Section D - General requirements for regulated qualifications

General rules, including about qualification fitness for purpose and accessibility, and about reviewing approach, enquiries and complaints, withdrawing qualifications and information for teachers.

Condition D1 - Fitness for purpose of qualifications

D1.1 An awarding organisation must ensure that each qualification which it makes available is fit for purpose.

  1. D1.2 A qualification will only be fit for purpose if that qualification, as far as possible, secures the requirements of –
    1. (a) Validity,
    2. (b) Reliability,
    3. (c) Comparability,
    4. (d) Manageability, and
    5. (e) Minimising Bias.
  1. D1.3 In any case where there is a conflict between two or more of the requirements in Condition D1.2, an awarding organisation must secure that it achieves a balance between those requirements that –
    1. (a) ensures its compliance with its Conditions of Recognition, and
    2. (b) is objectively the optimum balance in relation to the particular qualification.

There is currently no guidance on complying with these Conditions

Condition D2 - Accessibility of qualifications

  1. D2.1 An awarding organisation must ensure that it complies with the requirements of Equalities Law in relation to each of the qualifications which it makes available.
  1. D2.2 An awarding organisation must monitor qualifications which it makes available for any feature which could disadvantage a group of Learners who share a particular Characteristic.
  1. D2.3 Where an awarding organisation has identified such a feature, it must –
    1. (a) remove any disadvantage which is unjustifiable, and
    2. (b) maintain a record of any disadvantage which it believes to be justifiable, setting out the reasons why in its opinion the disadvantage is justifiable.

Guidance on Condition D2

Examples of ‘positive indicators’ that would suggest an awarding organisation is likely to comply

The awarding organisation:

  • has an up-to-date understanding of Equalities Law relevant to qualification design, delivery and award;
  • takes into account, when designing a qualification, information and advice on how different groups might be affected by particular features;
  • collects and analyses evidence to identify any features of its qualifications that have disadvantaged, or could disadvantage, a group of Learners who share a particular Characteristic, for example from Learner surveys, focus groups, statistical analysis, monitoring of Learner profiles and/or specialist reviews;
  • removes, where possible, or minimises features of its qualifications or assessments that have disadvantaged or might disadvantage a group of Learners sharing a particular Characteristic.

Examples of ‘negative indicators’ that would suggest an awarding organisation is not likely to comply

The awarding organisation:

  • breaches Equalities Law;
  • does not deal proportionately and appropriately with concerns from Learners or other stakeholders about possible bias in its qualifications;
  • does not actively monitor whether any features of its qualifications disadvantage particular Learners, or take appropriate steps to remove or reduce any such disadvantage.

Condition D3 - Reviewing approach

Review of approach

  1. D3.1 An awarding organisation must keep under review, and must enhance where necessary, its approach to the development, delivery and award of qualifications, so as to assure itself that its approach remains at all times appropriate.

Evidence to inform approach

  1. D3.2 An awarding organisation must –
    1. (a) have due regard to all information, comments and complaints received from Users of qualifications in relation to the development, delivery and award of qualifications, and
    2. (b) identify and give due regard to any credible evidence which suggests that a change in its approach to the development, delivery and award of qualifications is required in order to ensure that the approach remains appropriate.
  1. D3.3 Where an event relating to an awarding organisation (or an event, of which it is or should be aware, relating to any other awarding organisation) has had an Adverse Effect, the awarding organisation must review and revise where necessary its approach to the development, delivery and award of qualifications to ensure that its approach remains appropriate.

