Notice

Pearson: Notice of Monetary Penalty (PTE)

Published 15 December 2025

Applies to England

Notice of monetary penalty

Imposition of a monetary penalty on Pearson Education Limited (Pearson) in relation to the Pearson PTE incident

Introduction

1. The Office of Qualifications and Examinations Regulation (“Ofqual”) has decided to issue Pearson Education Ltd (“Pearson”) with a monetary penalty under section 151A of the Apprenticeships, Skills, Children and Learning Act 2009 (“ASCLA”) in the sum of £750,000.

2. This Monetary Penalty Notice (“the notice”) contains the reasons why Ofqual has decided to impose a penalty. Further information about Ofqual’s statutory powers and the Conditions of Recognition are set out in Annex A of this notice.

Executive summary

1. 3. This notice relates to a serious incident of candidate malpractice in respect of the online delivery mode of Pearson PTE Academic Level 1, 2 and 3 (“the qualifications”).

2. 4. In January 2022, Pearson introduced an online version of the PTE Academic test (PTEA Online) in response to both the significant disruption caused by the Covid 19 pandemic to international students needing to meet English proficiency requirements for the purposes of applications to higher education institutions around the world and the increasing stakeholder demand for more flexible assessment arrangements. The online assessment delivery method was established as secondary option allowing some students to take the assessment online at home rather than in a secure test centre.  PTEA Online was never used for visa purposes and in 2022 - 2023 represented less than 5% of all PTEA tests taken, with over 95% being taken in-person at secure test centres.

3. 5. 9,910 results from PTEA Online assessments dating from January 2023 to July 2023, were judged to feature candidate malpractice, and were revoked using a bulk revocation process. An additional 2,906 results were either revoked or withheld identified by Pearson’s business-as-usual monitoring processes during this period.

4. 6. Pearson accepts that it failed to establish and maintain appropriate controls to identify and manage emerging malpractice risks. Pearson has accepted that it could have acted sooner to reduce the severity of the critical incident. Pearson also accepts that it failed to promptly notify Ofqual of the incident.

5. 7. Ofqual finds that, on the balance of probabilities, Pearson breached the Conditions. The breaches can be summarised as follows:

   1. Pearson failed to take all reasonable steps to identify and prevent the occurrence of malpractice or maladministration in the development, delivery and award of qualifications which it makes available, contrary to General Condition A6.1, A6.2(a), A7.1. A8.1, and G8.1(a) and (b).

   2. In 2023, Pearson failed to promptly notify Ofqual when it had cause to believe that any event had occurred or was likely to occur which could have an Adverse Effect, contrary to General Condition B3.1.

   3. Pearson failed to establish and maintain appropriate systems of planning and internal control in respect of the qualification, contrary to General Condition A5.1 and A5.2(e).

6. 8. The incident had an Adverse Effect on public confidence in the system with 9,910 results being subject to a bulk revocation due to candidate malpractice and 3 universities electing to no longer accept the online version of the qualification.

7. 9. On 1 December 2025, Pearson entered into a voluntary settlement agreement with Ofqual to resolve this investigation. Pearson made full admissions in relation to Ofqual’s allegations of non-compliance and has agreed to pay a penalty of £750,000.

8. 10. In accordance with section 151A (4) of ASCLA, Ofqual served Pearson with a Notice of Intention to impose a monetary penalty on 1 December 2025. Ofqual determined it was not necessary to publish the Notice of Intention. On 1 December 2025, and in accordance with the settlement agreement, Pearson confirmed it had no representations to make and was content for Ofqual to proceed to final decision.

Background

The qualification

11. Pearson PTE Academic Level 1, 2 and 3 has been regulated since 1 August 2010.

12. PTE Academic is a computer-based English test assessing academic-level speaking, writing, reading and listening skills. The PTE Academic test is typically up to 2 hours in duration and produces an overall score of between 10 and 90 for each person taking the test.

13. Up until January 2022, PTE Academic assessments were delivered only through high security test centres.

14. In January 2022, Pearson introduced an online version of the PTE Academic test (PTEA online) in response to the significant disruption caused by the Covid 19 pandemic to international students needing to meet English proficiency requirements for the purposes of applications to Higher Education Institutions (“HEIs”) around the world and the increasing demand for more flexible assessment arrangements. This delivery method involved students taking the assessment online at home. The online assessment was never available to learners intending to use the PTE assessment for visa or immigration purposes.

