The Parliament is currently considering the Education (Scotland) Bill (‘the Bill’). This Bill will establish Qualifications Scotland to replace the SQA. It will also create a new office of His Majesty’s Chief Inspector of Education in Scotland, and thereby remove the inspection function from Education Scotland.
One of the themes during the consideration of the Bill has been about the accreditation function. This currently sits as part of the SQA and the Bill envisages the function moving to Qualifications Scotland. Professor Muir’s 2022 report, Putting Learners at the Centre: Towards a Future Vision for Scottish Education, recommended that the accreditation function be separated from the awarding function and be sited within a new national agency for Scottish education which would also take on the curriculum and professional support roles currently undertaken by Education Scotland.
A key concern during consideration of the Bill has been the independence of the accreditation and regulation function of the SQA from the SQA as an awarding body. This was brought into further focus during the issues with the 2024 Higher History papers, where the investigation on that issue was taken forward by the SQA. The review into the Higher History paper was carried out by SQA’s Head of Standards with support and oversight from the Director of Policy, Analysis and Standards. This was not undertaken by the SQA’s Head of Accreditation and National Qualifications are not accredited or regulated by the Accreditation Committee.
What is accreditation?
Accreditation is a process to ensure that a given qualification meets certain criteria which are verified by an external organisation – the accrediting body.
Part of this process will normally involve an awarding body being approved. The approval process will involve ensuring that the awarding body meets the regulatory requirements of the accrediting body.
An awarding body is a body that develops awards or qualifications. Some examples of awarding bodies are: SQA (which is also an accreditation body); City and Guilds; Associated Board of the Royal Schools of Music; and Duke of Edinburgh’s Award.
Accreditation can provide assurance that a qualification is of a certain standard. In other jurisdictions, accreditation of certain qualifications is required (e.g. GCSEs, A Levels in England).
How does accreditation currently work in Scotland?
The Education (Scotland) Act 1996 provides that the qualifications shall be accredited by an Accreditation Committee within the SQA. The Accreditation Committee reports to Ministers rather than to the SQA Board of Management and the SQA Board of Management cannot overturn a decision made by that committee. The Accreditation Committee is chaired by a member of the SQA Board of Management.
Accreditation and regulatory functions
SQA Accreditation function has several aspects. These are that the SQA:
- approves new awarding bodies
- approves qualification products
- accredits qualifications
- approves SCQF credit rating for qualifications
- approves awarding body audit and provider monitoring reports and action plans, and
- agrees sanctions, where applicable, to be placed on awarding bodies.
The SQA’s Accreditation Coordination Group also provides advice and guidance to internal and external stakeholders.
Approval of Awarding Bodies
SQA approves awarding bodies which enables those bodies to submit qualifications for accreditation. Any organisation can be approved by the SQA as an awarding body providing that it can demonstrate that it can meet the relevant regulatory requirements.
Being an approved awarding body means that the body will be subject to regulation by the SQA.
What qualifications are accredited?
The SQA can accredit any qualification providing that it is not a degree. Along with the other UK qualifications regulators, the SQA will also not accredit a qualification which includes ‘Postgraduate’ in the title.
There are four types of qualifications that SQA are required to accredit. These are:
- Scottish Vocational Qualifications (SVQs).
- Alternative Competence Based Qualifications, which are used as the main qualification in Modern Apprenticeship Frameworks. In the early 2010s, the Scottish Government permitted the use of alternative Competence Based Qualifications where the SVQ was not used by the sector.
- Qualifications required for regulatory purpose and/or licensing:
- The Security Industry Authority requires individuals working in certain roles within the private security sector to have a licence. To gain a licence, the individual must achieve a qualification.
- Certain individuals in the Licensed Trade sector must undertake a qualification and the SQA must accredit the qualifications.
- Workplace Core Skills.
All other accreditation is sought on a voluntary basis and accreditation is undertaken free of charge.
SQA have explained to SPICe why bodies would seek accreditation voluntarily. It said:
“Awarding bodies seek to be approved by us so that they can demonstrate to their customer that they and their qualifications meet a regulator standard or so that they can get their qualifications credit rated for inclusion on the SCQF.”
Regulation
SQA regulates awarding bodies and their accredited qualifications to safeguard the interests of learners, employers, parents, funding bodies and Scottish Government. This involves:
- awarding body audits
- provider monitoring visits where the SQA visits providers of the qualification (i.e. not the awarding body)
- self-assessment.
Every awarding body will be audited at least every three years, with bodies considered to be a higher risk being audited more frequently.
How does this compare to England and Wales?