Guidance on Condition D3

Examples of ‘positive indicators’ that would suggest an awarding organisation is likely to comply

The awarding organisation:

  • reviews its approach to developing, delivering and awarding its qualifications in a regular and systematic manner, for example by refreshing its approaches in light of experience and feedback and undertaking in-depth periodic reviews;
  • changes its approach to developing, delivering and awarding qualifications where it has identified a need, for example because:
    • it finds a systemic problem with its approaches through monitoring, its investigation into an event that has or may result in an Adverse Effect or through complaints it has received;
    • it has submitted qualifications for accreditation which were found not to comply with the accreditation criteria;
    • it has received information about an Adverse Effect (for example from another awarding organisation) that could potentially have an impact on the way it develops, delivers or awards its own qualifications;
    • it has received feedback from the regulator through audits, research or other means;
  • reviews each of its qualifications in a regular and systemic way, for example by annual monitoring of the performance of a qualification and more in-depth reviews every three to five years;
  • during its review of a qualification includes an independent element to ensure objectivity and challenge. This could be, for example, through one or more of:
    • employers from the sector the qualification is designed for;
    • organisations that rely on the qualification, for example further or higher education institutions;
    • other external stakeholders including Centres;
    • internal staff who were not involved in originally developing, delivering or awarding the qualification;
  • during its review of the development, delivery and award of a qualification takes into account and acts, as necessary, on any feedback received from Ofqual (for example, decisions from a previous accreditation submission, or outcomes of relevant audits);
  • seeks, records and analyses feedback from Users of qualifications (including, for example, employers and professional bodies who have an interest in the qualification and who may generate evidence about whether or not a qualification is meeting its objective) and takes it into account during its review of a qualification;
  • evaluates, records and, where appropriate, implements any improvements to its approach to developing, delivering and awarding a qualification in a timely and effective way. The awarding organisation ensures that, as far as possible, Learners are not unfairly advantaged or disadvantaged as a result of the way in which it implements any changes;
  • takes all reasonable steps, following the occurrence of an Adverse Effect, to revise its approach to the development, delivery and award of qualifications so as to reduce the likelihood of the Adverse Effect reoccurring in respect of any of its qualifications.

Examples of ‘negative indicators’ that would suggest an awarding organisation is not likely to comply

The awarding organisation:

  • does not routinely review its approach to developing, delivering or awarding a qualification;
  • does not consider whether it should review its approach in light of information of Adverse Effects affecting another awarding organisation of which it should be aware;
  • does not seek or respond, where appropriate, to feedback from Users of qualifications;
  • does not consider and act on information received from Users of qualifications or from Ofqual that identifies potential or actual issues with its approach to developing, delivering or awarding a qualification;
  • does not, without good reason, make necessary changes to a qualification that its review of that qualification has highlighted as necessary;
  • changes its approach to developing, delivering or awarding a qualification in a way that has, or may have, an adverse impact on Learners, unless it has good reason for doing so;
  • fails to consider, when dealing with an issue that arises in respect of one of its qualifications, whether the issue may affect other qualifications too.

Condition D4 - Responding to enquiries and complaints procedures

Responding to enquiries from Users of qualifications

  1. D4.1 An awarding organisation must answer accurately, fully and within a reasonable time any reasonable enquiries received by it from Users of qualifications.
  1. D4.2 Nothing in this condition obliges an awarding organisation to disclose information if to do so would breach a duty of confidentiality or any other legal duty.

Complaints procedures

  1. D4.3 An awarding organisation must establish, maintain, publish and at all times comply with a written complaints procedure.
  1. D4.4 The complaints procedure must in particular include procedures and timescales for –
    1. (a) responding to complaints, and
    2. (b) dealing with the subject matter of complaints.

There is currently no guidance on complying with these Conditions

Condition D5 - Compliance of qualifications with Regulatory Documents

  1. D5.1 An awarding organisation must ensure that in the development, delivery and award of any qualification which it makes available, or proposes to make available, it –
    1. (a) complies with any requirement relating to that qualification which is set out in a Regulatory Document, and
    2. (b) has regard to any guidelines and principles of good practice relating to that qualification which are set out in a Regulatory Document.

