EUROPEAN QUALIFICATIONS FRAMEWORK FOR
LIFE-LONG LEARNING (11189/05)
Letter from Bill Rammell MP, Minister
of State for Lifelong Learning, Further and Higher Education,
Department for Education and Skills to the Chairman
In your letter of 4 November 2005,
you asked that the Committee be sent a copy of the UK response
to this Commission consultation document.
I am pleased to be able to enclose with this
letter a copy of the UK Government's response to the consultation.
My officials sent it to the Commission on 11 January 2006.
My department launched a UK wide consultation
on the Commission Staff Working Paper on the European Qualifications
Framework (EQF) on 2 September 2005. 153 stakeholders were invited
to respond to the consultation directly, and the devolved education
administrations in Scotland, Wales and Northern Ireland also alerted
their stakeholders to the consultation. This response represents
the views of the UK Government, taking account of the responses
I will of course keep the Committee informed
about any developments relating to this document, which the Commission
propose to publish later this year.
23 January 2006
UK RESPONSE ON A PROPOSED EUROPEAN QUALIFICATIONS
The Department for Education and Skills, in
the United Kingdom, launched a UK wide consultation on the Commission
Staff Working Paper on the European Qualifications Framework (EQF)
on 2 September 2005. 153 stakeholders were invited to respond
to the consultation directly, and the devolved education administrations
in Scotland, Wales and Northern Ireland also alerted their stakeholders
to the consultation. The consultation invited interested parties
to provide answers to the questions raised in the Commission's
document. It also invited respondents to raise any other issues
about a European Qualifications Framework.
The responses received were from a wide range
of interested organisations. They included competent authorities,
whose occupations are covered by the provisions of the mutual
recognition Directives; awarding/examination bodies; sector skills
organisations; professional and business organisations; trade
unions; higher education institutions and their representatives
and the devolved education administrations.
This response represents the views of the UK
Government, taking account of the responses received.
The UK welcomes the proposal for an European
Qualifications Framework. We believe that it can help improve
mobility of individuals across borders by allowing qualifications
across different Member States to be related to one another. This
can make a significant contribution to the Lisbon process, by
helping labour markets function more effectively, as well as allowing
individuals to achieve personal fulfilment. We particularly support
the outcome-based approach, and moves towards the recognition
of non-formal and informal learning, which will allow the EQF
to be used for a wide range of different forms of learning.
However, we believe that there are some key
issues which need to be addressed to make the EQF a success. These
The EQF needs to be consistent with
the existing Framework for Qualifications in the European Higher
Education Area (the "Bologna Framework") and the linkages
between the two need to be clearly and simply articulated.
Links between lower levels of the
EQF and qualifications for learners with low skill levels should
be clarified further.
The process for self-certification
of EQF levels should be underpinned by a voluntary peer review
process to improve consistency and build mutual trust.
The level descriptors should be refined
after consultation with stakeholders and an extensive trial phase.
This should involve all stakeholders; and should aim to simplify
and reduce the level of detail.
The "Supporting and indicative
information" in table 2 should not be part of the consultation
document. This level of detail should be the responsibility of
Member States, to reflect their national contexts.
UK RESPONSE TO SPECIFIC CONSULTATION QUESTIONS
1. Are the most important objectives and functions
to be fulfilled by an EQF those set out in the consultation document?
The UK supports the objectives set out in the
consultation document, which recognise the EQF as a translation
device which will allow different national frameworks to be related
to one another. We believe that this has the potential to help
increase the mobility of individuals across Europe, as well as
helping develop institutional and sectoral partnerships across
national boundaries. This could help the internal market work
more effectively, and hence make a significant contribution towards
achievement of the Lisbon goals. It could also help individuals
achieve personal fulfilment by allowing them to work and study
more easily in different Member States. We are particularly pleased
with the focus on learning outcomes, which is consistent with
the development of qualification frameworks across the UK, and
should help move towards a system where individuals are recognised
for what they can do, rather than how long they have studied.
However, it is essential that the EQF remains
a meta-framework, and does not aim to replace or supplant national
frameworks. It is also important that it recognises the frameworks
that are already in place and, in particular that it is totally
consistent with the Framework for Qualifications in the European
Higher Education Area (the "Bologna framework"), to
avoid any confusion that might arise if stakeholders feel that
they have two different frameworks to relate to. Some stakeholders
have expressed concern over the mapping of the EHEA Dublin descriptors
to the EQF descriptors specified in the consultation paper. The
UK believes that the HE sector should be closely involved in a
pilot and testing phase to ensure that the terminology and descriptors
in the two frameworks are compatible with one another.
2. What is needed to make the EQF work in
practical terms (for individual citizens, education and training
systems, the labour market)?
