Consultation outcome

Subject-level conditions and guidance for new GCSEs in French, German and Spanish: response analysis

Updated 14 June 2022

Introduction

In January 2022, following review of the consultation responses and wider stakeholder feedback, the Department for Education (DfE) published the new GCSE French, German and Spanish subject content. DfE confirmed that the new qualifications will be available for first teaching from September 2024, with first assessments in summer 2026.

Also in January 2022, Ofqual published the confirmed assessment arrangements for these new qualifications. This followed a review of the requirements for assessing the proposed new content, which the exam boards offering GCSE qualifications in French, German and Spanish must follow, and a public consultation conducted at the same time as the DfE consultation on the required subject content.

Ofqual then consulted on the proposed subject-level conditions, requirements and guidance, which detail the regulatory requirements that must be followed in all new GCSE qualifications in French, German and Spanish.

In this document we analyse the responses to that consultation.

Who responded?

The consultation was open from 14 March to 19 April. Technical consultations on proposed regulations usually attract fewer public (non-exam board) respondents than assessment policy consultations and typically include little contextual information. However, given the level of public interest in the revisions to GCSE French, German and Spanish we included a more detailed description of the proposals to explain them to a wider audience.

We received 88 responses, with the majority being from the teaching community.

15 responses represented the views of organisations:

• 8 responses from a school, college or teacher representative group
• 3 responses from an awarding body or exam board
• 2 responses from a subject association or learned society
• 1 response from a union
• 1 other response

The other 73 were responses from individuals:

• 60 responses from teachers responding in a personal capacity
• 5 responses from individuals from academy chains
• 3 responses from members of a senior leadership team (SLT)
• 1 response from a consultant
• 1 response from a parent or carer
• 1 response from a private training provider
• 1 response from a school or college
• 1 other response

No responses were received from students, which was not unexpected given the detailed regulatory focus of the proposals. Almost all of the respondents were based in England, with the only exceptions being 1 from Scotland and 2 from Wales.

We received responses from the 3 exam boards that currently offer GCSEs in French, German and Spanish.

We were pleased to receive these responses and thank everyone who took the time to respond. We recognise that respondents to this consultation were self-selecting, so the responses are not necessarily representative of the general public or any specific group.

Approach to analysis

The consultation included 7 questions: 3 on the regulatory proposals and 2 on each of the regulatory and equality impact assessments. The consultation was published on our website, and respondents could respond using the Citizen Space consultation platform which was accessed via a link from the Ofqual webpage.

As the consultation covered the detailed regulatory proposals, the questions were asked as open comment questions to allow respondents to comment in their own words.

Questions 1 to 3 on the regulatory proposals, covered the three sections of the proposals: the conditions, requirements and guidance.

Responses to the consultation questions are presented in the order they were asked. For each of the questions, Ofqual presented background contextual information, followed by the proposals, and then invited respondents to comment if they wished. Respondents did not have to answer all the questions, and in some instances, they did not comment on the proposals.

All comments have been analysed. In some instances, respondents answered a question with comments that did not relate to that question. Where this was the case, those comments were considered against the question to which the comments related, rather than the question against which they were provided.

This report covers the key findings. Some comments have been used to illustrate the points made by respondents. Where we have included quotes from the responses, we have edited some for brevity and to preserve anonymity but have been careful not to change their meaning.

Common themes raised

A large number of comments related to matters which were not within the remit of this consultation. These focussed mainly on issues which had already been consulted on and on which decisions have already been made. In particular, many comments questioned the subject content and the approach to tiering. While these were not the subject of this consultation, we have summarised views on these topics here.

Many comments from respondents with a teaching background (teachers, schools, colleges, other representative and interest groups) provided comments relating to the subject content requirements, which have now been finalised and published by DfE. This is because many regulatory proposals referred to requirements set out in the subject content.

Common themes on the subject content repeated those raised in response to the previous DfE consultation (and in the previous Ofqual consultation on the assessment arrangements). These included the perceived challenges of dictation and the difference between the three languages, the introduction of a read aloud text, concerns about the possible limitations of vocabulary lists, and grammar and sound-symbol correspondence (SSC), again with concerns about differences in the languages.

