Regulating post-16 VTQs at L2 and L3

Closes 2 Jul 2026

F Certs and Occ Certs Assessment design (Moderation of centre-marked assessments)

Moderation of centre-marked assessments

Where awarding organisations permit centres to mark assessments, there need to be appropriate controls in place for awarding organisations to ensure marking is accurate and consistent. Ofqual requires awarding organisations to have arrangements in place known as Centre Assessment Standards Scrutiny (CASS) to oversee centre-marking.

Awarding organisations can determine their own approach under these requirements, for example deciding the types of checks they do, how often these occur, and when these happen, based on the design of their qualification. Such approaches are used in many vocational and technical qualifications and typically involve awarding organisations periodically sampling and checking school or college marking. Awarding organisations consider whether any adjustments are needed, and depending on how the qualification is delivered, may do this before or after results are issued. This means that not all components or all students are necessarily available to be sampled from each year, as long as all are sampled over a period of time.

We also specify a particular form of CASS, known as Moderation. Moderation is defined in Ofqual’s rules and is how school or college marking of centre-marked assessment in GCSEs, AS and A Levels, Key Stage 4 Technical Awards and Technical Qualifications within T Levels is checked. Moderation provides a higher level of awarding organisation control, as it requires checks to be completed across all components, and adjustments made, before results are issued.

Moderation in qualifications such as GCSEs and A Levels typically involves an awarding organisation sampling centre marking, and then where necessary, making adjustments to a centre’s marking, based on its review of the sample. Ofqual does not specify the exact process to be used for Moderation though, so approaches other than those used in the qualifications above may also be capable of meeting this requirement.

Proposal

We recognise the nature of the assessments in Foundation Certificates and Occupational Certificates may lead to different types of evidence being produced to that produced in other qualifications where Moderation is used. We do however consider it important that where an awarding organisation allows schools or colleges to mark assessments in a Foundation Certificate or Occupational Certificate, marking from across all components is checked, and where necessary adjusted, ahead of results being issued.

We propose therefore that centre-marked assessments in Foundation Certificates and Occupational Certificates should be subject to Moderation as defined in Ofqual’s framework, and to add Foundation Certificates and Occupational Certificates to the List of assessments that must be Moderated under General Condition H2.3(a)(i).

The proposal to permit both numerical marking and direct grading may affect the processes to moderate these assessments. While Moderation is often associated with assessments that are marked numerically, Ofqual does not specify the exact process to be used for Moderation. Awarding organisations may make adjustments in different ways and may decide to take different approaches to the sampling and checking of results. In directly graded assessments, for example, it may not be possible to apply the same adjustment across a cohort, but it may be possible instead to require a centre to repeat an assessment to adjust its marking to the required standard, where an awarding organisation identifies an issue with a centre’s marking. The way a qualification is delivered would need to reflect the Moderation approach being used, for example scheduling assessments sufficiently far ahead of results being issued to allow these checks and any adjustments to be made.

Our rules allow for awarding organisations to take such approaches, so long as they meet the requirements of checks and necessary adjustments taking place before results are issued.

40. To what extent do you agree or disagree with the proposal to require awarding organisations to conduct Moderation of all centre-marked assessment in: