Level 3 and Below Reforms: Turning Ambition Into A System That Works For All, and Sticks

The Department for Education has now published more of its policy decisions that shape the future for technical qualifications at Level 3 and below in England, alongside a transition plan that confirms the very demanding timeline for first teach. Ofqual have also published a consultation on the regulatory approach that will govern approval of the new qualifications. 

The reforms are critical to the nation’s skills base and the fortunes of young people across the UK

These are important waypoints for the Government’s qualifications reform programme and they will impact nationwide. The reforms are critical to the nation’s skills base and the fortunes of young people across the UK; their outcome will have a huge impact on efforts to increase youth employment and address workforce shortages.

Few are challenging the objectives and intent: a more coherent structure for technical education with clearer routes for students. Awarding Organisations hope that these reforms will also finally deliver a stable technical education system after a number of false, and expensive, starts over recent years.

As ever, the success of the reforms will depend, heavily, on how the decisions that have been published are implemented.

Maintaining Qualification Availability

For awarding organisations, the most impactful intervention is Ofqual’s regulatory approach. As published, it makes it very difficult for organisations that do not deliver A Levels or T Levels to secure approval for the reformed Level 3 and Level 2 qualifications in the first wave.

If our skills system is to serve learners across the UK and meet industry needs, we need diverse provision. We also need to enact the broader range of assessment options alluded to in the consultation response. The current approach, if carried forward, will have a significant impact on the availability of technical qualifications, particularly at Level 2. Apprenticeships that contain mandatory qualifications will also be affected.

The new qualifications due for introduction in 2028

With the majority of the new qualifications due for introduction in 2028, there is a window to address this. A revised regulatory approach, which Ofqual has already said it will reappraise, will be essential. It will be similarly important that an opening is provided for trade/niche qualifications that support specialist occupational entry, such as those for bakers and blacksmiths, in the Implementation Plan that the Department for Education will publish by mid-June. The continuance of these qualifications will strengthen the reformed offer – and it feels as if there is an option to build out from the occupational qualifications at Level 2. Such an approach will also help to ensure that the reforms support regional skills priorities alongside well as national policy aims.

Pathways That Reflect Student Choices

The Department for Education’s consultation response makes it clear that V Levels will focus on enabling progression into higher education or apprenticeships. The reality is that thousands of young people who complete a Level 3 qualification look for work.

T Levels, even with the adjustments recommended in DfE’s response, will remain highly specialised and inaccessible for many. There are not enough apprenticeships, either for 16‑ or 18‑year‑olds, and those that do exist are not in the right locations – and it is unlikely that the incentives announced recently will fix this.

If the new system is to meet the needs of learners and employers, it must include a clear, credible employment‑focused pathway at Level 3, as well as progression routes into higher education and higher apprenticeships. 

There must also be an option for students with lower GCSE attainment

There must also be an option for students with lower GCSE attainment, but who are capable of Level 3 study. This will be a challenging problem to fix as it will shape perceptions of T Levels and their value, but to not do so will constrain the options for those will lower attainment at GCSE who are capable of moving onto higher study.

Without an employment pathway at Level 3 and options for students with lower attainment at GCSE, the system risks directing some students downwards to Level 2 unnecessarily, or out of education entirely. With a growing unemployed cohort of young people and acute workforce shortages in key sectors such as health, digital support roles and construction, this is a significant concern and will reduce the likelihood of the reforms enduring.

Responding to the reality of student choices will strengthen, not dilute, the reforms.

Qualification Design Flexibility

The size of V Levels is another area where pragmatism will be essential. It is welcome that the consultation response recognises that a small number of partnered V Levels, equivalent to two A Levels, may be appropriate. The maths–further maths model is referenced. Whilst this supports preparation for degree study, it may also be necessary to embrace a ‘double V Level model’ if the sector subject matter is to be covered credibly. Such flexibility will also help to limit the number of V Levels per subject area, which is one of the Department’s headmarks.

Bold Decision Making Will Be Key

The next 12 months are critical for the Qualifications Reform Programme. With most new qualifications launching in 2028, the timeframe for refining the regulatory and implementation details is extremely short. Awarding organisations will show agility, as they have done before.

Nevertheless, we must take the bold decisions in implementation if we are to seize the opportunity for long-lasting positive change.

There can be a tendency towards caution when implementing reforms, the priorities are:

• Moving away from a regulatory approach that locks out capable providers and excessively narrows the market at Level 3 and Level 2.
• Delivering a pathway into work at Level 3, alongside progression into higher education.
• Ensuring there is a viable Level 3 option for learners with lower GCSE attainment.
• Accommodating the trade and niche qualifications on which certain industries rely.
• Taking a pragmatic approach to V Level size, placing a premium on subject relevance and credibility.

And, if we do not take these opportunities, there is a genuine risk that, within a year, the teams at Ofqual and DfE will feel they have delivered the reforms as intended – but the reality for learners and employers will be a weaker, less responsive system that does not stick.

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