Apprenticeship Assessment Reform: Can We Build Confidence Without Adding Complexity?

A fundamental aspect of the apprenticeship system has always been to prove, to employers and to the public, that apprentices are competent, capable and ready for work. Assessment is the foundation of that promise. If we get it right, apprenticeships inspire confidence, unlock opportunity and drive economic growth. If we get it wrong, we risk undermining employers’ trust and learners’ futures.

Ofqual’s consultation on a new regulatory framework for apprenticeship assessment is an opportunity to rethink how assessment works in practice. AELP’s message on behalf of our members is clear: reform should strengthen the system, not make it more complicated.

At its heart, assessment reform should pass five simple tests. Each is linked to one of five “C’s”:

• Cost
  Are we reducing financial burden or adding to it?
• Complexity
  Does this make the process simpler or more convoluted?
• Consistency
  Will this lead to more uniform outcomes across the board?
• Capacity
  Are we enabling additional assessor capacity to deliver effectively, or stretching the system further?
• Clarity
  Is the purpose and process of the assessment clearly understood?

If reforms can’t deliver on these five tests, they risk damaging the very system they’re meant to strengthen.  These tests shouldn’t just be Ofqual’s responsibility to meet, but Skills England and DfE too.

Employer confidence must come first

One of our strongest concerns is the proposed purposes of assessment. The consultation sets out a hierarchy of assessment purposes that risks downplaying what really matters: giving employers confidence that an apprentice is competent to do the job. Without that assurance, the apprenticeship brand weakens. In high-risk sectors such as engineering or health, even subtle shifts in the definition of competence (from “fully occupationally competent” to simply “occupationally competent”) could dilute trust and discourage employer engagement. Employers need to know that when an apprentice completes, they are genuinely job-ready, particularly if they are working in high-risk settings. Anything less undermines the whole system.

Complexity helps no one

There’s also a danger of creating a maze of rules that vary between awarding organisations. Take synoptic assessment, for example. In principle, it’s a positive step, testing whether learners can integrate knowledge, skills and behaviours from across the whole of their apprenticeship, and an element we feel should be kept. But without clear, consistent guidance from Ofqual, it risks becoming a patchwork of approaches that confuse learners, frustrate providers and make results less comparable.

Similarly, when it comes to marking and moderation, AELP supports a proportion of assessments being independently marked by awarding organisations to safeguard reliability. But blunt thresholds without clarity, such as the current “40%” requirement, risk generating duplication and bureaucracy rather than real assurance. We have been clear in our response to Ofqual’s consultation that this is an area that they need to look at.

Transition to the new system must be realistic

Perhaps the biggest practical risk lies in the transition arrangements moving to apprenticeship assessment from EPA. Apprenticeships are long programmes, with learners already in flight. Expecting providers and awarding organisations to switch models almost overnight is unrealistic and disruptive. We are urging Ofqual to allow at least six months as a baseline, with clear distinctions between new starts and existing learners, and a managed teach-out period. We recognise this will lead to a dual system potentially for a long period, but reform cannot come at the expense of stability for apprentices already on their journey.

And then there’s the matter of cost…none of this is cost-free. Re-designing assessments, staffing new quality assurance processes, and aligning with new guidance will all create pressures, not just for AOs; there will be an impact for providers too, particularly for those who are smaller and more specialist. Without proportionate arrangements, there’s a risk of consolidation in the market that reduces diversity and choice. That would be the opposite of what the system needs.

If reforms drive up cost, complexity, and inconsistency, we risk undermining capacity at the very moment when employers are demanding more skills from the system.

How can we pass the ‘five tests’?

So how can assessment reform meet those tests so it can be more cost-efficient, simplify processes, ensure consistency, build system capacity, and provide clarity on purpose?

• Prioritise employer confidence in outcomes above all else.
• Provide clear, proportionate guidance that avoids duplication and reduces burdens.
• Adopt a phased, risk-based implementation that gives providers and awarding organisations time to adapt.
• Safeguard smaller providers with proportionate expectations, so innovation and specialist provision aren’t driven out of the market.
• Build consistency through assessment plans and clear expectations for awarding organisations.

Trust at the heart of apprenticeships

Apprenticeships are one of the most effective levers we have to close long-established skills gaps and to power economic growth, both key missions of the government. However, the system only works if it is trusted. Employers need to know apprentices are job-ready. Learners need to know their achievements will be recognised fairly and are transferable. And the public needs to know that apprenticeships deliver real value. That trust depends on regulation. But regulation can add confusion, duplication, and unnecessary complexity, risks weakening confidence instead of building it.

Ofqual’s consultation is a timely opportunity to shape apprenticeship assessment, so it becomes simpler, clearer, and more consistent. AELP is committed to working with Ofqual, DfE, and Skills England to ensure that all the different cogs can align. Because if done well, these reforms can build employer confidence, support providers, and give learners the assurance that their achievements are recognised fairly.

By Helen Johns, Policy and Stakeholder Manager at AELP