The concern that underpins the premise of your question relates to capacity in the school estate, which has certainly been a matter of discussion with the schools and colleges I have visited over the last year. If I can once again allude to the visit to the sixth form college in Hampshire that I made recently, I asked the exam secretary what it would it be like from their perspective—as someone organising the public exams for a large number of young people taking A-levels and other qualifications at 18 or 19—if any significant proportion was done on-screen. I detected a certain blanching and then, as is typical, a series of very practical concerns such as, “Where do all the laptops come from? How do we manage in an exam hall? What about extension leads? What if it does not work on the day of the exam?” It is sometimes easy for policymakers sitting above all this to ignore practical issues that become very real indeed when you talk to the real people in the grassroots institutions who have to deliver these qualifications. That absolutely underpins why we are taking this in hand. First, my view is that—should it happen at all—we cannot allow on-screen specifications to saturate the market in an uncontrolled way, whereby we do not have the tools to manage the volume. Secondly, the extent to which we open the sluice gates should, in the first instance, be very minimal indeed, to make sure that anything that is allowed to enter the market is small scale and therefore sufficiently manageable for schools and colleges. Obviously, the provision of infrastructure in schools and colleges is a matter for the Department for Education, and the Secretary of State's steer letter that accompanied our consultation—where the Government makes their own comments on their ambitions for IT and their take on the IT infrastructure of schools—has been published. But we have to deal with the world as it is, and for teachers, exam officers, headteachers and principals, this feels challenging. That is why, as I say, we are taking a very controlled approach.

The risk of that happening is low. In many cases, not all cases, there is more than one alternative. We have a market of awarding organisations and four exam boards. I deem the likelihood of all qualifications in a particular subject moving on-screen across all exam boards as not impossible, but very low. One of the complexities, but also strengths, of a market-based system for qualifications is that there is choice and diversity within qualifications. So those choices will still be available to schools.

The subject where that is most likely to happen is computer studies or computer science, where in fact we already have some on-screen assessments. Beyond that, you are quite right to say that it is not a theoretical impossibility; but once again, I come back to the way in which the awarding organisation market operates because it is principally about securing market share. Qualifications are their business; if by moving on-screen there is a prospect of losing schools and therefore losing market share, that acts as a strong disincentive for exam boards to make such a decision. They do not want an exodus of schools taking their qualifications. That is not a hard control, but it is a market operation control.

Yes, to a certain extent. Chair, if I can pick up the Member's question in reverse order, taking the handwriting point first; I strongly agree with the premise that underpins that question. Handwriting is cognitively important during the learning process. We may not yet have rock-solid evidence for that, but the emerging evidence is that learning to handwrite does support cognitive development. Ensuring that we do not create incentives in the system that reduce the emphasis on handwriting at earlier stages of learning is important. Again, that is why we are proposing to control on-screen assessments and only allow them in very limited circumstances. Coming back to children with special educational needs and disabilities, again the evidence is not overwhelming but there is some evidence—as our research indicates—that some children with some types of SEND may benefit from the opportunities that on-screen assessment offers. It is of course already the case that under equalities legislation children with a specific SEND can access arrangements for qualifications on-screen to mitigate a learning need.

Well, it will not change up to now because while it is a market, it is a regulated market; how the market behaves is controlled by Ofqual because we are the regulator. If the results of the policy consultation do not make us revise our view and we implement that cap, it will exist until we choose to revoke it. What I want is to watch both how the wider state of education and the resourcing of schools develops, and what the research is telling us over the next two, three, four, and five years. I want to see how the development and accreditation of any actual on-screen specifications is going, how successful that is, and what kind of quality results, before I would propose any revision of that.

Ofqual is proposing that exam boards must use substantially different questions in on-screen and paper-based specifications. Could you explain why that is? How will you ensure that this is done fairly and that the qualifications will be comparable?

I may invite my colleague to come in on this, but let me just give you a quick headline. It is already the case that we have different specifications and therefore different exams, in the same subject between exam boards, and they are comparable in standards. So the methodology for ensuring that we have comparable standards across different question papers in the same subject already exists. The rationale for having different questions in anything that goes from paper to on-screen is largely to do with the way in which mode effects play out. Mode effects are the impact that the method of assessment has on the quality of the student response. The quality of the response is in part shaped by whether they handwrite it or whether they type it. If you imagine a situation where you have an on-screen specification in, let us say—give me a subject, Michael?