There is currently no guidance on complying with these Conditions

Condition D6 - Management of the withdrawal of qualifications

  1. D6.1 For the purposes of this condition, an awarding organisation withdraws a qualification at the point in time when it first –
    1. (a) ceases to register Learners for the qualification,
    2. (b) ceases to deliver or award that qualification to Learners,
    3. (c) surrenders its recognition in respect of that qualification, or
    4. (d) has its recognition withdrawn by Ofqual in respect of that qualification.
  1. D6.2 Where an awarding organisation intends to withdraw, otherwise believes it to be likely that it will withdraw, or is obliged to withdraw, a qualification, it must take all reasonable steps to protect the interests of Learners in relation to that qualification.
  1. D6.3 An awarding organisation must give to Ofqual reasonable notice of its anticipated withdrawal of a qualification, and must do so prior to the time at which it provides that information to any Learners, Centres, or purchasers of qualifications.
  1. D6.4 Where an awarding organisation intends to withdraw, or is obliged to withdraw, a qualification, it must –
    1. (a) promptly prepare, maintain, and comply with a written withdrawal plan, which must specify how the interests of Learners in relation to that qualification will be protected, and
    2. (b) provide clear and accurate information about the withdrawal to Learners, Centres, and purchasers of qualifications who are likely to be affected by the withdrawal.
  1. D6.5 An awarding organisation must ensure that any withdrawal plan which it prepares complies with any requirements which Ofqual has communicated to it in writing.

Guidance on Condition D6

Examples of ‘positive indicators’ that would suggest an awarding organisation is likely to comply

In respect of the withdrawal of qualifications, the awarding organisation:

  • regularly monitors the extent to which its qualifications are taken by Learners (such as reviewing registration and certification data). After analysing this information or the outcome of any other review(s) of its qualifications, the awarding organisation puts in place steps to withdraw any qualifications:
    • for which it is not currently making awards, or for which it has never made an award and which it is unlikely to award in the near future; or
    • that are no longer fit for purpose; or
    • that no longer meet its regulatory requirements; or
    • that it has replaced with an alternative qualification;
  • gives notice to Ofqual of its intention to withdraw a qualification within a reasonable timeframe and before it communicates this to Learners, Centres and purchasers of the qualification;
  • promptly sets an operational end-date and certificate end-date when it decides to withdraw a qualification and provides this information to Centres and other relevant Users (taking into account the uptake and purpose of the qualification);
  • includes in its withdrawal plan:
    • clear timescales;
    • an explanation of why the qualification is being withdrawn;
    • information about the numbers of Learners or Centres that may be affected;
    • information about how the interests of Learners taking the qualification will be protected;
  • delivers the withdrawal plan effectively, keeps the plan under review (including seeking and analysing feedback from Centres about how the withdrawal is progressing) and changes the plan, as necessary;
  • provides relevant and timely information to Users about the qualification being withdrawn. This information is proportionate to the impact of the withdrawal, and could include (where applicable):
    • which qualifications are being withdrawn and why;
    • how the withdrawal could affect Learners;
    • dates for final registrations for new Learners, and assessments and retake opportunities for existing Learners;
    • information about deadlines for completing particular actions;
    • arrangements for Learners to switch to alternative qualifications, if appropriate;
  • taking into account the uptake and purpose of the qualification, provides timely and relevant information to Learners, Centres and purchasers of qualifications about alternative or replacement qualifications that are available and how these differ from the qualification being withdrawn;
  • where a qualification is withdrawn as a regulated qualification but continues to be available as an unregulated one, communicates the changed nature of its regulatory status to avoid Users of qualifications being confused or misled and ensure it complies with the requirements of Condition B5.1.

In addition to the guidance above, in relation to withdrawal or surrender of recognition which will lead to the withdrawal of qualifications (General Conditions D6.1(c) and (d)), compliance will be indicated where the awarding organisation:

  • approaches Ofqual at an early stage to discuss its action plan relating to the surrender of its recognition;
  • uses staff who have the necessary capability to manage the withdrawal or surrender of its recognition and the associated withdrawal of the qualifications.