In order to make the EQF work, it needs to be
described in clear and simple terms in order to be accessible
to all key stakeholders. It needs to complement and articulate
clearly to other existing frameworks, such as the EHEA framework
developed under the Bologna Process.
A number of respondents to our consultation
felt that the overall purpose of the EQF, as well as its limitations
could be stated more clearly, and a few misunderstood the nature
of the EQF as an attempt to harmonise or regulate. Clear communication
of the purpose and objectives of the EQF is essential to build
support for it amongst stakeholders.
Furthermore, it is essential that the framework
is not excessively detailed, otherwise it will become complex
and inaccessible. Detail should be left to those implementing
national frameworkswith the EQF merely providing common
reference points. A number of respondents were concerned by the
level of detail in the framework, and the UK would support moves
to further refine and simplify the descriptors.
The EQF also needs the support of employers,
awarding bodies, and professional bodies in order for it to encompass
the full spectrum of lifelong learning. In order to achieve this,
extensive consultation on the detail of the EQF needs to be undertaken.
This should be done through a piloting and test phase that will
involve stakeholders from each of the key sectors.
An integrated credit transfer system would be
useful in the long term to improve the ability of individuals
to acquire qualifications within different learning systems in
different countries. This should be linked to learning outcomes,
to be consistent with the principle of the EQF. However, this
will need to be consistent with existing credit transfer systems,
and in particular, the developments in Higher Education under
the Bologna process.
3. What should be the content and role of
the "supporting and indicative information" on education,
training and learning structures and input (table 2)?
The UK believes that the "supporting and
indicative information" on education, training and learning
structures and input given in table 2 should not be part of the
EQF proposal. This is because it contains input-based measures,
which sometimes contradict the descriptors given in table 1, and
can therefore be confusing. Instead, the content in table 2 should
be the responsibility of each Member State to complete during
the implementation phase of the EQF, to indicate how their national
and sectoral qualifications fit into the EQF.
This view was echoed by our stakeholders, many
of whom felt that table 2 as drafted was confusing to them, and
undermined the outcome-based focus of table 1. However, a number
felt that some sort of information on how the outcomes in table
1 related to the particular qualifications frameworks in the UK
would be helpful.
4. Does the 8-level reference structure sufficiently
capture the complexity of lifelong learning in Europe? Do the
level descriptors, in table 1, adequately capture learning outcomes
and their progression in levels?
The UK supports the 8 level reference structure
as an effective means of capturing a wide range of lifelong learning
approaches. We particularly support the outcome-based approach
of the EQF, which is consistent with the developments within qualification
frameworks across the UK, and are pleased that non-formal and
informal learning will be captured by these descriptors.
However, we have some concerns about the lack
of clarity in the present framework over how lower levels of qualifications,
such as those for learners with low skill levels would be accommodated.
This could weaken progression opportunities across Europe for
vulnerable learners, which is an important issue given the concern
with EU-wide progress against the agreed social inclusion benchmarks.
We would suggest that the content of the lower levels of the EQF
is reviewed to ensure that the lowest levels of qualifications
and learning are recognised within them.
We are also concerned about the level of complexity
within some of the descriptors. Although there is a need to ensure
that the descriptors contain adequate detail to ensure that they
are not too general for practical purposes, we are concerned that
in some areas, the level of detail is approaching that of a national
As mentioned in section 2 above, the UK believes
that it is essential for the actual descriptors to be tested out
in practice, with a wide range of stakeholders and a number of
different qualification systems. There is no mention of a test
and trial period for the actual descriptors within the consultation
document, and we strongly believe that there should be one.
5. How can your national and sectoral qualifications
be matched to the proposed EQF levels and descriptors of learning
There are three different qualification frameworks
in existence in the different parts of the UK. Both national and
sectoral qualifications in the UK will be matched to the EQF through
these national qualifications frameworks.
The involvement of Sector Skills Councils will
be important for matching sectoral qualifications to the EQF in
the UK. More details of this are given in section 10 below.
6. How can a national qualification framework
for lifelong learningreflecting the principles of the EQFbe
developed in your country?
As mentioned above, the UK already has three
different qualifications frameworks in each of the different parts
of the UK. Northern Ireland, Wales and England have a 3-country
framework, known as the National Qualifications Framework (NQF),
which has nine levels, including an entry level. Within this,
Wales has its own Credit and Qualification Framework for Wales
(CQFW). Scotland has a separate own credit and qualifications
framework, the Scottish Credit and Qualifications Framework (SCQF),
based on 12 levels, which includes access levels.
Currently, England, Wales and Northern Ireland
are discussing the development of the current NQF into a more
inclusive unit-based qualifications framework, underpinned by
a system of credit accumulation and transfer across the three
countries. Furthermore, joint working with Ireland has led to
a publication of a diagram showing the equivalence between qualifications
in England, Wales, Scotland, Northern Ireland and Ireland.