15. When introducing the online delivery method, Pearson was keenly aware of a risk of malpractice, in particular malpractice where individuals may act as proxies for the registered student (“proxy testing”). Pearson had industry standard measures in place to detect candidate malpractice from the outset which operated effectively throughout 2022.

The incident

16. In 2023, test volumes more than doubled from January 2023 to June 2023. Data obtained from Pearson shows that from March 2023, there had been an increasing number of assessments where the result was subsequently revoked.

17. From May 2023, Pearson began to receive increased numbers of reports from higher education providers, including universities in the UK and Australia, about discrepancies between students’ test score and their English proficiency.

18. By July 2023, approximately 1100 test results from June and July had been placed on hold. Placing a result on hold prevented HEIs and students from accessing the result whilst Pearson investigated.

19. On 7 July 2023, Pearson decided to limit further test availability of PTEA online for the rest of July and significantly reduce availability whilst it investigated.

20. On 9 July 2023, Pearson implemented enhanced security criteria.

21. On 10 July 2023, Pearson began a detailed investigation of online test issues.

22. On 13 July 2023, all 2023 online test results that met Pearson’s enhanced security criteria were put on hold as a precautionary measure meaning results were inaccessible to test takers and institutions.

23. On 19 July 2023, Pearson formed an incident management group.

24. On 21 July 2023, Pearson concluded that there was a high degree of confidence that malpractice had occurred in relation to results flagged by its enhanced security criteria and c.10,000 results should be revoked.

The event notification, Pearson’s investigation and revocation of results

1. 25. On 21 July 2023, Pearson alerted Ofqual to the incident, informing Ofqual of its intention to revoke results.

2. 26. On 25 July 2023, Pearson submitted an event notification via Ofqual’s Portal pursuant to General Condition B3.1 (“the event notification”). On the same date, Pearson initiated revocation of results.

3. 27. Due to the significant and unprecedented increase in test volumes and number of assessments affected, Pearson undertook a ‘bulk revocation’ based on its findings from sampling. Pearson concluded that it could identify common features that would suggest malpractice in 99% of cases identified by the enhanced security criteria.

4. 28. 9,910 results dating back to January 2023 were revoked using the bulk revocation approach. Overall Pearson revoked or withheld a total of 12,816 results with 2,906 identified by business-as-usual monitoring.

5. 29. An appeals process was available to students and students were offered free re-tests to mitigate any Adverse Effect:

   1. Appeals: Pearson did not receive any complaints but was contacted by 8 candidates expressing dissatisfaction. No appeals were upheld.

   2. Retests: Only 375 vouchers were used by the students to whom the vouchers were issued. 276 of these tests had been ‘delivered’. Of the 276 students who had their initial result revoked through bulk revocation and went on to take a centre-based assessment, 11 went on to achieve a high score comparable to their online score.

6. 30. Of the 9,910 results revoked based on the bulk revocation, 5073 had been verified by one or more institutions prior to revocation.

7. 31. As a result of the incident, 3 universities decided to stop accepting the online test as evidence of proficiency in English.

8. 32. From August onwards, Pearson restricted the availability of PTEA Online. It withdrew the delivery method altogether in November 2023.

Root cause

33. On 26 July 2024, Pearson provided Ofqual with a copy of its internal audit dated 28 June 2024 (“the audit”). The audit investigated the root causes of the incident. Although it concluded that Pearson has a robust security infrastructure (including industry standard prevention and detection controls) in place to deliver exams securely, it identified various weaknesses in Pearson’s risk and management processes, as set out below.

Non-compliances

34. Pearson has admitted that it failed to comply with the Conditions in relation to the qualification, as follows:

Introduction of PTEA online

35. Pearson failed to establish and maintain adequate arrangements for identifying and managing malpractice risk in its development and monitoring of PTEA online), contrary to General Conditions A5.1 and A5.2(e), A6.1, A8.1, G8.1 (a) and (b).

36. In particular, there was an absence of defined risk review triggers. Pearson had no established risk factor thresholds such as sharp increase in volume or changes in coverage requirements, that would automatically prompt a reassessment of risk. As a result, risk assessments were only conducted at the outset, or an on ad-hoc basis when specifically requested, rather than as part of a structured, ongoing risk management framework.

