Chief Regulator’s report: 10 December 2025
Updated 30 June 2026
Applies to England
Date
10 December 2025
Title
Chief Regulator’s report
Report by
Sir Ian Bauckham, Chief Regulator
Paper for information and discussion
Recommendations
- The Board is asked to note the matters reported.
Overview
2. Since the Board last met, a key area of Ofqual’s focus has been on preparing to support the government’s reforms arising from the Curriculum and Assessment Review and Skills White Paper.
3. The refreshed internal structure agreed by the Board in October went live at the start of November and puts Ofqual in a strong position to deliver the important work ahead of us. We are now operating under 6 directorates: Delivery, Policy, Strategy, Legal, Corporate Services and Standards, Research and Analysis (SRA). The transition has gone smoothly from a People perspective, with changes to roles and reporting lines effectively implemented, and an overall positive reception. Feedback from stakeholders has also been positive, with clear support for the new Delivery and Policy structure.
4. Our annual staff conference in November was successful, with keynote speakers including Laura McInerney, schools expert and education commentator, and a strategic focus throughout the day on embedding our new strategy and delivery of Ofqual’s upcoming priorities. I am delighted some Board members were able to join us for this event.
5. We are in a busy period for significant publications: as well as the usual annual delivery reports and official statistics relating to the summer series, publications include new reports on access arrangements and our consultation on on-screen assessment.
6. We hosted an Awarding Organisation Governance Forum in October. There was rich discussion on a wide range of topics, including the impact of reform and wider contextual challenges on the qualifications and apprenticeship assessment markets, the new Principles condition and patterns in recent regulatory and enforcement action.
7. I and the Deputy Chief Regulator have been invited to attend an accountability hearing before the Education Select Committee on 13 January.
Ofqual Strategy 2025 to 2028
8. Annex A sets out the progress made in delivering the Ofqual Strategy up to the end of quarter 2 2025 to 2026.
New qualification reforms
9. The Skills White Paper and associated Post-16 Pathways consultation were launched by the Department for Education (DfE) on 20 October. The Curriculum and Assessment Review and associated government response were published on 5 November. These documents set a clear direction of travel for qualifications in the current Parliament. Ofqual has now initiated a new qualification reform programme as a consequence.
10. DfE confirmed in October it would be delaying publication of the Schools White Paper, which is expected to include recommendations on SEND. We now expect this to be published in early 2026.
11. As set out in the Skills White Paper, a key part of the reforms are V Levels, a new vocational pathway at Level 3, positioned between A Levels and T Levels. Foundation Certificates are being newly introduced post-16 at Level 2, which are one-year programmes designed for those aiming to remain in education once they have achieved at Level 2 and support progression on to Level 3 programmes. Occupational Certificates are also being newly introduced at Level 2, which are 2-year programmes designed to support progression into jobs in sectors where there is Level 2 entry, such as construction and hospitality. These qualifications will be introduced in sets by sector, with the first sectors being available for teaching in 2027.
12. The government’s response to the Curriculum and Assessment Review set out plans to reform GCSEs and A Levels. These are also going to be introduced in phases, with the first GCSE subjects being introduced from 2029, followed by the related A Levels in 2031. The government will make the new national curriculum available for first teaching from 2028.
13. Overall, Ofqual is supportive of the government’s recommendations and direction of travel.
14. Ofqual is now mobilising to implement these changes. A formal request for funding from DfE has been made, at their invitation, and a resourcing strategy is being drawn up to support delivery. Policy development work has commenced with a view to initial Ofqual consultations launching in the spring. We are looking to optimise the key processes that support reform, such as accreditation, where AOs submit their specifications and related assessment materials for upfront scrutiny, with a view to securing high quality outcomes in the most efficient way possible.
15. We are mindful of the importantly different role that AOs, and especially the four exam boards, play in reform, where they are crucial delivery partners as well as regulated entities. Ofqual is establishing new structures to engage AOs regularly throughout the reforms.
