Notice

Undertaking given by IAO to the Office of Qualifications and Examinations Regulations (‘Ofqual’), in accordance with B8 of the General Conditions of Recognition (‘the Conditions’)

Published 27 October 2026

Applies to England

Background

1. 1. IAO is an awarding organisation recognised by Ofqual to deliver a range of vocational and technical qualifications.

2. 2. On 25 September 2026 IAO agreed a settlement proposal by which it admitted that it had failed to comply with its Conditions of Recognition in several respects and agreed to the imposition by Ofqual of a requirement for it to pay a Monetary Penalty and costs.

3. 3. As part of the settlement process, Ofqual required IAO to provide information about the measures it had taken, and those it intended to take, to minimise the risk of recurrence of issues similar to those which occurred between 2023 and 2024. IAO has provided information about, and agreed to give an Undertaking in respect of steps it has taken, and will take, to review and enhance its approach to:

   1. 3.1. Centre approval;

   2. 3.2. Centre arrangements, Centre monitoring and quality assurance activities;

   3. 3.3. Identifying malpractice and undertaking malpractice investigations;

   4. 3.4. Data retention and data monitoring arrangements.

4. 4. Ofqual accepts this Undertaking from IAO to secure assurance that these issues will not be repeated in future for any of IAO’s qualifications.

5. 5. On 27 October 2026 Ofqual published its Notice of Monetary Penalty to accept the settlement proposal. The Notice of Monetary Penalty sets out the factual background which provides the context for this Undertaking. The 2 documents should be read together.

Undertaking

The Objectives of the Undertaking

1. 6. IAO expects completion of the Undertaking will:

   1. 6.1. Allow it to identify, manage and mitigate any aspect of its current processes and procedures which creates or contributes to avoidable risks to the safe and valid delivery and award of its qualifications.

   2. 6.2. Inform the development and implementation of revised processes and procedures which minimise the incidence of avoidable risks and promote a right-first-time delivery model.

   3. 6.3. Inform its approach to the identification, recording and management of emerging risks, relating to areas that include (but not limited to):

      1. 6.3.1. Centre approval, Centre monitoring and quality assurance activities,

      2. 6.3.2. Malpractice and maladministration,

      3. 6.3.3. Retention of data, allowing it proactively to resolve and manage any risks which could affect the safe and valid delivery and award of its qualifications.

   4. 6.4. Support it to build, train and retain its in-house expertise in relation to the development, delivery and award of its qualifications, which will reinforce a right-first-time model and increase its ability to react to emerging issues.

2. 7. IAO anticipates that completion of the Undertaking will secure that Ofqual can have greater confidence in IAO’s performance. In particular, IAO expects the Undertaking to mean:

   1. 7.1. IAO can demonstrate over a period of 12 months (from the date of this Undertaking being signed), its ability to:

      1. 7.1.1. Adequately monitor, assess and identify Centre concerns at an early stage, including prior to Centre approval;

      2. 7.1.2. Undertake effective Centre monitoring and quality assurance activities and promptly take appropriate action to address concerns and prevent / minimise Adverse Effect;

      3. 7.1.3. Adequately monitor, assess and identify malpractice / maladministration concerns and take appropriate action promptly to prevent / minimise Adverse Effect;

      4. 7.1.4. Undertake adequate malpractice / maladministration investigations and ensure management of such events adhere to relevant policies; and

      5. 7.1.5. Ensure retention of data without the need for any repeat of the very close regulatory scrutiny, and adequately monitor and assess information on relevant data management system(s).

   2. 7.2. By October 2027, Ofqual will have sufficient confidence to plan for only routine monitoring of IAO.

Reviewing Performance and Action Plan

1. 8. With respect to Actions 2, 3, 4, 6, 7, 8, 9, 10, 11, 14, 16 and 17 as set out in the Action Plan provided on 26 June 2026 (“the Action Plan” or “Schedule 1”), IAO undertakes to provide Ofqual, information set out under Schedule 2 Paragraph 3, on a quarterly basis for a period of 12 months.

2. 9. With respect to Action 12 of the Action Plan and following the Independent Audit Review Report of June 2026 (“the 2026 Audit” or “Schedule 3”), IAO undertakes to provide Ofqual with the information set out under Schedule 2 Paragraph 4, on a quarterly basis for a period of 12 months.