Examples of ‘negative indicators’ that would suggest an awarding organisation is not likely to comply

The awarding organisation:

  • does not act upon a requirement to withdraw one or more of its qualifications following a decision by Ofqual to withdraw its recognition in respect of those qualifications;
  • does not give appropriate notice to Users of qualifications of its plan to withdraw a qualification to allow them time to make suitable plans ahead of the withdrawal;
  • does not provide sufficient information for affected Users when it withdraws a qualification, for example about timelines or possible alternative available qualifications;
  • does not provide sufficient resources to deliver, mark or award a qualification that is being withdrawn;
  • allows a Learner to enrol or register for a qualification that they are unlikely to be able to complete before the qualification is withdrawn;
  • does not make clear what arrangements (if any) are in place for Learners to retake assessments for a qualification that is being withdrawn;
  • continues to offer the withdrawn qualification and certificates it as a ‘regulated qualification’;
  • promotes or allows others to promote any qualification which it has withdrawn from the Register as a regulated qualification.

Condition D7 - Making available information to help meet Teachers’ needs

  1. D7.1 In respect of each qualification which it makes available, an awarding organisation must ensure that there is available to each Teacher any information which, for the purpose of preparing Learners and persons likely to become Learners for assessments for that qualification, the Teacher may reasonably require to be provided by the awarding organisation.

There is currently no guidance on complying with this Condition

Condition D8 - Compliance with saving and transitional provisions following cessation of accreditation

  1. D8.1 In respect of each qualification which it makes available that is subject to an accreditation requirement in accordance with section 139 of the Act, and for which accreditation will cease to have effect in accordance with section 140(6) of the Act, an awarding organisation must comply with any requirements relating to that qualification which are set out in any saving and transitional provisions made by Ofqual in accordance with section 140(10) of the Act.

There is currently no guidance on complying with this Condition

Guidance for designing and developing accessible assessments

This guidance is for awarding organisations when they are designing and developing assessments – particularly, though not exclusively, exams or other written assessments. The guidance concerns the accessibility of assessments for students, referred to hereafter as Learners.

This guidance will help awarding organisations to comply with the following General Conditions:

  • Condition C1 – Arrangements with third parties
  • Condition D1 – Fitness for purpose of qualifications
  • Condition D2 – Accessibility of qualifications
  • Condition E4 – Ensuring an assessment is fit for purpose and can be delivered
  • Condition G1 – Setting the assessment
  • Condition G3 – Use of language and Stimulus Materials
  • Condition G6 – Arrangements for Reasonable Adjustments
  • Condition G9 – Delivering the assessment

This guidance should also help awarding organisations comply with their obligations under Equalities Law, a requirement of Condition D2.

Assessments should enable Learners fully to demonstrate the knowledge, skills and understanding that the assessment is intended to measure (the assessment construct). An accessible assessment will not include any irrelevant features that make it more difficult, or more easy, for some Learners than others to demonstrate what they know, understand and can do to the required standard.

Assessments should not be easier or more difficult for certain Learners just because of their protected characteristics, for example because of their gender or ethnicity. They should not stereotype or use language which is likely to cause offence.

Designing and developing assessments that are accessible for the widest range of Learners is not always straightforward. This guidance should help awarding organisations balance the various factors they need to consider. It should help them to recognise and avoid irrelevant features in assessments that could unfairly disadvantage certain Learners.

Guidance

Validity – the overarching principle

Principle: An assessment task should only measure what it is intended to measure.

The purpose of an assessment task is to enable a Learner to demonstrate their level of attainment in relation to specific elements of knowledge, skills and understanding. To enable this, the task should only test those elements of knowledge, skills and understanding that it is intended to measure. If a task is intended to measure basic numerical skills, the task should not require Learners to also negotiate complex language (for example, in the wording of the question). However, if the task intends to measure Learners’ understanding of complex language, then complex language should be the central element of the task.

Assessment structure

Principle: The structure of the assessment should not create unnecessary barriers for particular Learners.

Awarding organisations should consider the impact on Learners of the order of tasks and avoid placing more demanding tasks at the start of an assessment. If an assessment differentiates performance by using tasks of different levels of demand, placing more demanding questions early in the assessment might demotivate some Learners. It might also prevent them from fully demonstrating the required knowledge, skills and understanding in the remainder of the assessment.

Assessment instructions

Principle: Instructions on how to complete an assessment should be clear and unambiguous.