16. Ofqual is also taking steps to ensure that the programme is being managed coherently with the different parts of DfE, putting in place appropriate governance arrangements where progress can be monitored and risks managed.
Apprenticeships
17. By the time the Board meets, Ofqual will have published the policy decisions made following consultation on a revised regulatory framework for apprenticeship assessment, which closed on 27 August. These proposals followed the publication of DfE’s new in February, which signalled a change away from End Point Assessment to a more flexible approach where centre-marked assessment would be allowed in line with other VTQs. We were pleased with the positive engagement with our consultation proposals, which were designed to enable this change to happen in a way that maintained a baseline level of quality in the system.
18. Training providers, AOs and other sector stakeholders responded well to our plans to require that about half of the assessment carried out should remain AO-set and marked, and that a similar proportion would need to be synoptic. These requirements were designed to ensure that achieving the apprenticeship would remain a clear signal of occupational competence. Alongside publication of the policy decisions, Ofqual is consulting on the proposed draft regulations and guidance, with a deadline of 11 February for responses.
Summer series 2025
19. Overall, the delivery of exams and results this summer was successful and there have been no significant issues reported in relation to reviews of marking, moderation or appeals.
20. General qualifications saw a reduction in assessment material errors reported this summer for three of the four exam boards. Reports of security breaches increased, but these primarily concerned question papers distributed in error by centre staff, mostly with little or no wider impact.
21. Evaluative reviews and post-summer meetings with awarding organisations and exam boards addressed key themes from the summer series, followed by summary letters issued to each AO.
22. For VTQs, significant progress has been made to strengthen delivery and support continuous improvement. We have set clear expectations for delivery of results for VTQs in 2026.
Summer series reporting
23. The 2025 delivery report, covering general and vocational and technical qualifications, will be published on 11 December.
24. On 3 December we published our annual equalities report. The analyses considered A level and other level 3 performance table qualifications (PTQs). It was not possible to provide equivalent analyses for GCSE and other level 2 qualifications this year due to the absence of KS2 prior-attainment data which is an important variable in the analysis. The analyses at level 3 showed very stable findings over time with no notable changes in relationships identified in the A level analysis.
November GCSE resits for English and maths
25. Exams for the November GCSE English and maths series ran from 3 to 12 November. We are not aware of any issues to date with the potential to impact results.
26. The primary aim of awarding in the GCSE resit series this year is to carry forward standards from summer 2025. Exam boards are conducting this process through December, scrutinised by Ofqual, ahead of the release of results to students on 8 January 2026.
VTQ autumn and winter delivery
27. Monitoring expectations and activities for the VTQ autumn and winter series have been communicated to AOs.
28. The T Level window for Employer Set Projects opened on 3 November and core exams are taking place between 25 November and 12 December. During this series, paper reviews and standardisation observations are underway to ensure consistency and quality across T Level assessments, helping maintain standards and public confidence.
29. The winter series of level 3 and level 1/2 & 2 exams takes place between 5 January and 5 February 2026.
2026 Delivery
VTQ information hub
30. Ofqual’s VTQ information hub was published on 13 November, earlier than in previous years to better support centres’ planning. It provides key dates for Levels 1/2, 2, and 3 qualifications that will be used for progression in 2026 alongside or instead of GCSEs and A-Levels. Its purpose is to help schools and colleges prepare to meet critical deadlines to ensure timely delivery of results.
Access arrangements
31. Ofqual published new access arrangements ‘official statistics in development’ for GCSE, AS and A level on 27 November. These used a new candidate-level dataset of access arrangements granted by exam boards that we linked to exam results data from 2015 to 2016 to 2024 to 2025. This allowed us to estimate a range for the number and proportion of students with valid access arrangements being assessed in each year – correcting the much less accurate picture given by our previous reporting of the data, which we had withdrawn earlier this year.