Incident management

1. 37. Pearson failed to promptly respond to an emerging critical incident, contrary to General Conditions A5.1, A5.2(a), A6.2(a), A7.1, A8.1, G8.1 (a) and (b).

2. 38. In particular:

   1. a. the audit found that ambiguity within Pearson’s PTE incident management procedures contributed to delays in the identification, management, and eventual resolution of a critical test security incident. The absence of a clearly defined process hindered timely decision making at key stages of the incident,

   2. b. Pearson acknowledges that it could have acted earlier when proxy malpractice issues associated with online testing first began to emerge,

   3. c. despite warning signs emerging from May 2023, when universities in the UK and Australia were reporting increased instances of misalignment between proficiency and test outcomes, Pearson continued the online version of the qualification until 7 July 2023 and did not place results on hold until 10 July 2023. Ofqual considers that there were reasonable steps available to Pearson such as withdrawing the online version before July 2023, when Pearson should have recognised that a critical incident was developing.

Notification to Ofqual

39. Pearson failed to promptly notify Ofqual of the incident, contrary to General Condition B3.1.

40. Specifically, Pearson failed to notify Ofqual promptly about a developing malpractice incident, despite clear evidence of increasing proxy-testing risks and rising concerns from universities. Pearson accepts that it should have submitted an event notification to Ofqual before July 2023.

Regulatory action

1. 41. On 1 December 2025, Pearson signed a settlement proposal by which it:

   1. a. Agreed that it had breached its Conditions of Recognition as set out in this Notice,
   2. b. Agreed to pay a monetary penalty in the sum of £750,000 in settlement of those breaches,
   3. c. Agreed to pay Ofqual’s reasonable legal costs.

Determination of monetary penalty

42. On 1 December 2025, Ofqual’s Enforcement Panel considered the evidence relating to the breaches set out above, alongside the settlement proposal presented by Pearson.

43. Ofqual finds that Pearson breached its Conditions of Recognition as per the allegations set out above.

44. Having had regard to Ofqual’s policy, Supporting Compliance and Taking Regulatory Action (2025), as well as to Ofqual’s objectives and duties as set out in the Apprenticeships, Skills, Children and Learning Act 2009, Ofqual considers that this case represents a serious and prolonged period of non-compliance.

45. Pearson breached regulatory conditions which led to undermined public confidence in the PTE Academic (online) qualification (now legacy). Ofqual finds that Pearson’s failure to comply with the Conditions is such that Ofqual should impose a monetary penalty.

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

Aggravating factors

47. The following factors, as taken from Ofqual’s Supporting Compliance and taking regulatory action policy, are relevant in this case:

The seriousness of the breach, particularly in relation to its effect on standards of qualifications, public confidence and the efficiency of the qualifications system,

The effect of the breach (both in terms of the seriousness of the impact and the number of people affected) on purchasers, learners and users of qualifications:

• The breaches constitute a serious breach of Pearson’s regulatory obligations to monitor and assure the ongoing integrity of its qualifications.

• Throughout 2022 and 2023, assessments were delivered in circumstances where Pearson had ineffective risk identification and incident management processes in place. Ofqual considers, and Pearson accepts that had those weaknesses not been present, the emerging issues with proxy testing may reasonably have been identified at an earlier stage. Between January 2023 and July 2023, over c.12,000 results were judged to involve candidate malpractice, requiring withdrawal or revocation.

• The incident had an adverse effect on public confidence, with 3 universities electing to stop accepting PTEA Online. It is noted that there is no evidence of this impacting public confidence in the underlying PTEA qualification which continues to be delivered in high security test centres.

• 5,073 revoked results were verified by one or more institutions prior to revocation. It is reasonable to conclude that universities have incurred costs in enquiring about results and reconsidering applications following revocation.

• Following revocation of results, 11 learners who retook the assessment achieved comparable scores to their revoked online results, indicating Pearson revoked some genuine results.

• In relation to failure to promptly notify Ofqual about the incident, this non-compliance prevented regulatory oversight of Pearson’s management of the incident, over a significant timeframe (particularly between May to July).

Whether the breach was prolonged or repeated:

• Pearson failed to establish effective risk-management arrangements when introducing the online delivery method. The weaknesses persisted throughout delivery and reduced Pearson’s ability to identify and respond to emerging risks in a timely and effective manner; therefore the breaches were prolonged.

The extent to which the circumstances of the breach were within the control of the Awarding Organisation:

The behaviour of the awarding organisation in relation to the breach, including whether it happened intentionally, whether there was any negligence on the part of the awarding organisation, and whether the breach gives rise to concerns about the organisation’s management or control systems:

• Pearson failed to promptly respond to an emerging incident. Ofqual considers that the breaches resulted from failures in internal governance, oversight and quality assurance arrangements.

• Ofqual has not found any evidence to show that Pearson acted intentionally in committing the breaches.

Pearson has breached regulatory requirements in the past, and, if so, how frequently:

• Pearson has breached General Condition B3.1 (notification requirement) on 5 occasions since 2022 with Ofqual recording non-compliance but taking no further action.
• Ofqual has, on four previous occasions, imposed a monetary penalty on Pearson. The first fine (£85,000) was imposed in 2016 and concerned inaccurate and delayed results arising out of complications following a change of IT system.
• The second and third fines were imposed in November 2022 in the sum of £1,200,000 and £150,000 respectively. These related to (i) Pearson’s failings in its review of marking arrangements between 2016 and 2019 and (ii) to Pearson’s issuing of incorrect short course certificates in 2017 and 2018.
• The fourth and most recent fine was imposed on 21 March 2025 in the sum of £250,000. This related to Pearson’s failures in identifying, monitoring and managing conflicts of interest, and to take all reasonable steps to secure the confidentiality of assessment materials.

A fine is likely to improve compliance with regulatory conditions in the future (including by other awarding organisations):

• Ofqual considers that there is a clear need to deter Pearson and other awarding organisations from making similar failings in the future. The imposition of a monetary penalty emphasises the importance of maintaining robust systems to identify and manage risk, and any potential adverse effects. It also demonstrates that where standards are compromised, Ofqual will take proportionate and transparent regulatory action to protect the integrity of, and public confidence in, qualifications.

Mitigating factors

48. The PTEA online version of the test was introduced in response to the significant disruption caused by the Covid 19 pandemic and the increasing demand for more flexible assessment arrangements.

49. It is recognised that Pearson had security infrastructure (including industry standard prevention and detection controls) in place and the test was delivered online without significant incident during 2022. It is further recognised that the malpractice incident stemmed from the actions of bad actors in an environment where methods of online cheating are constantly evolving and becoming increasingly sophisticated.

50. Pearson provided the opportunity for students to have swift access to a free-of-charge re-test, so that genuine learners were not prevented from progressing.

51. Pearson has fully accepted responsibility for the non-compliances and the impact on public confidence.

52. Pearson has engaged and co-operated fully with Ofqual during the enforcement process.

53. Ofqual has not found any evidence to show that Pearson acted intentionally in committing the breaches.

Other factors

1. 54. The Enforcement Panel has also considered:

   1. a. the need to deter Pearson and other awarding organisations from making similar failings in the future;
   2. b. the need to promote public confidence in qualifications through visible, appropriate and effective regulatory action;
   3. c. the nature and circumstances of these breaches in comparison to other breaches for which fines have been imposed by Ofqual on other awarding organisations;
   4. d. Ofqual has taken into account that there is no evidence the breaches were motivated by financial gain.

Settlement

55. Pearson cooperated with Ofqual’s investigation, promptly admitted the non-compliances and entered into a voluntary settlement in which it has acknowledged Ofqual’s decision in this Notice and agreed not to appeal. In light of this settlement, Ofqual has decided to impose a lower penalty than it would have done in a contested case.

Final decision

56. Taking all of the above into account, the Enforcement Panel has confirmed its earlier notice of intention to accept a settlement proposal and imposes a monetary penalty in the sum of £750,000.

57. The Enforcement Panel is satisfied, in accordance with section 151B of the 2009 Act, that a Monetary Penalty in the sum of £750,000 would not exceed 10% of Pearson’s total annual turnover.

Payment

58. The monetary penalty must be paid within 28 days of the date of this notice, in accordance with the payment instructions provided with this notice.

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

Appeals

1. 60. An awarding organisation may appeal to the First Tier Tribunal in respect of Ofqual’s decision to impose the monetary penalty and/or in respect of the amount of that penalty, in accordance with section 151C of the Act.