The instructions in an assessment should:

  • enable Learners to understand how to complete the assessment without needing to read through unnecessary text
  • clearly tell Learners what they need to do – for example, how many tasks they must complete, whether their answers should make a certain number of points or be within a word limit, or to turn the page to find further information relating to the task
  • make it clear whether Learners can respond in different ways for example, by using either a bar chart or a pie chart
  • give instructions in the order in which Learners should follow them. Each instruction might be in a separate sentence or paragraph
  • be in the active voice and give direct instructions. For example, “You have 2 hours” or “you have 2 hours plus any extra time allowance” to complete the assessment”, “Answer all the questions”
  • if referring to any other elements of the assessment (for example, to an image or to source text), be clear to which element the instructions are referring
  • use commands that are literal, unambiguous and explicit, so Learners do not interpret commands in different ways
  • only include information for Learners and not, for example, information for invigilators

The instructions in an assessment should not:

  • require Learners to hold large amounts of information in their working memory, unless the assessment construct requires otherwise

Language

Principle: The language used in an assessment task should be appropriate for the assessment level and construct, and should not create unnecessary barriers to Learners.

General Condition G3 requires the language used in assessments to be “appropriate”, taking into account the age of the Learners likely to take the assessment, the level and objective of the qualification, and the knowledge, skills and understanding being assessed. Language should reflect the assessment construct and/ or the level of the qualification. That will mean language used in some assessments is necessarily more complex than in others.

In some assessments, understanding complex language is one of the things being assessed and will therefore be used in the assessment tasks. Awarding organisations should otherwise avoid using complex language.

Unless the assessment construct, level, context or subject requires otherwise, an awarding organisation should aim to:

  • use language that is straightforward – for example, “with” rather than “in conjunction with”
  • use words that are commonly understood – for example, “appropriate” rather than “apt” or “use” rather than “utilise”
  • use words and phrases consistently – for example, refer to “text” or “source” but do not use both interchangeably
  • use command words that are appropriate to the expectations of the task, and use these consistently and correctly
  • only use names where necessary – the inclusion of a name could confuse some Learners – especially if the name is unfamiliar or if it is used at the start of a sentence
  • be cautious when using negative words (such as “not” or “don’t”), as some Learners might overlook them
  • use active verbs where appropriate – a subject-verb-object construction can help Learners understand the action the sentence describes
  • consider the most appropriate way to present abbreviated phrases, including whether to give the expanded form of abbreviations only the first time they are used. For example, “International Monetary Fund” for “IMF”
  • make sure questions are worded clearly – for example, consider whether asking the question “Explain how…” or “Summarise how…”, rather than simply “How…”, would make the question clearer
  • consider the reading age of Learners who would typically take the assessment

Unless the assessment construct requires otherwise, an awarding organisation should avoid:

  • uncommon words with unusual or irregular spelling
  • words that are specific to a region, country, or particular culture or socioeconomic background, that may not be familiar to some Learners taking the assessment
  • words that have more than one meaning. For example, “present”, “sound”
  • ambiguous use of pronouns. For example, some Learners might not understand what “it” refers to in the following: “the hotel room featured a large bed, a lampshade and a desk. It was three feet high.”
  • abstract nouns – for example, “state what you think about this event” is better than “state what your reflections are about this event”
  • more than one negative in a sentence
  • unnecessary figurative language, including colloquialisms, idioms and metaphors

Sentence structures

Principle: Sentences in assessment tasks should be structured clearly.

Unless the assessment construct requires otherwise, an awarding organisation should:

  • use just one clause or idea per sentence, with each task expressed in a separate sentence or question
  • use clear punctuation
  • put any background information to the task or question in a separate sentence or paragraph
  • give any relevant information about the time or setting of the task at the beginning of the sentence
  • arrange sentences that describe sequential actions in the appropriate logical or chronological order
  • where sentences do not describe sequential actions, consider giving the most important sentence first

Unless the assessment construct requires otherwise, an awarding organisation should avoid:

  • participle clauses (clauses which do not explicitly indicate tense or who is doing the action of the verb). For example, the following sentence may be challenging for some Learners: “Calculate the ratio of the sides of Rectangle A to the corresponding sides of Rectangle B, giving your answer in the form of 1: n.” The task could instead be written in two sentences: “Calculate the ratio of the sides of Rectangle A to the corresponding sides of Rectangle B. Give your answer in the form 1: n.”