32. Alongside the statistics, we published 3 research reports: a literature review of the effects of extra time in assessment; an ‘intelligent comment’ about the role of time in assessment; and a statistical investigation of whether GCSE exams in 6 subjects may be time pressured, based on information about items left blank at the end of the exam paper.
33. We also published a regulatory report on Ofqual’s wider work to review the access arrangements system for GCSE, AS and A Level. While this work found that the system generally meets its stated purpose, we identified a range of specific improvements that we now expect the exam boards to make, to support the system’s effectiveness and transparency in line with our regulatory expectations, and always mindful of the challenge of managing access arrangements and reasonable adjustments for schools and colleges.
Communications and stakeholder engagement
34. Ofqual ran a cyber security communications campaign in October. Delivered in partnership with DfE and NCSC, this campaign has improved its impact year-on-year. Reaching 16% of teachers – up from 15% last year – driving higher engagement with digital products and leading to 11% of those secondary teachers who saw the campaign implementing new cyber security measures.
35. I delivered a speech to CST members at their annual conference in October, and was ‘in conversation’ with Jon Severs, TES Editor, at the Schools and Academies Show in November on the topic of qualification reforms, including reflections on the opportunities and challenges of digitisation.
36. Ofqual had a significant presence at the Federation of Awarding Bodies’ annual conference at the end of November. I delivered a keynote on regulatory priorities in the current change agenda, and Catherine Large, ED Policy, delivered a session alongside Skills England on apprenticeship assessment. Colleagues also ran workshop sessions for FAB members on recent changes to Ofqual’s regulatory framework – including the publication of our new policy on Supporting Compliance and Taking Regulatory Action and the introduction of Principles to our General Conditions of Recognition.
Regulation of National Assessments
37. Publication of our annual report on the Regulation of National Assessments is planned for 16 December.
38. Schools completed over 550,000 Reception Baseline Assessments (RBA) with their pupils during September and October. Activity is now coming to an end and Ofqual will conduct an end-of-delivery review with STA. Following a small-scale focus group meeting, we have gained valuable insight from schools into their experience of, and sentiments towards the new RBA which will inform aspects of our upcoming review with STA.
39. STA is completing the final stages of 2026 key-stage 2 test development and approval.
Development of a GCSE in BSL
40. We published the Subject Level Conditions, Requirements and Guidance for GCSEs in British Sign Language on 13 November. Alongside this, we published the outcomes of the public consultation on the draft regulations and these materials were made available in both English and BSL.
41. Media coverage included positive responses from key stakeholders, including Signature and the National Deaf Children’s Society (NDCS).
42. This concludes Ofqual’s work to develop the regulations for this new GCSE subject.
GCSE in Natural History
43. We continue to liaise with DfE on the draft subject content for the proposed GCSE in natural history. In light of the outcomes of the Curriculum and Assessment Review, we are reviewing our proposed assessment arrangements to ensure they align with the expectations for changes to cognate GCSE qualifications. Should we revise any of our proposals, which were previously agreed by the Technical Committee, we will update the Committee and seek its approval ahead of public consultation.
Consultation on on-screen assessment
44. Ofqual’s consultation on on-screen assessment is set to launch on 11 December. As agreed by the Board in October, I have approved the consultation document, in consultation with the Chair. Our research will be published alongside the policy consultation, including research on mode effects.
45. Documents are being shared with Board members ahead of the launch. A comprehensive communications and engagement plan is in place, and engagement with DfE continues, including on the steer letter from the Secretary of State to Ofqual.
46. The consultation will run for 12 weeks, ending in early March, after which we will return to the Board with analysis of responses and recommended next steps.
Formulae and equation sheets
47. As the Board is aware, DfE previously decided that students taking GCSE mathematics, physics and combined science exams up to 2027 would not need to memorise the usual formulae and equations. Ofqual consulted and made the necessary technical changes to our rules to enable exam boards to provide formulae and equation sheets for these exams.
