ASCL supports the overall aim of greater consistency, comparability and clarity across post-16 technical and vocational qualifications but emphasises that reforms must remain deliverable in real-world centre conditions.

There is a need to maintain an appropriate balance between robust regulation and flexibility, ensuring qualifications remain responsive to different subjects, sectors and learner needs.

Manageability and workload for schools and colleges must be a central consideration, particularly given cumulative reform pressures and constraints on staffing and resources.

Qualification design should be curriculum-led rather than assessment-led, supporting applied learning, engagement and progression rather than over-emphasising measurement and accountability.

Reforms must take full account of disadvantaged learners and those with SEND, ensuring accessibility, fairness and avoidance of unintended barriers (including digital inequality).

Full response to consultation