Source text or materials, context, images and colour

Where an awarding organisation is considering including source material, context, images or colour in an assessment task, the awarding organisation should consider whether it would be central, useful or incidental to the construct.

  • A central element is necessary to measure the construct. An awarding organisation should include central elements in the assessment, even where they might be challenging for some Learners. For example, if the assessment is measuring a Learner’s ability to understand legal or historical text, the assessment must include such text
  • A useful element might help to measure the construct but is not strictly necessary. An awarding organisation should consider whether any elements might be useful for some Learners (for example, an image that would help some Learners understand the written task) could be distracting for others who might have difficulty seeing it or who might wrongly assume there is additional information in the image that they need to use to complete the task. Consider how to achieve an appropriate balance across the assessment
  • An incidental element does not help to measure the target construct – for example, an image that is purely decorative. An awarding organisation should avoid incidental elements that might look attractive but add nothing to the assessment task, as they can be distracting or confusing for Learners

Source text or materials

Principle: Source text or materials should only be provided in an assessment where they support the measurement of the assessment construct.

Where an awarding organisation adds source text or materials to a task, the text or materials should:

  • use language that is of appropriate complexity for the assessment construct. For example, source text should only include colloquialisms, idioms and metaphors when these are part of the construct
  • be presented in a format that is likely to be familiar to Learners (unless the interpretation of unfamiliar formats is part of the construct)
  • have line numbers, paragraph numbers or section headings if appropriate
  • be of an appropriate length to measure the construct, and include an explanation of how the materials should be used in the task

When adding source text or materials to a task, an awarding organisation should try to ensure no group of Learners is advantaged or disadvantaged. An example of this would be use of a source text that is more familiar or accessible to Learners from a particular socioeconomic background where that is not relevant to the assessment construct.

When adding source text or materials to a task an awarding organisation should avoid using:

  • unnecessary negative, narrow or stereotypical representations of particular groups
  • source text or materials that might be interpreted differently by Learners where such interpretation does not form part of the construct

Context

Principle: Tasks should only be set in a context where that supports the measurement of the assessment construct.

Unless the assessment construct requires otherwise, an awarding organisation should:

  • be sensitive to contexts that will not be equally familiar to all Learners, and try to ensure no particular group of Learners is advantaged or disadvantaged by the choice of context. For example, blind or deaf Learners might find it more difficult to perform well in the task if their disability means the context in which the task is set will be unfamiliar to them. Contexts such as those related to particular types of housing, family arrangements, or social, travel or cultural experiences may advantage or disadvantage particular groups of Learners
  • be sensitive to the possibility that the context might confuse or distract some Learners, for example, Learners on the autism spectrum, or Learners whose first language is not English. Such Learners might assume that their lack of familiarity with a context will prevent them from attempting the task, or might be distracted by the context to an extent that they do not demonstrate the full extent of their knowledge, skills and understanding’

Unless the assessment construct requires otherwise, an awarding organisation should not:

  • use a context that will confuse or distract Learners from the task – for example, because it could be contentious or upsetting
  • use unnecessary negative, narrow or stereotypical representations of particular groups

Images

Principle: Images should only be used in an assessment where they support the measurement of the assessment construct. Where images are used, they should be clear.

Images can help some Learners to access the task – including those who have difficulty reading or those less familiar with the context in which a task is set. However, images can be a barrier to others, including some Learners on the autism spectrum, Learners with attention deficit hyperactivity disorder (ADHD) who might find them distracting, and Learners with a visual impairment. Where images are used in an assessment, awarding organisations should consider the need also to describe the image.