The UK believes that its experience of working
with its different qualifications frameworks would provide a useful
model that the Commission may wish to consider when implementing
7. How, and within what timescale, can your
national qualifications systems be developed towards a learning
National qualifications systems in the UK already
adopt a learning outcomes approach.
8. To which extent can the EQF become a catalyst
for developments at sector level?
The EQF can become a catalyst for developments
at sector level, by allowing qualifications developed by sectors
in the UK to be related to their equivalents in other European
countries. Employer and business organisations that responded
to our consultation were optimistic that this could help support
efforts to reduce skill and labour shortages by encouraging mobility
within sectors across Europe.
9. How can the EQF be used to pursue a more
systematic development of knowledge, skills and competencies at
Systematic development of knowledge, skills
and competencies at sector level should first occur through national
qualifications frameworks. The EQF can then be used to translate
these developments to similar ones across Europe. Many sectors
already collaborate on an EU-wide basis and the EQF can help stimulate
collaboration on skill development in similar sectors across different
Member States. However, as a meta-framework, it should not be
used to bypass national frameworks.
10. How can stakeholders at sector level be
involved in supporting the implementation of the EQF? How can
the link between sector skills development and national qualifications
Stakeholders at sector level can only be involved
in supporting the EQF implementation if the content of the EQF
is relevant to them. This means that it should support recognition
of workplace as well as academic learning, and sectoral stakeholders
should be involved in the test phase of the EQF.
To improve the link between sector skills development
and national qualifications, it is important for national qualifications
bodies to work with sector organisations to ensure that the development
of qualifications fits within the national frameworks. In particular,
it is essential that the work on defining knowledge, skills and
competencies at a sectoral level is demand-led. Otherwise, the
development of sectoral qualifications may not necessarily be
relevant to the needs of the employers, which will reduce their
Our mechanism for achieving this in the UK is
through the involvement of Sector Skills Councils. These are employer-led
bodies that are responsible for identifying and defining current
and future skill needs within their sector. Our national qualifications
bodies are working with the Sector Skills Councils to understand
their learning and training needs. The aim is to deliver customised
qualifications that help drive the acquisition of skills in a
sector, and are linked to the national qualifications frameworks
to provide clear pathways for progression.
11. How can the EQF contribute to the development
of mutual trust (eg based on common principles for quality assurance)
between stakeholders involved in lifelong learningat European,
national, sectoral and local levels?
The UK believes that mutual trust cannot solely
be achieved through a consistent set of level descriptors, but
also requires trust in quality assurance systems in different
countries. In particular, we believe that the self-certification
of levels to the national qualifications frameworks in Member
States will need to be strengthened through a form of voluntary
peer review, to build trust and ensure that consistent procedures
are being used.
It is also essential that the EQF does not undermine
existing arrangements for quality assurance under the Bologna
process. This requires consistent terminology, and compatible
12. How can the EQF become a reference to
improve the quality of all levels of lifelong learning?
The EQF can improve the quality of lifelong
learning in the EU by facilitating co-operation and collaboration
between providers in different countries, thereby raising standards.
It can also stimulate the development of national qualifications
frameworks that are outcome based, and recognise a wide range
of learning. However, it is the national qualifications frameworks
themselves, and not the EQF that should be the main drivers of
improvement of quality in lifelong learning. The EQF therefore
needs to ensure that it remains a translation device, complementing
other frameworks that are already in place, and does not seek
to supplant or replace national frameworks.
Letter from the Chairman to Bill Rammell
Thank you for your letter dated 23 January which
was considered by Sub-Committee G on 9 February.
We are grateful to you for sending us a copy
of the UK response to the Commission consultation document.
Although you say that the Government welcomes
the proposal, we note that the response draws attention to several
key issues which it says need to be addressed to make the EQF
a success. Of these, we are particularly concerned over the possibility
of duplication with the Bologna framework. If the Government regards
the Bologna framework as useful so far as higher education is
concerned, is it necessary to have a separate EQF for the EU at
that level? Would it not be better to concentrate on the levels
which Bologna does not cover?
We agree that the other points made in your
response should be pursued. You will recall from other correspondence
that we attach great importance to ensuring that the commitment
of the Commission and Member States to life-long learning is genuine,
effective and based on real understanding of, and adequate support
for, the needs of older learners. We trust this will be given
high priority in any discussions about the EQF.
Your Explanatory Memorandum dated 4 October
2005 reported that the results of the Commission consultation
were expected to be discussed at a conference this month, in preparation
for the formal proposal which the Commission was expected to present
before the end of the current Presidency. Please let us have a
report on the results of the conference, together with your comments
on the above, and any more news you may have about the Commission's
We will retain the document under scrutiny in
13 February 2006
203 Correspondence with Ministers, 45th Report of
Session 2005-06, HL Paper 243, p 612. Back