Business.

It will not be a business GCSE because that is out of the equation, but just for the sake of the argument let us pretend that there is an online business exam and a handwritten business exam, and the questions are exactly the same. What could happen is that with the online exam, the mode effects lead either to higher marks or lower marks. Because of those mode effects we would have to set standards differently to compensate. If the questions have been the same but the standards are different, we think that would jeopardise public confidence. I am aware I have not explained this very clearly, so I am going to ask my colleague to have another go.

Thank you, and apologies; I was thinking of A-level business. That was my mistake. The key point is essentially that we want to ensure that standards are comparable across all specifications. As Sir Ian said, we go through a process with exam boards every year to ensure that exams are no easier or harder with one exam board compared to another. That is a core principle of the regulatory framework. It is easiest to achieve when they are independent specifications, where examiners are looking at the quality of work as it has been presented through the mode of assessment that students have taken. That is then aggregated and looked at by examiners alongside the range of other evidence that they have. This is essentially the most effective way to maintain standards. Alongside that, we are also interested in making sure that exam boards are making the best opportunities of digital. We do not want them necessarily to be constrained by taking exactly the same questions and simply replicating them on-screen, but to think about how items are presented on-screen, making the best use of the digital technology that they have. So there are those two arguments. The final control—again Sir Ian has mentioned this—is what we will be looking at in our accreditation process. We will be looking at how they are going to ensure standards are maintained across the different forms of assessment on paper and digitally, and how they are going to ensure that the questions are of an appropriate difficulty. We will be scrutinising that upfront as part of our approval process.

Your own research highlights that on-screen assessments could give students from wealthier backgrounds an unfair advantage over others. How are you going to monitor the impact of this? If students are negatively affected, what changes could you make?

Once again, the risk of that happening is one of the reasons we need to take this in hand and prevent an uncontrolled entry of on-screen assessments into the market. The headline principle is that we need to have the tools to manage this so that we can control it. One of our core principles—I am absolutely firmly committed to it—is that no qualification can be an experiment as far as young people are concerned. We will only allow regulated qualifications to be used in schools and colleges if we have reached a very high bar of confidence that they will not, by design, unfairly discriminate against students from less advantaged backgrounds. We will do that process during the accreditation; we will check that there is nothing in the design intention or implementation of the qualification that would inadvertently cause specific harm to students from socio-economically less advantaged backgrounds. There will be no experiments here, and that is a very high bar.

It is probably fair to say, though, that schools in richer areas, possibly private schools, have more income and will be more likely to offer online assessment because they will have the necessary IT equipment.

Yes, but they will have very little opportunity to do it precisely because we allow so little of it to exist in the system.

If I am gauging this right it seems that you are really reluctant; you are really not keen on the idea of on-screen assessments at all. So why do you not just say it is not going to happen?

As I said, the first thing we needed was to make sure we had the tools to control entry to the market, so that is what we did first. We are mindful of the significant risks but as has been alluded to in other questions, there are also some potential benefits. Technology is moving fast. It is a plausible argument to say that many aspects of life are increasingly on-screen, despite all the concerns we hear about that. We thought it was right to consult on a proposal that allowed exam boards to show whether they could develop a qualification that could be delivered fairly for students—albeit in relatively small entry subjects—and we would evaluate that on its own merits. We felt it was appropriate to open the door, but only that wide.

I want to talk a little about exam boards. Ofqual has issued a number of significant fines to awarding bodies this year for breaching regulations regarding exams. Why do these problems occur, and what more can be done to prevent future breaches?