An awarding organisation should consider whether an image is central, useful or incidental to measuring the construct, and balance the interests of different Learners when deciding whether to use an image. If an image supports or emphasises the ideas in the text, the image might be a useful element of the task. Awarding organisations should consider how useful the image would be for the Learners overall, and whether its usefulness would outweigh any problems it might cause for particular Learners.

Unless the assessment construct requires otherwise, awarding organisations should:

  • use clear images. For example, a clear diagram or line drawing might be more accessible than a photograph or a 3D-effect drawing
  • use images with clearly defined and distinguishable features, labels and symbols that do not include irrelevant information. For example, a graph might only include major grid lines; a data table might only include the data needed to test the construct
  • use images that are large enough to allow the key features to be easily distinguished
  • use straight lines or arrows where they are needed to join labels to an image. Ideally, lines or arrows should not intersect with other label lines or arrows, and it should be clear to which part of the image each label refers
  • make the relationship between an image and its associated task clear. For example, by using a heading at the top of the image to indicate clearly what it is, to which task it relates and any other essential information (such as that the image is not drawn to scale)
  • consider whether the image could be made accessible to Learners with a visual impairment before deciding whether to use it
  • decide whether an image that is useful but not central to the task would be similarly useful in a paper modified for braille users, for those who require tactile images or for those using digital technology
  • consider whether to, in response to a request for a Reasonable Adjustment for a Learner with a disability who finds images distracting, provide a modified paper that omits useful (although not central) images
  • consider the potential cumulative effect of the images used across an assessment, as well as the images used on a task-by-task basis

Colours

Principle: Assessment tasks should only require Learners to distinguish between colours where this is central to the measurement of the assessment construct.

Unless the assessment construct requires otherwise (for example, because a competence standard requires a Learner to differentiate between the colours of electrical wires), awarding organisations should:

  • consider using patterns, shading, hatching or text labels to distinguish between sections of an image
  • consider shading an area to indicate a blank space, rather than using only an outline
  • where colour is used, ensure there is sufficient contrast between any text and its background, in line with the colour contrast ratios specified by the Web Content Accessibility Guidelines on Contrast (Minimum)
  • where colours are used to convey information, ensure they contrast sufficiently with adjacent colours, in line with the Web Content Accessibility Guidelines on Non-text Contrast

Unless the assessment construct requires otherwise, awarding organisations should not:

  • overuse hatching within an image where this could make the image confusing for Learners
  • use coloured backgrounds (although some Learners may choose to modify their assessment material to have a coloured background, for example as a Reasonable Adjustment)
  • require Learners to infer information through the use of colour alone

Layout

Principle: The layout of an assessment should be clear and consistent and not create an unnecessary barrier for Learners.

Unless the assessment construct requires otherwise, awarding organisations should:

  • consider using white space between blocks of text and images
  • ensure that the font and text size are easily readable, including when text is used within or alongside an image
  • consider using shorter paragraphs, section headings, subheadings or lists to break up long sections of text
  • ensure that, where possible, Learners can readily access all relevant information for a particular task. For example, putting it all on the same page or double-spread of pages, rather than having to turn between different pages in paper-based assessments or to avoid scrolling up and down long pages or between pages in on-screen assessments
  • align text with the left margin, but not with the right margin (That is, text should be “ragged right” not “justified”)
  • indicate to Learners where a page has been left intentionally blank – for example, with text that states “[BLANK PAGE]”
  • be mindful of the range of formats in which Learners will be taking the assessment, such as modified large print and onscreen. For example, number questions and sub-questions clearly for Learners using assistive technology, as use of numbers, letters and roman numerals together, such as ‘1(a). i’, can lead to translation errors in ‘text to speech’ software

The UK Association for Accessible Formats (UKAAF) produces standards and guidance for accessible documents, including minimum standards and guidance for clear print, large print and braille documents.

Anticipating Reasonable Adjustments

An awarding organisation must make Reasonable Adjustments for disabled Learners, to meet their duties under Equalities Law. Ofqual’s General Condition E4.2(d) requires awarding organisations to ensure an assessment “permits Reasonable Adjustments to be made, while minimising the need for them”.