48. DfE is now planning, subject to ministerial approval, to lift the requirement to memorise formulae and equations in these subjects for the lifetime of the current specifications for these qualifications, to apply to exams from 2028 to 2031 (or 2032, depending on the resit policy). Ofqual will therefore need to consult again on the assessment arrangements to support this DfE decision. In line with the governance approach agreed previously, it is my intention to approve the proposals, in consultation with the Chair. We expect to consult in early 2026.
Supporting compliance and taking regulatory action
49. Following the Board’s decisions at the October meeting, the revised policy on supporting compliance and taking regulatory action was published alongside the new appeal rules on 30 October. Amendments to the Governance Framework and internal Scheme of Delegation arising from decisions have also been made.
Counter fraud programme
50. One year on from the launch of our fraud prevention advice note, work is progressing on a strategy across short, medium and long term objectives, which include introducing stronger rules on certificate checks and learner registration, as well as exploring more ambitious approaches to information sharing in response to sector feedback.
51. A counter fraud communications campaign went live in November to coincide with international fraud awareness week. The campaign was developed in partnership with Construction Industry Training Board (CITB) and the Construction Skills Certification Scheme (CSCS) and focuses on an Ofqual-led survey to better understand how the construction industry identifies and reports suspected qualification fraud. The campaign aims to reduce fraud and increase use of the reporting channels.
Artificial intelligence
Regulation of AOs’ use of AI
52. Following successful engagement with AOs and subject matter experts to share and test our work on principles of AI use in marking high-stakes exams, we now plan to publish this research in early January. This work was presented at the AEA Europe conference (see paragraph 71).
53. In October, we launched the first in a 5-part series of online workshops for AOs, focused on innovative uses of AI in qualifications and assessments. Engagement has been high: over 440 individuals registered for the first webinar, with more than 370 attending and around 172 awarding organisations represented, alongside other regulators and sector bodies. The session provided an update on Ofqual’s work and polled AOs on AI opportunities and challenges.
54. The second workshop, held on 12 November, focused on Ofqual’s research into AI in marking, with 435 registrations, 285 attendees, and around 128 AOs represented. Further workshops are planned from January to March, offering smaller, in-depth discussions on a range of AI use cases across the qualification lifecycle.
55. We have begun work to consider our approach to malpractice, including use of AI in assessments, and will be shaping a coherent plan of activity in this area for the coming year.
Internal use of AI
56. Staff are completing the Cabinet Office’s ‘AI for ALL’ One Big Thing training, with over 100 colleagues having completed the course by mid-November. We have also delivered a well-attended internal session on “Getting the most from Microsoft Copilot”. These efforts support our commitment to building AI capability across the organisation.
57. We continue to maintain active engagement with government, other regulators, and the education sector to share learning and understand emerging AI adoption and use cases.
AEA-Europe conference
58. Ofqual colleagues presented research at the annual conference of the Association for Educational Assessment – Europe (AEA-Europe) in November. The topics presented by Ofqual included: comparative judgement; exploring the use of similar items for monitoring grading standards; problem solving; principles of AI use in high stakes marking; principles for determining the optimal item format; oracy.
Covid Inquiry
59. Module 8 of the Covid-19 Inquiry closed for witness evidence at the end of October. The Inquiry did not call Ofqual as a live witness, but we observed the key witnesses’ evidence that was relevant to the awarding of regulated qualifications in 2020 and 2021
Corporate and people matters
Finance update
60. As reported in the Finance paper, at the end of September a revenue underspend of just over £100,000 was forecast.
61. The process of budgeting for financial year 2026/27 is now underway and the budget will be presented to the Board for approval in March, following prior sighting by the PRF Committee for its endorsement.
People update
62. The 2025/26 Civil Service People Survey was completed in October. A summary of results will be circulated at the next Board meeting.