Similarly, many comments referred to the assessment arrangements which have already been confirmed - the assessment objectives, use of tiered assessments, and use of non-exam assessment (NEA) for the assessment of speaking. While the assessment approach was finalised, the consultation focussed on the wording and detail of the approach to regulating these requirements, in particular details relating to the speaking assessment and the guidance for the application of the assessment objectives.

Comments on the use of tiering included calls for a change - whether to remove tiering, allow students to take assessments across a mix of foundation and higher tier, rather than the single tier entry that is required, or to take a different approach to tiering entirely. These comments have been noted, however as decisions on tiering have already been taken, the focus of this consultation analysis remains on the proposed subject level conditions, requirements and guidance.

Another key theme raised by many of the respondents was requests for greater clarity of the requirements, with those from a teaching background being more likely to query what the wording meant than those from exam boards who are more familiar with regulations. We welcome these queries as we seek to ensure our publications are clear to all, regardless of their familiarity with regulatory requirements.

Some comments called for Ofqual to provide examples of how exam boards could comply with the regulatory and/or content requirements. Exam boards are required to demonstrate in their assessment strategies their approach to meeting certain content requirements, for example to covering the grammar requirements or to compiling the vocabulary list.

Comments on the regulatory proposals relating to speaking assessment and the assessment objective guidance are noted in the relevant section below.

Detailed analysis

Proposed conditions

Question 1. Do you have any comments about the proposed conditions?

• Condition 1 – compliance with DfE content requirements
• Condition 2 – assessing the full range of abilities
• Condition 3 – compliance with Ofqual assessment requirements
• Condition 4 – assessment of spoken language
• Condition 5 – access to dictionaries

Around half of respondents did not respond to this question. A few respondents stated that the conditions had already been decided and were not currently for consultation.

As these subject level conditions reflect current requirements for GCSE modern foreign languages, and have therefore already been decided, I see no value in proposing changes.

Teacher responding in a personal capacity

Where respondents did comment, many felt the requirements were fair and appropriate, and noted they are consistent with the current requirements.

These proposed conditions are reasonable and acceptable.

School or college

One exam board queried the requirement in condition 4.3(b) for awarding organisations to ensure that the assessment of speaking takes place during a five week period in April and May, which was proposed as a condition, whereas in the regulations for the current GCSEs, it is in the subject level guidance.

Another exam board commented that the wording of Condition 4.4 is complex:

We find the wording complex (essentially that an awarding organisation must ensure that xxx is not required to, but it may…). However, our interpretation of this condition is that it provides awarding organisations with a degree of flexibility around the timing of the five-week window of assessment for speaking. If this is the case, and given the main audience is likely to be awarding organisations, it may be that other stakeholders will not be particularly confused by the wording of this condition.

Awarding body or exam board

Proposed requirements

Question 2. Do you have any comments about the proposed requirements?

This question covered a range of requirements relating to both the assessment arrangements and to specific content requirements. Most respondents commented here.

As mentioned in the section on common themes, some commented on the requirements in the subject content or on the assessment arrangements that were published in January 2022. These decisions were not the subject of this consultation.

Assessment Requirements

Grammar and sound-symbol correspondence requirements

One languages teaching association queried the proposed requirement for awarding organisations to set out in the assessment strategy their “approach to covering the grammar requirements in the assessments for the qualification”, with some stating that Ofqual should exemplify what an acceptable approach might look like.

It is not clear what “an approach to covering the grammar requirements” would look like in practice. It is not possible to give feedback on an unclear proposition. An example here of how such an approach can be articulated would enable consultation responses. The same comment applies to the requirement to state the “approach” to covering the vocabulary: is Ofqual looking for the method used to compile the vocab list., or something else?

Other representative or interest group

Vocabulary requirements

One languages teaching association commented on the requirement to demonstrate in their assessment strategies their approach to compiling the vocabulary list.

