Apprenticeship Assessment Reform: Turning the Pivot into Progress

Rob explains that we stand at a critical juncture in apprenticeship assessment reform. While the pivot offers welcome flexibility, success isn’t guaranteed. We face significant challenges: employer awareness gaps, quality maintenance risks, and concerning funding pressures. The unchanged 20% assessment cap creates front-loaded costs that particularly threaten smaller awarding organisations’ survival.

As Skills England prepares to release revised assessment plans and Ofqual’s consultation on apprenticeship assessment regulation continues, we are on the cusp of moving into the next stage of the biggest pivot in apprenticeship assessment since 2017. What insights have emerged since the initial announcements, and what must be addressed to ensure the shift is a success? Recent events, including the Federation of Awarding Bodies’ EPA Conference, the AELP Annual Conference, and various employer forums, have provided valuable perspectives from key stakeholders.

Employer Awareness and Engagement

Employers have long expressed their confidence in EPA. They desire assessments that are a true validation of competence and independent, whilst also advocating for a system that is proportionate, offers continuous assessment and is simple. Many employers and training providers are only now beginning to unpack the approaching change, and it is a risk that many employers and providers remain uninformed about the details or rationale behind the pivot; in the absence of clear information and understanding, scepticism can grow.

Employer confidence remains a key driver of apprenticeship uptake. DfE, Ofqual, and Skills England are now more visible and engaging, with Ofqual particularly noted for the clarity and consistency of its communications around apprenticeship reform. But further efforts are needed to raise awareness, and especially amongst employers. Extensive employer participation in Ofqual’s consultation, which closes on 27 August 2025, would be a good headmark and rallying point. Achieving this will require a coordinated effort and practical tools, such as an engagement toolkit that demystifies the technicalities for those less familiar with them.

Maintaining Quality

Since the initial policy announcements, there has been little elaboration, and Skills England has been working with stakeholders on the first five plans.

A major concern has been the risk of a ‘race to the bottom’ that could compromise quality. Apprentices themselves have emphasised the importance of rigorous, high-quality assessments that reflect the value of their achievements.

Currently, there is a strong commitment to quality, with assessment organisations prioritising their reputations and regulatory compliance. While Ofqual and Ofsted play critical roles, it would be shortsighted to rely solely on regulation for the maintenance of quality. The positive commitment to quality must be nurtured and sustained, including by employers and providers across all sectors. The alignment of regulatory, financial, and monitoring frameworks will be key.

The core purpose of apprenticeships, producing occupationally competent employees, must remain central, and the Gateway process, which brings together providers and employers, has been a valuable innovation. Its future remains uncertain, but losing it would be a step backwards. Gateway needs re-imagining in the future construct.

Consistency and Comparability

Employers, assessment organisations, and providers have voiced concerns about reduced consistency and increased complexity due to greater flexibility in assessment design. In our overall approach, we must be careful to consider how we ensure that we facilitate ease of access for employers in particular. It feels that this needs more focus. Similarly, we have not done enough to ensure greater consistency or comparability in a system that will embrace flexibilities well beyond those of today.

There is a risk that the reforms will see Skills England issue assessment plans and then step back from the process until the assessments have occurred, which may be many years later. A potential option to address this, the comparability challenge, and avoid employer consultation fatigue is for Skills England, or a designated body, to convene awarding organisations during development for a consistency check, noting that this should be done in a way that preserves the space for innovation the revised approach creates.

Behavioural, Provider-Delivered, and On-Programme Assessment

Reactions to employer-delivered behavioural assessments have been mixed. While some employers are enthusiastic, others are uncertain about expectations and their capacity to deliver. Concerns have also been expressed that the change may lead to the marginalisation of behavioural assessments or that they overly reflect individual employer values rather than the needs of all employers. Clear guidance and supportive oversight are essential for employers if this innovation is to work and the interests of apprentices are to be protected.

Provider-delivered assessments have also received a cautious response. Many providers speak of lacking the capacity and expertise, having moved away from assessment functions since the adoption of standards-based apprenticeships. Initial uptake is expected to be low, and it is important that the sector is afforded time to explore and adapt to the new flexibility. To overly force the pace or adoption would be counter-productive.

Support for on-programme assessment is stronger, particularly where it aligns with occupational needs. We should therefore see uneven take-up as positive. The commitment to synoptic assessment is welcome and consistent with the competence focus of apprentice assessment and the reform’s goals.

Funding and Implementation

The Department for Education is reviewing the Funding Rules but has indicated that there will be no changes to the overall apprenticeship funding model, including the 20% cap on assessment costs. While the full financial impact is still unclear, there will be increased and front-loaded costs for providers and assessment organisations. Smaller awarding organisations, especially those not part of larger training organisations or groups, will be particularly exposed to these forces, and this is where gaps in provision are most likely to emerge.

Many of these organisations will face the most significant adaptation challenge and describe the challenge as daunting. Assessment organisations that deliver qualifications are better placed to adapt, but all will require some support, and there is an upskilling opportunity for the whole sector. The Federation of Awarding Bodies plans to release a free training package in September, following the publication of the first five plans and the close of Ofqual’s consultation, to support the transition.

It is vital that these organisations are given the time to adapt. Employers and other stakeholders need time to adapt and contribute their expertise. Despite the pressures to show progress, we must not rush to implementation; undermining employer support in any form would be particularly damaging to the credibility of the apprenticeship programme.

In steady-state, awarding organisations estimate they will need up to six months to implement a new plan, which is longer than the current 90-day limit but still faster than typical qualification timelines. Accelerating this process would increase risk, as would permitting mid-programme switching of apprentices to revised assessment regimes, except in the longest programmes.

Looking Ahead: Realising the Reform’s Ambition

The reforms in apprenticeship assessment offer a timely and overdue opportunity to evolve apprenticeship assessment. The pivot introduces welcome flexibility and leverages sector expertise while maintaining the valued principles of independent and synoptic assessment.

However, success is not guaranteed. It depends on how we now thicken out the policy intent and notably to address comparability, the assessment of behaviours and overall quality alongside an appropriate implementation pace. We must balance flexibility with rigour, and pace with preparedness.

Proactive engagement, especially from employers, and a collaborative approach from all stakeholders will be essential. There are promising signs of broader sector engagement, but more work remains, and this is not the time to be leaving key stakeholders behind. To ensure English apprenticeships remain a gold standard for skills development, we need to progress the pivot together.

By Rob Nitsch, Chief Executive of the Federation of Awarding Bodies