That is a very pertinent question; once again, Chair, I may ask my colleague to come in on the back of my opening remarks. The regulatory powers given to us by Parliament have been used to the full. On arriving as chief regulator I inherited something of a backlog in enforcement cases, and I have been very keen to clear that backlog. Our powers were given to us by Parliament to send clear strong messages to exam boards and to the sector that they will be sanctioned where there are breaches that are potentially damaging for the integrity of the qualification or for students. I am particularly keen that this is done in a timely way, in other words as quickly as can safely be achieved. The adage that justice delayed is justice denied applies in this circumstance; if a student feels that an exam board has done something that has rocked the student’s confidence in the exam that they have worked hard to gain, then something must be seen to be done quickly about that. We have used our formal legal enforcement powers on 26 occasions in the last year, from January to December 2025, which is significant. Not all of those involved fines—for example, we also have the power to impose legally binding special conditions on exam boards as well, to make them do things that we think they might not otherwise do. Why do these things happen? There is a range of reasons: they happen by accident, they happen because exam boards sometimes take their eye off the ball and are not sufficiently attentive to risk management, and they happen because we are operating in a commercial market and exam boards have an eye to what competitors are doing for the same market share. What can be done to stop these things happening in the future? One of the things we always do when we identify non-compliance and move towards using enforcement action is to make sure that the exam board has fully understood the problem, carried out an appropriate root cause analysis of why it happened in the first place, and put in remediation to prevent it happening again. We take a very dim view of exam boards that repeatedly make the same breach of our requirements. That is a very serious offence. If it is a different breach, that is also serious but less serious than repeat offences in the same area. We have the power to escalate the scale of our penalties where exam boards are not learning from past non-compliances and are making the same mistake a second time.

Can an exam board or an awarding body that is making the same mistakes year after year be disqualified?

Yes. The nuclear option is to withdraw recognition. Formal recognition gives the power to an exam board to offer regulated qualifications; if we withdraw recognition, that means that the qualifications that exam board does can no longer be funded in state-funded institutions in England. So that is the nuclear option. We would always consider the impact it would have on students taking those qualifications at the time, but ultimately it is a sanction that is legally at our disposal.

Many of these breaches occurred several years ago—2016, 2017, 2019—so is the delay in Ofqual issuing fines because of this backlog?

Yes.

How has the backlog formed?

The backlog probably formed for a couple of reasons. It was partly because of covid; during the covid years, little enforcement activity took place. That was a situation I inherited as chief regulator. It was also partly because—I hope I can say this—the priority has not always been to speedily bring enforcement cases to a conclusion. One of my personal priorities is to ensure that where there is non-compliance it is speedily brought to enforcement, for the reasons that I alluded to earlier. My view is that justice delayed is justice denied. If I took an exam and somehow the exam board messed it up and I have been caused stress and anxiety as a result, I do not want to wait for three years before I see something done about it, I want something done about it in the current academic year. That is the view I take as somebody who has worked with young people in schools for many years.

Lastly, it was reported in the summer that you were scrutinising Pearson's approach to A-level maths, following concerns about this year's replacement papers. What updates can you give us about the results of this scrutiny?

Pearson is the largest provider of maths A-level in England, and maths A-level is the largest A-level in the country, with a little over 100,000 entries. It has three components, papers 1, 2 and 3; following paper 1, there was speculation on social media about the potential predictability or apparent familiarity of the questions. As a result, Pearson took the decision to withdraw the paper 2 they had originally lined up and replace it with a different paper. When that paper was sat there was further negative commentary from students, particularly on social media, about the range of topics that had been covered. We analysed that and reached the conclusion that when papers 1, 2 and 3 were taken together—paper 3 had not been affected by any of this—the examination gave an accurate indication of the skills, knowledge and understanding of the content, so we deemed the grades to be reliable. However, I was concerned about the anxiety that had been caused to students and the commentary I had read online, so I asked my team to look hard at this and try to make a decision about whether Pearson had in any sense been non-compliant. We have not quite finished that piece of work but when we do it will of course be published in the normal way.

The exam boards that you regulate obviously exist in the context of the real world and its threats. One of those threats is the increasing number of cyber attacks on public sector bodies. The National Audit Office has deemed this to be a threat which is severe and advancing quickly, so I just wonder how confident you are that the cyber security arrangements across all the bodies that you regulate are sufficiently robust?

Thank you for that question. With your permission, Chair, I am going to invite Michael Hanton to take that.

Thank you. The first thing is to recognise the point you have made: that 2025 demonstrated that no industry or sector is immune to cyber threats; unfortunately that is absolutely true for the exam industry as well. In light of that, we are focused on the threat of cyber issues and attacks on the exam industry. We are very grateful for the work and the support we have had from the National Cyber Security Centre; we have worked closely with it and with the exam boards too. The exam boards that are offering high stakes qualifications have ISO 27001, which is the international standard for cyber security. That is an important step but we continue to look at all aspects of how exams are delivered, including looking at third party suppliers and the different interdependencies of what is quite a complex system. In that context it is also worth noting that there are 6,000 schools, colleges and training providers delivering exams each summer; so many other organisations are involved in secure delivery. In light of that, for the past two years we have run our cyber awareness campaign, which is a month long campaign targeted particularly at schools and colleges. We are making sure they have access to the resources that are specifically for them, to help them think about their own individual cyber resilience preparedness and encourage them to check over their arrangements. From our point of view it is an end to end endeavour; this is a topic that we will continue to work on and focus on.