We note that Awarding Organisations have to demonstrate their approach to covering the vocabulary in the assessments. Presumably this is to explain how they will test the vocabulary in their assessments in each exam series and over time- to ensure the same words are not repeated too often, and that all words are tested. This will be an extremely difficult task, especially given the fact that word lists will be made up of high frequency words. It is difficult to word an amendment to the requirement, but we would wish to urge that Ofqual adopt a flexible and realistic approach to this requirement.

Other representative or interest group

One exam board commented on the vocabulary requirements, noting that a reference to a requirement from an earlier draft of the subject content could now be removed. This reference was also queried by a few others.

We would like to comment on the requirement that ‘an awarding organisation must set out its approach to compiling the vocabulary list, including an overview of the parts of speech distribution’. We do not understand the purpose of this requirement, as there is no longer reference to this in the subject content document.

Awarding body or exam board

Where “a balance of parts of speech” is mentioned, what will this be? Can there be assurances that there will be no more artificial boundaries that restrict natural communication?

Teacher responding in a personal capacity

Speaking assessment

The proposed requirements for the assessment of speaking generated numerous comments, with respondents noting the proposal to maintain the current timings for both the preparation period and the assessment itself. Whilst the assessment timing did not result in comments, the proposed preparation time was widely commented on.

Time allocation for preparation remains unchanged although the number of tasks to be prepared has increased. I propose an increase in the time allocated to preparation.

Teacher responding in a personal capacity

The requirements around the speaking assessment include the same amount of formal preparation time as in the current qualifications. As each new qualification will include an additional (reading aloud) task we feel it would be helpful to increase the time range available for formal preparation by two minutes to ‘…between 12 and 14 minutes’.

Awarding body or exam board

We note that this is the same preparation time currently provided to students for the speaking exam in the current GCSE where they have to prepare for two tasks: the ‘role play’ and the ‘picture-based task’. The equivalents of these two tasks remain in the new speaking assessment, but there will also be an additional task of ‘read aloud’, which will need preparation time. Therefore, we propose that the range provided for the preparation time should be extended, for example up to 15 minutes, to ensure awarding organisations are able to select an appropriate amount of preparation time from the range, based on evidence of candidates’ needs when the new element has been taken into consideration.

Awarding body or exam board

Understanding spoken extracts

The requirements relating to the assessment of understanding spoken extracts were widely commented on, with general support for the regulatory approach based on a required number of words rather than the current approach of specifying a required assessment time. That said, some comments focused on the proposed upper word limit for foundation tier, with calls for it to be raised, on the basis that allowing more words to be used in a spoken extract can provide more support to students, improving accessibility of the assessment.

We agree with the word limit ranges that have been set for spoken extracts.

Awarding body or exam board

The DfE subject content specifies the number of words for Foundation as 1200 and for Higher 1700 i.e ratio of 70%. However, the limit on the number of words in this requirement does not follow the same ratio… If there is to be a limit imposed, we propose that the proportion of the minimum and maximum reflect the same ratio of 70% i.e. keep High at 700-850 and increase Foundation to 500-600.

Other representative or interest group

It is our view that the total number of words proposed at Foundation tier should be increased to between 450 and 550, to take into account the different nature of the three languages (e.g., no subject pronoun in Spanish; negation in French requires one extra word each time a negative expression is used) … We would also like confirmation that the reference to ‘understanding spoken extracts’ relates only to listening comprehension tasks and does not include the separate requirement for dictation (20 words at Foundation and 30 words at Higher).

Awarding body or exam board

We also think there will be a challenge around the number of words and texts; fewer words does not mean it will necessarily be easier to understand as sometimes the information repeated in a different ways aids students’ understanding; we therefore believe a higher number of words may be helpful on occasions to allow for repetition, giving context and reinforcement. The length of the text does not necessarily equate to how demanding something is. Sometimes a short extract is a very short track with limited context and no repetition can be more demanding of comprehension. We welcome the stipulation that there will be sufficient reading time; we would also recommend having sufficient pause time for students to formulate answers.