When designing and developing an assessment, an awarding organisation should anticipate the diversity of the Learners likely to take it, and the range of Reasonable Adjustments disabled Learners might need. For example, some Learners might need a reader, a British Sign Language interpretation, a braille version of the assessment, or versions that are compatible with assistive software. An assessment designed to be taken in one format should be available for disabled Learners in other formats too, unless the assessment construct precludes it.

Awarding organisations should consider whether a Reasonable Adjustment might raise accessibility issues for a particular task. For example, awarding organisations should consider how images would be provided in alternative formats, or how screen-reading software would “read” a table of data.

If a task would be inaccessible when used with certain types of Reasonable Adjustment, the awarding organisation should decide how the task would be changed or replaced to make it accessible when used with those Reasonable Adjustments, or whether another form of Reasonable Adjustment could be used instead.

An awarding organisation should be cautious of wording that would not be relevant in alternative formats. For example, “See picture opposite” will not be relevant for Learners using a braille paper and might not be applicable for modifications with different layouts, such as large print or those using assistive software. If such wording is used in the standard paper, it should be removed or adjusted in modified papers as appropriate.

Alternative formats and assistive technology

An awarding organisation should have regard to this guidance when putting assessments into an alternative format for a Reasonable Adjustment – whether the modification is undertaken in-house or by a third party.

An awarding organisation should consider how Learners who use digital and/or assistive technology as a Reasonable Adjustment will be able to access the assessment. For instance, Learners might use a digital version of the paper to alter the colour of the background or magnify the content. A Learner might use a computer/screen reader to listen to their responses. A Learner might rely on text descriptors (“alt text”) to access images.

An awarding organisation should consider whether disabled Learners using digital and/or assistive technology would have to do more work than Learners using the standard format. For example, Learners who need to switch between separate files in a software program to see source material and tasks could be disadvantaged compared to Learners who see all the material together in paper versions. Learners who do not use an answer booklet could be disadvantaged compared to Learners who could judge the expected length of response as it is indicated by the space provided in the answer booklet.

With digital assessment materials, whether in a digital document format or dedicated platform, an awarding organisation should be aware of the Web Content Accessibility Guidelines’ accessibility principles “perceivable, operable, understandable and robust”. This will help ensure that Learners using digital and/or assistive technology can use digital assessment materials reliably. This can be achieved in part through meeting the European standard on the accessibility requirements suitable for public procurement of ICT products and services in Europe EN 301 549, which is currently aligned to the W3C Web Content Accessibility Guidelines 2.1 Level AA. Awarding organisations should use appropriately validated lists of the assistive technology disabled Learners taking the assessment might use. They should check whether the assistive technology will work with their assessments. Awarding organisations might also find it helpful to consider the W3C Web Accessibility Initiative (WAI) supplemental guidance to the Web Content Accessibility Guidance (WCAG 2). Although this guidance is not specifically about assessments, it contains advice on using clear and understandable page structure and content, including use of white spacing.

An awarding organisation’s processes

An awarding organisation should ensure all those involved in the design and development of assessments understand the importance of accessibility and inclusion, and of how to design and develop accessible assessments.

An awarding organisation should ensure those designing and developing assessments consider the diversity of Learners likely to take the assessment. It might consult Learners or groups that work with or represent Learners or individuals with relevant expertise. In particular it might consult groups that represent Learners who share a protected characteristic, or that represent disadvantaged Learners.

Condition D2.2 requires an awarding organisation to monitor qualifications which it makes available for any feature which would disadvantage a group of Learners who share a particular Characteristic. An awarding organisation should review whether any specific tasks or formats, or types of task or format, would advantage or disadvantage particular Learners.

In accordance with Condition D3.2, an awarding organisation should also gather and respond to stakeholder feedback on the accessibility of its assessments. An awarding organisation should:

  • seek feedback from Centres, gather and analyse information (for example about complaints received and the performance of Learners), to identify issues with its use of language or Stimulus Materials
  • use feedback to inform its development of valid assessments and qualifications and to provide feedback and training for those who develop assessment materials