You have mentioned the cyber awareness campaign. Are there any other things that you are doing to your processes—updating, changing, or transforming them—so that you can be sure you are maintaining the confidentiality and the security of exam papers and that you, as well as those you regulate, have a system that is fit for purpose? What is changing to achieve that?

One of the threats that arises in a cyber context is the confidentiality of assessment materials, and that is obviously very important. There are a range of controls in place across our regulatory approach, but essentially the heart of it is to ensure that the fewest number of people possible are aware of the content of assessment materials before they are sat. There are organisations that need to be involved in that process; part of the work we are doing at the moment is to ensure that they have the right security arrangements in place: asking exam boards to look at their third party suppliers, and essentially looking across that broader system of the different stages of exam delivery. That goes, again, all the way through to schools and colleges; there are clear regulations around the storage of exam papers once they come into schools and colleges. There are requirements on things such as the opening of packages, which must be done with two people present, and ensuring that the right papers are opened at the right time so that there are no vulnerabilities right up to the last point before students are taking materials. It is an issue we take very seriously, again, looking end-to-end.

Presumably this is part of your deliberations over online, on-screen assessments as well, as to how—with even greater vulnerabilities in such cases—you might replicate the same monitoring of first sight within a digital system.

Yes, absolutely. As Michael has said, there are already vulnerabilities in the system and as part of the process of accrediting any on-screen proposals we would want to make sure that there were no material additions to such vulnerabilities. Of course, on-screen assessments do not have to mean online assessments; the two things are different. It is possible to have a pre-loaded assessment that is not accessed via the internet. But yes, securing the security of assessment materials is absolutely fundamental to our objective of maintaining public confidence and trust in what is a highly trusted qualification system already. We are not going to take any risks in that space.

That is an interesting question and one that has produced some debate, as you might imagine. We felt that from time to time it was appropriate for us to review our policy on compliance, sanctions and enforcement. As I said earlier, we have a range of powers, and we must be clear with awarding bodies on how those powers are used and who the decision-makers are. We have an enforcement committee that hears contested cases and makes a decision on any settlement cases where a settlement is proposed. I do not personally do that—a group of appointed board members makes those decisions—but we just wanted to clarify the routes to enforcement, the appeals mechanism, and so on. The additional sanction that we introduced was, as you say, a Chief Regulators Rebuke. We felt that there was space for a sanction where things such as a special condition were not appropriate, where it did not meet the bar for a fine, or where the process of getting to a fine would involve a disproportionate and unjustifiable use of public resources, but where public signalling of non-compliance was none the less an important thing to do. As the name suggests, introducing a rebuke allows us to make a formal statement rebuking an awarding organisation for doing something that was non-compliant and potentially not in the interests of students taking the qualifications, and making that public. It is an addition to our regulatory enforcement toolkit.

Not yet.

Interestingly, we consulted on it and we got very sharp feedback from awarding organisations that they would find it a very difficult thing to receive indeed. It would give chief executives cause to have difficult conversations with their boards, and in the case of awarding organisations that are commercial entities with shares, it could have an impact on share price. So they did not like it very much, which gave me the assurance that it might be effective.

You are alluding to our principles condition. We have published a series of conditions under the principles condition, which basically encapsulates the key qualities that we expect from exam boards in the way they work, including honesty, integrity, transparency and co-operation with the regulator. As we have already discussed, there are breaches, and where there are breaches it could be that exam boards may not have acted with the level of integrity that we expect. But what the principles were really intended to do was to extract from the general conditions of regulation the high level principles that effectively inform the conditions that follow. There is nothing new in principles such as honesty and integrity; they are already effectively implicit in all the conditions. But one of the reasons we felt it would be useful to extract and headline those principles is to support awarding organisations in dealing with novel situations, which may not quite fit the exact wording of any of the conditions now. They could go up a level and refer to those principles and think, “Is this course of action at least in line with the principles, even if we cannot quite make it match the other conditions?” Secondly, one of the things we have been doing over the last couple of years is supporting governance in awarding organisations. Governance bodies in awarding organisations are often not familiar with the granularity of the conditions, but we felt it would support governors in holding their own awarding organisations to account if we were able, in relatively straightforward language, to extract high level principles and equip those in governance roles to provide a challenge to their executives.