Union

Dictation

Comments on the proposed regulatory requirements for dictation often related to how dictation would be assessed, particularly given the differences in sound-symbol correspondence in the three languages.

As for dictation, we recommend a more precise definition of “word” (type? token? lemma?) when determining text length. Differences between languages must also be accounted for. More can be said in 20-30 words in some languages compared to others. Dictation is also harder in some languages with opaque sound-spelling relationships such as French compared to German or Spanish. We request reassurance that exam boards will be supported in adjusting demands for French, and it should be crystal clear that no student who picks French as their ML should be disadvantaged over students picking German or Spanish, owing to the greater demands of this task in this language. It is also unclear whether this dictation is also intended to test AO3; if not, will incorrect spellings, but spellings which correspond with the sound articulated, be accepted? The assessment objectives tested by the dictation task are of critical importance and this as yet remains unclear, so a full consultation response is not possible.

Other representative or interest group

One exam board commented that the wording of the proposed regulatory requirement could be misinterpreted.

The word ‘each’ implies that the dictation should be made up of a number of extracts of a minimum of 20/30 words each. Our understanding from previous cross-AO meetings with Ofqual is that the dictation should be a minimum of 20/30 words in total. It is important to have a clear expectation of how long the total dictation should be in order to ensure comparability across awarding organisations. As currently written, having a number of extracts of 20/30 words minimum is too open to interpretation.

Awarding body or exam board

Understanding written language

The proposed requirements relating to the assessment of understanding written language also stipulate the total number of words that may be used, as well as the maximum number of words in any single text, and the maximum number of texts to be used in the assessment of this skill. Some respondents commented that the proposed maximum number of texts that may be used, alongside the word count requirements, would be too restrictive, narrowing the range of text lengths that may be used given how the total number of words could mathematically be divided into each permitted text.

Can we propose more texts (no maximum) with less words so as not to overwhelm Foundation candidates?

Teacher responding in a personal capacity

We strongly believe that the restriction of number of texts combined with a word limit of maximum 100 words is extremely unhelpful and could lead to a daunting and depressing experience, especially for Foundation level students who may well ‘give up’ at an early stage of an exam which launches into long texts. The constraint given could lead to 7 tests of nearly 100 words for Foundation with no opportunity to break these up… Long texts make for daunting exam experience. It is better (and more authentic) to have an accessible experience involving reading, for example, several short notices / adverts. Candidates would be more overwhelmed by 7 long texts than by, say, 12 shorter texts. If this were addressed by introducing short texts and thereby being forced to reduce the number of words overall, this could compromise the validity of the exam, as fewer words would be insufficient to allocate marks in a way that would discriminate sufficiently over 5 grades at Foundation and 6 grades at Higher.

Other representative or interest group

The requirements around understanding written language are likely to result in the use of extracts which are relatively long and potentially less accessible to some learners. The requirements may also limit the opportunities for awarding organisations to use some authentic contexts such as a direction or instruction sign within these assessments. It would be helpful if the maximum number of texts allowed was increased (for example, to a maximum of 9 texts and 10 texts for foundation tier and higher tier respectively) to provide awarding organisations with more flexibility for achieving the required word ranges by using a greater number of shorter texts. This is likely to improve the exam experience for learners.

Awarding body or exam board

Translation

Few comments were received relating to the proposed regulatory requirements relating to the translation, which are consistent with the current requirements and specify the same minimum word count for each tier.

Proposed guidance

Question 3. Do you have any comments about the proposed guidance?

This question focused on the proposed subject level guidance document. Most respondents provided a comment here, while 22 chose not to respond. Again, many respondents commented on the subject content requirements, which have been covered in the earlier section on “Common themes”. Comments relating to the regulatory proposals are covered in this section.

Assessment of speaking

The guidance relating to the assessment of speaking included three proposals relating to the three tasks required by the subject content: the read aloud task and subsequent conversation, the role play, and the visual stimulus/stimuli and subsequent interaction.

