Chapter 3 - Consultation Response: Changes to Conditions of Recognition (22 October 2019)

Oct 20, 2026

Uploaded by Patrick

AQA provides detailed consultation responses on proposed changes to the Conditions of Recognition. It addresses Condition F1 (Fees), focusing on transparency of fee information, clarity for purchasers, and concerns about timing, accessibility, and prescriptive publication advance periods. It evaluates categorisation of fees and argues for publishing actual purchasable fees or clearly listed bundle components, while warning against manipulative “notional” pricing. It also comments on invoicing clarity under Condition F3 and offers additional recommendations in later sections.

LanguageEnglish

CategoryExam

FormatPDF

Pages10

Reading Time25 min

AccessFree to download

Chapter 3

1. Condition F1 (Fees): transparency and value for money

2. Fee categorisation clarity for purchasers

3. Additional changes to improve transparency and value for money

4. Condition F3 (Invoicing): clarity on invoicing requirements

5. Other comments on Section F

Chapter 4

6. Condition A3.1 (Duty on Change of Control)

7. Draft guidance on Conflict of Interest

Consultation response Consultation on Changes to the Conditions of Recognition 22 October 2019 Chapter 3 1. To what extent do you agree or disagree that our proposed changes to Condition F1 (Fees) would: a. Increase transparency of fee information? AQA agrees that Awarding Organisations (AOs) publishing price information could make prices more transparent, provide a level playing field among Awarding Organisations and increase information for customers. We have concerns, however, about the timescales the regulators have stated between when this information is published and when candidates sit the qualifications. For instance, a teacher will choose a specification (and AO) at least 27 months before their students in Key Stage 4 sit their first GCSE examination (which usually occurs 21 months after they begin learning the specification, and a teacher will usually have chosen the specification six months earlier so they and colleagues can prepare) . AQA further has concerns that AOs’ websites might publish fee information but make it difficult to find. The regulators might, therefore, want to tighten their requirements about how easily accessible the published information is. While we are slightly reassured, therefore, that Condition F1 .4 allows AOs to accompany the publication of its prices with a statement that they are indicative, we would urge strongly against the regulators being too prescriptive with how far in advance of entry the reformed information on fees would need to be published. We would also, on this point, note that we do not receive any complaints from our centres about the time between when we publish our price information and when the candidates sit their qualifications. b. Help purchasers secure value for money? While AQA agrees it will help centres compare fee information, we feel they will continue to make purchasing decisions based on quality and suitability as well as cost. 2. To what extent do you agree or disagree that the proposed categorisation of fees under Condition F1 would provide sufficient clarity to purchasers? AQA agrees they would provide sufficient clarity. 3. What other changes could we consider to improve: a. Transparency of fee information; and/or b. Value for money; In the market for regulated qualifications If the regulators required the publication of fees on a pre-determined date each year, customers could be confident that AOs had not amended their pricing plans once competitor information had been published. Centres would benefit from lower prices, as AOs would be incentivised to give their best price on publication date. While we would be happy to publish our package fee for a given qualification if that was the only way in which a qualification could be bought, AQA has concerns about publishing the package fee where a qualification can be bought both on its own and as part of a bundle. AQA is of the view that the wording in paragraph 3.24 of the consultation document is clearer than paragraph 3.25 about what must be published in helping buyers achieve value for money. The fees published should be the actual fees a purchaser would pay. Any allowance for the publication of ‘notional’ fees, which exclude other parts of a package including products, services and other qualifications, might encourage AOs to manipulate their pricing information, by giving a higher cost to other aspects of the package, and implying a lower-than-actual qualification fee. The regulators’ Conditions should require, therefore, that AOs publish either (i) a Standard Qualification Fee that must be something the purchaser can actually buy (which may require a change to Condition F2) or (ii) the actual prices they charge together with a very clear list of which products and services are included. The proposal as currently worded risks making pricing information more complicated, rather than less complicated, so AQA would strongly recommend the regulators provide the c

FAQs

What does AQA say about transparency of fee information under proposed Condition F1?

AQA agrees that publishing price information can increase transparency and improve market fairness. It is concerned about regulator-set timescales and about making fee information easy to find on awarding organisations’ websites.

How does AQA suggest fees should be published to support value for money?

AQA recommends that published fees should be the actual fees purchasers pay, or else include the actual prices with a very clear list of bundle products and services. It warns that “notional” fees could enable price manipulation and confuse comparisons.

What recommendations does AQA make regarding invoicing under Condition F3?

AQA would accept a requirement for a more detailed price breakdown than on current invoices, but it is less acceptable if the information requires an overly specific level of granularity.

Oct 20, 2026

Uploaded by Patrick