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

Signed:

Chris Paterson

Chair of the Enforcement Panel

Date: 5 December 2025

Enforcement Panel:

Chris Paterson

Susan Barratt

Hardip Begol CBE

Annex A - Legal provisions

Statutory powers

1. Pearson Education Limited (“Pearson”) is recognised as an awarding body by The Office of Qualifications and Examinations Regulation (“Ofqual”) under section 132(1) of the Apprenticeships, Skills, Children and Learning Act, 2009 (“the 2009 Act”) and is subject to the General Conditions of Recognition (“the Conditions”) which Ofqual is required to set and publish under Section 134 of the 2009 Act.

2. Under Section 151A(2) of the 2009 Act, Ofqual may impose a Monetary Penalty on an awarding body if it appears to Ofqual that the awarding body has failed to comply with its Conditions of Recognition.

3. Under Section 151B(3) of the 2009 Act, the amount of any Monetary Penalty may be whatever Ofqual decides is appropriate in all the circumstances of the case, subject to Section 151B(1), which provides that Ofqual may not impose a Monetary Penalty in an amount which exceeds 10% of the awarding body’s turnover.^{[footnote 1]}

4. Ofqual’s Supporting Compliance and Taking Regulatory Action Policy (2025) sets out how it will use its powers to take regulatory action, including the factors it will take into account when deciding whether to impose a Monetary Penalty and how it will determine the amount of any Monetary Penalty to be imposed.

General Conditions of Recognition

5. The conditions relevant to this incident are set out below.

6. General Conditions A5.1 and A5.2 requires:

A5.1: An awarding organisation must –

(a) ensure that it has the capacity to undertake the development, delivery and award of qualifications which it makes available, or proposes to make available, in a way that complies with its Conditions of Recognition, and
(b) take all reasonable steps to ensure that it undertakes the development, delivery and award of those qualifications efficiently.

A5.2(e): For the purposes of Condition A5.1, an awarding organisation must establish and maintain appropriate systems of planning and internal control.

7. General Condition A6.1 requires:

A6.1: An awarding organisation must take all reasonable steps to identify the risk of the occurrence of any incident which could have an Adverse Effect.

8. General Condition A6.2(a) requires:

A6.2(a): Where a risk is identified in accordance with A6.1, the awarding organisation must take all reasonable steps to prevent the incident from occurring or, where it cannot be prevented, reduce the risk of that incident occurring as far as is possible.

9. General Condition A7.1 requires:

A7.1: Where any incident occurs which could have an Adverse Effect, an awarding organisation must (whether or not it has previously identified a risk of that incident occurring) promptly take all reasonable steps to – (a) prevent the Adverse Effect and, where any Adverse Effect occurs, mitigate it as far as possible and correct it, and (b) give priority to the provision of assessments which accurately differentiate between Learners on the basis of the level of attainment they have demonstrated and to the accurate and timely award of qualifications.

10. General Condition A8.1 requires:

A8.1: An awarding organisation must take all reasonable steps to prevent the occurrence of any malpractice or maladministration in the development, delivery and award of qualifications which it makes available or proposes to make available.

11. Condition B3.1 requires:

B3.1:An awarding organisation must promptly notify Ofqual when it has cause to believe that any event has occurred or is likely to occur which could have an Adverse Effect.

Condition B3.2(g) states that for the purposes of this condition, such events may in particular include those where the awarding organisation believes that there has been an incident of malpractice or maladministration, which could either invalidate the award of a qualification which it makes available or could affect another awarding organisation.

12. General Condition G8.1 requires:

Condition G8.1: An awarding organisation must take all reasonable steps to ensure that, in relation to qualifications which it makes available – (a) evidence generated by a Learner in an assessment is generated by that Learner (or includes evidence generated by that Learner as a contribution to group work), and (b) where an assessment is required to be completed under specified conditions, Learners complete the assessment under those conditions (other than where any Reasonable Adjustments or Special Consideration require alternative conditions).

1. The turnover of an awarding organisation is determined in accordance with Regulations 3 and 4 of the Office of Qualifications and Examinations Regulation (Determination of Turnover for Monetary Penalties) Order 2012/1768 (as in force from 6 July 2012). ↩