Some respondents called for clarity in relation to the guidance on the read aloud task, particularly in relation to whether there would be questions to prepare in advance, or whether the exchange would be unprepared.

The read aloud is very short and, as with the dictation, we do not know what it is assessing apart from accurate pronunciation. Is it SSC being tested or memory of whole words and chunks?

Consultant

It is unclear how the conversation relates to the text which has been read aloud. Is it an unscripted conversation related to the theme/topic of the text or is it based on comprehension of the text?

Teacher responding in a personal capacity

A few respondents sought clarity on the expectations for the role play.

In order to satisfy the subject content requirements that the task be unambiguous, guidance should clearly state that the instructions and prompts must be in English.

Teacher responding in a personal capacity

Assessment of writing

Very few comments were received relating to the guidance on the assessment of writing other than a comment on clarity of requirements.

We would like to note that no assessment requirements have been stipulated for the writing element of the qualifications, although there is ‘guidance’ provided in the guidance document. We welcome the opportunity to set out our own rationale for the design of our writing assessment.

Awarding body or exam board

In the assessment of writing we are concerned that if an AO chooses to test writing through a mixed skill task involving responding to written assessed language there again could be a double penalty (not understanding task, producing irrelevant assessed language). Clarification is required about ensuring there are unambiguous instructions in English for the written task.

Union

Infer meaning

A few respondents commented on the guidance on infer meaning.

We welcome the interpretation of this task.

Union

We understand the definition of this word which matches the subject content.

Other representative or interest group

Dictation of short spoken extracts

A few respondents suggested the proposed guidance on dictation was unclear, although this was not queried by exam boards.

There is mention of using an extract that may have already been heard. What is the meaning behind this, if an exam board were to choose this option? What would be being tested exactly?

Teacher responding in a personal capacity

Guidance on the new assessment objectives

Some respondents felt the guidance on assessment objectives (AOs) should be revised to clarify expectations for tasks using visual stimuli and to allow for tasks with stimuli or prompts in English.

As with the role play, this format does not match any of the AOs (speaking in response to spoken/written) The format of a visual stimulus (not in written French) and output in the assessed language does not apparently match any of the AOs (speaking in response to spoken/written) if we assume that ‘written’ means ‘written in the assessed language’.

Other representative or interest group

As they stand, they do not explicitly allow for a stimulus in English for reading, listening, the role play and writing. The original assessment objectives should be re-worded to ensure consistency between subject content and Assessment Objectives. If this is not possible at the very least the guidance must be clarified further to ensure that the tasks required by the subject content paragraph 9 be assessed as required. i.e. that ‘written’ can be interpreted as ‘written English’.

Teacher responding in a personal capacity

A few respondents commented that the guidance should be clearer about which assessment objective marks for the various tasks would sit under, while an exam board was content that this was not stipulated.

Which of the assessment objectives does the role play satisfy? (given that in order to satisfy the subject content requirements that the task be unambiguous, the instructions and prompts must be in English.) Which of the assessment objectives does the visual stimuli satisfy?

Teacher responding in a personal capacity

We appreciate and welcome that none of the interpretations/definitions specifically name tasks that must be allocated to the strands allowing freedom to the awarding organisations to design and rationalise their own assessment structures.

Awarding body or exam board

A few respondents queried the inclusion in the guidance to AO3 of ‘intonation’.

Why is intonation included in AO3? Does that not go beyond word/vocabulary level?

Teacher responding in a personal capacity

We would query the addition of ‘intonation’ in the guidance related to speaking in AO3, when it does not appear as a requirement in the subject content in the assessment of pronunciation. The DfE only requires clear and comprehensible pronunciation when speaking the language (page 4). Intonation is only referenced in the subject content in relation to interrogatives for both French and Spanish and ‘stress’ is referenced as a Higher tier aspect of SSC knowledge for Spanish (there is no similar requirement for German). We would appreciate clarification on this.

Awarding body or exam board

One exam board noted the drafting of some of the guidance could be clearer.