In your opening address, you referred to inaccurate data on access arrangements that will lead to legitimate public questions; let us consider that in a little more detail. It has been claimed that Ofqual knew about the problem with the statistics on access arrangements for at least two years before any action was taken. Why did it take so long for investigations to begin?

What Ofqual has historically published, Chair, on access arrangements is the data that is provided to Ofqual by exam boards of access arrangements that are in force in the year in question. When an access arrangement is granted in a school or college, it is granted for a period of 26 months. The rationale for that is clear: if you get an access arrangement at the beginning of May in year 11, it will expire at the end of June in year 13, and for all sorts of workload reasons, you then have an access arrangement that covers, in a traditional setting, both GCSE and A level. But what that means is that you have access arrangements that are technically in force, as I say, from the beginning of year 11 through to the end of year 13, including in year 12 when currently the vast majority of students do not take examinations. So while the data that we were publishing was published in good faith, with data received from exam boards on the access arrangements in force at the time that the publication related to, what I realised with a degree of clarity was that the data was not answering the basic question, “What proportion of students taking their GCSEs and A levels in 2025 did so with the support of an access arrangement?” The public legitimately want an answer to that question. The follow-up questions are, “Is it rising, and if so, why is it rising? Is it the right proportion, and if so, why is it the right proportion?” You cannot address any of those questions unless you have the clearest possible answer to the original question, “What proportion of students in this year had access arrangements?” We were not answering that question, and potentially we risked misinforming the public debate. So we took the decision to withdraw those statistics, not because they misrepresented what exam boards had told us—they did not do that—but they were not accurately answering the questions the public had. The work we have been doing since then is to try to ascertain exactly what proportion of students have access arrangements in a particular exam year in question. Let us take 2025 as an example; now that might sound like an easy thing to do but unfortunately it is not. Access arrangements are historically done by exam boards working together, through a system that was originally designed some years ago by the Department for Education. It is a different system to the exam entry system. The exam entry system in schools and colleges normally happens through the school's own management information system, so it is very clear and accurate; it is benchmarked against the actual names of students on roll. But then you have this access arrangement system that happens separately, and you get mismatches in the data between the access arrangements database, the management information system and exam entries, which may involve different spellings of names, nicknames being used, erroneous dates of birth and so on. Reconciling the two is actually quite difficult and laborious and we cannot always do it with accuracy, but I asked my team at Ofqual to do a significant piece of very granular work to try to get the data from the exam boards and work out what proportion actually had access arrangements in the exam series 2025. We have done that to a certain extent, but unfortunately we do not have a precise figure. We have a range, and the reason why we have a range is because of these data inconsistencies between, on the one hand, the accurate exam entry database and on the other, the access arrangements database. In the light of that, we are doing two things; we are continuing to try to get more accurate data, and we have also told exam boards that we expect them to reconsider the systems that they use for access arrangements in order to ensure those are better reconciled with the entry database so that we have more accurate data and we can speak to the legitimate question that the public has on this. Now the new figures that we published for 2025 show that we still have significant access arrangements in the system. They also show that access arrangements are rising year on year; modestly, but rising none the less. They are significantly lower, as you would expect, than the historic figures because of the problems I described associated with the older figures. Importantly—this is also a topic for public debate as well—the figures are still higher in independent schools than they are in state-funded schools, although I would add as a rider that identifications of special educational needs and disabilities are also higher in independent schools than in state-funded schools. I am sorry, that is a very long answer to the question but I hope it made sense.

I will pick apart a few things, starting with the independent schools point that you raised. The statistics are still proportionally much higher in independent schools; let us take for example the numbers of children who have access arrangements for 25% extra time. Nearly a third of children in independent schools have those arrangements compared to less than 25% in state schools. The Independent Schools Council has called for an apology because of the inaccurate data on access arrangements. Have you apologised and if not, are you prepared to do so?