England
In England there is a market for school qualifications, whereas in Scotland the SQA has near monopoly on school level qualifications. In England, the regulation and accreditation functions are undertaken by Ofqual.
Ofqual summarises its responsibilities as regulating “awarding organisations that design, deliver and award qualifications and apprenticeship end-point assessments in England. Ofqual controls entry to the regulated market, and we create rules and provide guidance for awarding organisations to help make sure regulated qualifications are fit for purpose, valid and delivered securely.” Ofqual regulates around 245 awarding organisations to develop, deliver and award qualifications in England.
Ofqual regulates awarding bodies, including “exam boards”. There are four exam boards recognised by Ofqual to award GCSE, AS and A level qualifications in England:
Exam boards can only award GCSEs, AS and A levels that Ofqual has accredited, although they can also award unregulated qualifications such as ‘international GCSEs’ (iGCSEs). Ofqual explains, “Exam boards develop and award GCSEs, AS and A levels based on the subject content set out by the Department for Education and following Ofqual’s General Conditions of Recognition, subject level and qualification level conditions.” Ofqual produces detailed conditions for each qualification.
The Department for Education maintains a list of qualifications that are eligible to receive public funding in England. Part of the process for an awarding body to ensure that its qualification can receive public funding is to have the qualification regulated by Ofqual.
Ofqual sets out how appeals should be handled and there is a an appeal route to Ofqual for certain qualifications. An individual can complain to Ofqual on a number of matters.
Wales
Qualifications Wales is the independent regulator of non-degree qualifications. Prior to its establishment in 2015, the Welsh Government were responsible for regulating qualifications in Wales.
Like Ofqual in England, Qualifications Wales recognises and approves awarding bodies who issue qualifications in Wales. In Wales, there has been reform of the school curriculum and GCSEs and other qualifications are also being reformed to align with the new Curriculum for Wales. New ‘Made for Wales’ GCSEs will start to be taught in the coming academic year.
WJEC is the sole provider of GCSEs, AS and A-Levels linked to the Welsh curriculum. This monopoly is not a policy decision, but rather a market response; WJEC is the only exam board to express interest in developing these qualifications.
Qualifications Wales specifies criteria for qualifications. Qualifications Wales regulates awarding bodies to ensure that they maintain the required standards and deliver qualifications effectively. It has the power to oversee the design of new qualification requirements and can commission awarding bodies to develop new qualifications for the Welsh education system. Qualifications Wales may also designate a qualification as eligible for use on publicly funded programmes of learning for learners under the age of 19.
Scrutiny of the Bill and Reform of Accreditation
The Education, Children and Young People Committee’s report on the Bill discussed both where the accreditation function should sit and what the scope of accreditation and regulation of qualifications should be.
The Committee said that it “believes the accreditation function should sit separately from Qualifications Scotland” but recognised the “challenging nature of the current financial climate in terms of creating a new stand-alone body”. The Committee recommended that the Government “explore more fully the options of where else the accreditation function could sit”.
The Committee linked the purpose of accreditation to where the function might sit. It urged the Government to “clarify what it considers the scope and function of regulation should be” and argued that the “structure and resources for accreditation match the scope of that ambition”.
The SQA’s response to the Muir Review advocated developing and strengthening the accreditation function in Scotland. The SQA said:
“We propose that there is a strengthened function in self-regulation around National Qualifications (where there is not a qualifications market), as well as an augmented role for vocational qualifications (where there is a qualifications market). Features of stronger self-regulation for NQ would involve greater emphasis on codes of practice, monitoring, a system of checks and balances, and critically, greater transparency and independence from government around these.”
The Government’s response to the Committee’s report on the Bill noted that it had undertaken analysis on options for where the accreditation and regulation function should be sited. The Government published details of this analysis in March 2025. The Government also said “a short-life working group was established in October 2023 to look at the role of accreditation and regulation of qualifications and how it currently operates in relation to other forms of oversight across the wider qualifications system.”
At Stage 2 of the Bill consideration process, which is the Committee amending stage, there were a range of suggestions as to where the accreditation function should sit from opposition Members. The Cabinet Secretary for Education and Skills, Jenny Gilruth MSP, also lodged an amendment which would require the Government to undertake a review of the operation of the accreditation provisions, including “the scope of the accreditation function” and “whether the accreditation function should remain a function of Qualifications Scotland”. The Committee agreed the Cabinet Secretary’s amendment, but the Government also agreed to work with opposition Members to discuss the matter further before Stage 3, the final stage of consideration of the Bill in Parliament.
Ned Sharratt
SPICe