In the Strand 2 interpretation, bullet point 1, we would like to highlight that although we do understand that the second clause ‘and writing in the assessed language in response to spoken stimuli’ seems to be referencing the dictation task, on first reading of this bullet point the ‘and’ seemed to join ‘understanding of spoken language and writing’, which lead to some momentary confusion. If it were possible to separate the clauses that would remove any confusion currently being created by the wording.

Awarding body or exam board

Equality impact

Question 4. We have set out our view that our proposals would not impact (positively or negatively) on students who share a particular protected characteristic. Are there any potential impacts that we have not identified?

Question 5. Are there any additional steps we could take to mitigate any negative impact you have identified would result from our proposals, on students who share a protected characteristic?

We received 56 responses to question 4 and 49 to question 5. Most respondents to these questions raised potential impacts on students who share a particular protected characteristic. Almost without exception, however, these related either to issues in the subject content, or in the assessment arrangements on which Ofqual has already consulted and made decisions. In particular, respondents raised concerns about the lack of mixed tiering, the content requirement for dictation and talking about visual stimuli, arrangements for students who are deaf or hard of hearing or who have visual impairements, and issues stemming from the prescribed vocabulary (mostly focussed on potential discrimination).

Many responses recognised that the issues they raised were a matter stemming from the subject content rather than Ofqual’s regulations.

In some cases, however, respondents proposed guidance as a solution.

Can there be some guidance about subject pronouns? Which should we teach for students who do not identify as he or she? Which pronouns will be accepted under the exam board mark schemes?

Teacher (responding in a personal capacity)

We urge guidance to awarding organisations regarding how assessments could be adapted for those with physical impairments which can directly affect the way in which they communicate e.g.

Hearing impaired:

• assistance in accessing spoken word

• allowance made for SSC difficulties (dictation / read aloud)

Other representative or interest group

Others suggested adaptations to the assessment as a mitigation for students for whom some of the content may be less accessible.

Could the dictation part of the exam (or even the whole listening) perhaps be a video for students to watch? This may support students who are hearing impaired as they could lip-read the speakers.

Teacher (responding in a personal capacity)

Regulatory impact

Question 6. We have set out our understanding of the cost implications and burdens of our proposals for schools, colleges and exam boards. Are there any other potential costs or burdens that we have not identified?

Question 7. Are there any additional steps we could take to reduce the costs or burdens of our proposals?

We received 64 responses to question 6 and 60 to question 7. Almost all the responses we received to these questions focussed on the costs to schools and colleges of purchasing new resources, paying for or providing training for teachers, and spending time planning and preparing for the new curriculum. These were impacts which we had identified in our consultation.

Suggested additional steps to reduce these costs and burdens focussed on the awarding organisations providing free access to training and resources.

Provide free training for teachers and sufficient time to implement the changes.

Teacher (responding in a personal capacity)

Free resources/exemplars produced by the exam boards ASAP.

School, college or teacher representative group

Others provided practical suggestions as to how training could be made easier to access.

Providing online training that can be done during pre-arranged school INSET rather than require travel to a large city for training. This would mean the whole team can be part of the training and would reduce the cost for schools.

Teacher (responding in a personal capacity)

A significant proportion of respondents suggested that the easiest way to reduce burden would be to not introduce the new qualifications at all.

The awarding organisations which responded to these questions identified costs which were similar to, but slightly more specific than, the general ones we identified in our consultation:

In addition to those already identified, there will be cost implications for awarding organisations in relation to:

• development of resource materials to support the delivery of the new qualifications

• development of entry, processing and awarding systems

• costs of running a legacy resit series in summer 2026, if required

Awarding body or exam board

Annex A: List of organisational respondents

When completing the consultation questionnaire, respondents were asked to indicate whether they were responding as an individual or on behalf of an organisation. These are the organisations that submitted a non-confidential response and provided the name of the organisation:

• AQA
• Association of School and College Leaders
• Helsby High School
• Independent Schools’ Modern Languages Association
• Pearson Education Ltd
• Saffron Walden County High School
• Schoolshape
• Sir William Borlase’s Grammar School
• The Association for Language Learning
• WJEC