidance.

62. The interim HR director has been in place since the start of July and is anticipated to be in post until the end of the financial year to allow the People team to move forward with key initiatives to support Ofqual’s Strategy whilst allowing sufficient time for a permanent replacement to be recruited.