3. 10. With respect to External Quality Assurance (EQA) activity, IAO undertakes to provide Ofqual with the information set out under Schedule 2 Paragraph 5, on a quarterly basis for a period of 12 months.

4. 11. With respect to Action 21 of the Action Plan and following the 2026 Audit, IAO undertakes to provide Ofqual with additional information set out under Schedule 2 Paragraph 6.

5. 12. On or before 30 September 2027, IAO will:

   1. 12.1. Review its performance against the Action Plan;

   2. 12.2. Review its performance against any necessary actions / recommendations following the 2026 Audit;

   3. 12.3. Review its performance against the objectives of this Undertaking;

   4. 12.4. Submit to Ofqual a written report and Statement of Assurance, certified by a third-party external auditor at IAO’s own expense, providing independent assurance that:

      1. 12.4.1. IAO has completed the actions set out in the Action Plan;

      2. 12.4.2. IAO has implemented necessary actions / recommendations following the 2026 Audit; and

6. 12.4.3. The actions have been effective in meeting the objectives identified in this Undertaking.

7. 13. IAO shall ensure that such report to Ofqual:

   1. 13.1. Provides details of the review conducted;

   2. 13.2. Explains the effectiveness of IAO’s performance against the Action Plan, the Independent Audit Review in June 2026, and the objectives of this Undertaking; and

   3. 13.3. Set out the arrangements it has in place to bring the review to the attention of its Governing Body.

8. 14. In the event that IAO is unable to provide Ofqual with a Statement of Assurance required under Paragraph 12.4 above, IAO undertakes to:

   1. 14.1. Provide to Ofqual a Statement of Non-Compliance which sets out (where applicable):

      1. 14.1.1. How and why it has not met any actions, recommendations and/or objectives as set out in the Action Plan, the Independent Audit Review and this Undertaking; and

      2. 14.1.2. What further steps it has taken or proposes to take to ensure compliance and in what timescale.

9. 15. IAO recognises that:

   1. 15.1. Ofqual will evaluate the report submitted by IAO;

   2. 15.2. To the extent that if IAO has failed to deliver any of the milestones in the Action Plan and any necessary actions / recommendations from the Independent Audit Review in June 2026 which is the subject of the report, Ofqual will consider whether IAO has presented a reasonable excuse of that failure;

   3. 15.3. In the absence of a reasonable excuse, Ofqual may determine any such failure constitutes a failure to comply with this Undertaking, and a breach of Condition B8.

10. 16. As well as evaluating IAO’s performance against the Action Plan and Independent Audit Review of June 2026, Ofqual will as part of this review consider whether it agrees the Undertaking can be discharged. Where Ofqual does not consider the Undertaking can be discharged, it will explain which of the objectives it considers IAO has not sufficiently achieved, and IAO will present a further Action Plan accordingly. The review and re-planning cycle set out above will continue for so long as Ofqual considers necessary.

11. 17. IAO will maintain appropriate records and evidence to demonstrate how it has reached the conclusions set out in the report submitted to Ofqual. Such records and evidence will be retained until a date three years after the report is presented to Ofqual, or for such further period as Ofqual might later specify.

Declaration

1. 18. In giving this Undertaking, I acknowledge on behalf of IAO that:

   1. 18.1. The rules of interpretation and definitions outlined in General Condition J1 shall apply to this Undertaking;

   2. 18.2. Ofqual will publish this Undertaking on a date to be confirmed following consultation with IAO;

   3. 18.3. Ofqual may provide information to other government departments, bodies and agencies, including other regulators, about IAO’s Undertaking and Action Plan, including IAO’s performance under the Undertaking and the sharing of any updates provided by IAO and Ofqual’s analysis of it^{[footnote 1]};

   4. 18.4. Ofqual may take regulatory action in respect of any failure to comply with the terms of this Undertaking which may include the issue of a Direction, the imposition of a Monetary Penalty, Withdrawal of Recognition, Costs Recovery, and/or any other such action as it deems appropriate, acting in accordance with Ofqual’s ‘Supporting Compliance and Taking Regulatory Action’ policy (2025^{[footnote 2]});

   5. 18.5. Nothing within this Undertaking restricts Ofqual’s ability to conduct its own review, audit, investigation and/or other monitoring activity of IAO at any time.

Signed: NAME (Responsible Officer, IAO)

Date:

1. In accordance with sections 156 and 157 of the Apprenticeships, Skills, Children and Learning Act 2009. ↩

2. And as amended from time to time. ↩