No, I have not apologised. What I have done is to explain clearly why we published the data that we originally published and historically had been publishing. It was data received in good faith from exam boards about the total quantum of access arrangements in place, and that is always what it was. When we drill down into it and try to answer that legitimate public question we arrive at a lower figure, but there is still a differential.

Yes, it is still significantly higher. In terms of the assessments for this year, how confident are you that exam boards are going to meet the number of actions that Ofqual has set out, and how will you monitor their compliance?

It is going to take a little while for exam boards to redesign the access arrangements system. That will not be possible to achieve for summer 2026. For all sorts of reasons, schools often apply for access arrangements either during year 10 or earlier on in year 11. If you are in 11-16 years old schools—about half of our secondary schools are 11-16 years old schools—there is no particular incentive for you to leave the application until year 11 because what the student does after year 11 is not your business. Many of those schools will choose to apply for access arrangements in year 10, so those access arrangements will already be in place. Effecting visible change in this area is going to take a little while; it will not be in summer 2026. We have an expectation that exam boards will comply with equalities law, and many of these access arrangements—those that are under the category of reasonable adjustments—are provided under exam boards' direct responsibilities under equalities law. JCQ, which is effectively the trade body for the exam boards, administers the system and has reviewed the way in which access arrangements are granted; it has not found a specific incident of bad practice. Exam boards are accountable, not just under our regulation but under equalities law, for granting access arrangements in cases where evidence is provided that points to the need for an access arrangement. Where that happens in greater numbers in independent schools than it does in state schools, I do not know what that points to; as I have said already, there are higher proportions of identified SEND in independent schools than state schools. It may be partly a reflection of that, or it may be evidence of other kinds of needs. I do not know the answer, but exam boards are under an obligation under equalities law to do this fairly, and would ultimately be answerable under equalities legislation if they did not.

During the pandemic we obviously saw widespread grade inflation, as teachers awarded grades. I was one of those teachers; I was trying to make sure I did it in line with expectations. We know that the inquiry into covid-19 has taken evidence from a range of witnesses about these arrangements into exams. Once that module of the inquiry is reported back, what steps will Ofqual take to engage with those findings, and what lessons do you think you will learn so that you can be informed in response to any future pandemic?

Regarding the question about the covid pandemic and the inquiry, Module 8—the schools and children module—has now finished hearing but has not yet reported. It is clearly a statutory inquiry and I have given written evidence that is in the public domain and is in considerable detail. Once the module results and the findings are published we will, of course, engage with them seriously and take any steps that we have not already taken. But this provides an opportunity for me to say briefly that, as per my evidence, there are two principal areas of learning that we take from the pandemic experience. The first is that an attempt to award qualifications and grade them in a way that is separate or divorced from the actual performance level of the work of individual students is unlikely to command public confidence. That is effectively what happened in 2020. The arrangements that were originally put in place in 2020 were done largely under direction from the Secretary of State for Education at the time, but they overly separated the actual performance of individual students from the grades they got. That did not hold public confidence, and a principal learning I take from that experience is that any such approach in the future is equally unlikely to hold public confidence.

Will they have to do exams in a future pandemic?

At the beginning of the pandemic our advice to the Government was not to cancel exams. In the event they were still cancelled. Our preference will always be that students should take exams if it is at all humanly possible to do so because that provides the only robust, fair way to award qualifications based on student performance. If it is impossible to take exams—this moves on to the second area of learning that I wanted to talk about—there needs to have been pre-scenario planned ways of dealing with qualification awards in the absence of exams. They are likely to be imperfect; as you have already alluded to, we saw grade inflation in 2021. That was an imperfect system but it did at least hold the link between student work and the grade received. There are two broad areas where we have been active in this. First, is to impose a resilience condition, C2.6, in our statutory framework. That requires exam boards to ensure that schools abide by our advice and retain evidence of student work within their examination course that we can have recourse to should we need evidence for awarding qualifications and holding that link between grade and work. Secondly, as I alluded to earlier, is detailed scenario planning for the cancelling of exams at a range of different points in the school year and in a range of different ways, with an eye to whether there is a likelihood that exams might be able to restart or happen in some shape or form. No actual scenario is going to directly match any planned scenario, but at least having a range of planned scenarios enables us to look at what possible recourses there are in the event that exams are cancelled. I need to underline, Chair, that without exams, the awarding of qualifications will be an imperfect exercise. But as I say, holding that link between individual student performance and grade is something that we have learned from the pandemic. It is also helpful for me to underline—which I did in writing in my evidence—that we are sorry for the anxiety and stress that was caused to students in the summer of 2020. I do not want to make any bones about that, but the background and how we got to that point is documented in detail in the written evidence. As I say, once Module 8 reports we will look at the findings with interest, and if there is any further action for us to take we will of course take it.

If somebody was interested, where might they find these detailed scenario planning documents?

We have not published those yet; it is work that we do internally.

I would like to ask you about the new British Sign Language GCSE, which was set to be rolled out in September last year. Ofqual did not start consulting on the assessment regulations until April and there has been huge disappointment in the deaf community about the length of time it is taking to bring this GCSE into existence. What is the reason for the delay?

By way of response, Chair, I will just give a headline if I may, and then invite Michael Hanton to give some more detail in answer to that important question. We are absolutely committed to playing our part in bringing the British Sign Language qualification to schools, ensuring that we have done all the policy work that we need to do to ensure that the subject content that the DFE has developed can be developed into a specification by exam boards. Michael, can you give a bit more detail on timelines, please?

Perhaps the place to start is to say that in November 2025 we confirmed all our regulatory requirements, so in essence everything is now in place for exam boards to develop a GCSE in British Sign Language. The point I would reflect on is that it is obviously vital that a GCSE in British Sign Language stands up alongside other GCSEs and that it is a rigorous, high-quality qualification. Alongside that, we were very committed to working closely with the deaf community and making sure that we were drawing on expertise in terms of how to develop this qualification. There are a couple of interesting, quite unique features about BSL as a language; there is no written form, for example, and there are regional variants. So there are particular challenges in terms of designing the qualification and ensuring that it can operate effectively. It did take some time to work with the deaf community to make sure we had a qualification that reflected the genuine needs of the deaf community, including looking at content around the culture of BSL as a language and its place in the deaf community. It took some time, but I am pleased that we were able to complete it and everything is now in place ready for the next stage.

There was an article in Schools Week that said that AQA have said it does not want to offer it, and there are three other exam boards that have not said yet whether they will. So there are concerns that there may be no exam board that wants to offer it. What steps can you take if that is the case?

As you say, four exam boards are currently recognised to offer GCSEs in England; they are making their own individual decisions about what qualifications they offer and obviously there are new qualifications as we have talked about this morning from the Curriculum and Assessment Review. We do not have the power to force an exam board to offer a particular qualification, that is not something that we—

Can you rebuke them if they do not do it.

Gosh!

We can only rebuke them, Chair, for regulatory non-compliance, and unfortunately it would not be regulatory non-compliance, it would be effectively a commercial and market decision.

I would just say—I know there has been some commentary on this in the press as well as among the deaf community—that there is the opportunity for an awarding organisation to become recognised to offer a GCSE in this particular area. That is a route that is open and we would welcome conversations about that.

Could it be an organisation that just does BSL GCSE and nothing else?

That is right.

There is no legal obstacle to a new awarding organisation that is not currently recognised to deliver GCSEs coming forward and asking to be recognised to deliver a GCSE specifically for British Sign Language. That could happen.

Is it quite a lengthy process for them to get recognised?

This is a “piece of string” answer: it depends how strong they are and how ready they are for recognition. As Michael has alluded to, GCSEs are high prestige qualifications and we would want to make sure that British Sign Language GCSE stood muster against all other GCSEs, that it was of the same quality and the same standard. There would be a bar that the awarding organisation would have to meet, but it is not impossible that it could be met.

This is essentially a parallel answer to the one about BSL: we do not have the power to make an exam board offer a GCSE or an A-level or any other qualification. Once the subject content is developed, which is the DFE's responsibility, an exam board needs to step forward and develop a specification. I know that Ministers have met with the exam boards and encouraged them to consider developing a specific Ukrainian GCSE, but as yet no exam board has picked that challenge up and run with it. That is essentially the reason why there is no regulated GCSE in Ukrainian.

Thank you very much. Is there anything else that you would like to bring to the attention of the Committee this morning?

I do not think so. It has been a wide-ranging and, from our point of view, helpful discussion. Thank you for your questions. I hope our answers have provided clarity and assurance for the Members who have posed them.

Thank you very much for coming to give your evidence to us today. We look forward to seeing you in a future session. That brings our session for today to a close.