Notice

Pearson undertaking

Published 17 April 2025

Applies to England

Undertaking given by Pearson Education Limited (‘Pearson’) to the Office of Qualifications and Examinations Regulations (‘Ofqual’), in accordance with B8 of the General Conditions of Recognition (‘the Conditions’).

Background

1. Pearson is an awarding organisation recognised by Ofqual to deliver a range of General Qualifications as well as Vocational and Technical Qualifications.

2. On 25 October 2024 Pearson signed a settlement proposal by which it admitted that it had failed to comply with its Conditions of Recognition in relation to the identification, monitoring and management of conflicts of interest, and in relation to maintaining the confidentiality of assessment materials during 2023. Pearson agreed to the imposition by Ofqual of a requirement for it to pay a monetary penalty and costs.

3. As part of the settlement process, Ofqual required Pearson to provide information about the measures it had taken, and those it intended to take, to minimise the risk that issues similar to those which occurred in 2023 might occur in future years. Pearson has provided information about the resources it has invested, and continues to invest, in IT and automation processes to improve controls and reduce risk. Pearson has provided an Undertaking to Ofqual submitting its conflict of interest processes, relevant IT systems, and procedures to an audit to test compliance, the results of which will be shared with Ofqual.

4. On 31 January 2025, Ofqual published its notice of intention to accept the settlement proposal. The notice of intention sets out the factual background which provides the context for this undertaking. The 2 documents should be read together.

5. Pearson has agreed to provide this undertaking to give assurance to Ofqual as to the measures it is taking to secure the safe and effective delivery of its qualifications in the future.

Undertaking

6. In order to ensure improved compliance with Ofqual’s Conditions, Pearson has put in place enhancements to its conflicts of interest, processes and procedures. To ensure that these enhancements are operating effectively, Pearson Education Limited has requested an audit of those processes, and its relevant IT systems, be carried out by the Pearson group audit function, which operates independently of the Pearson qualifications division.

7. Pearson has shared, and agreed, the scope of its audit with Ofqual. The audit has now commenced.

8. The outcome of the audit will be reported to the Audit Committee of the Pearson Plc Board. A copy the final audit report will be shared with Ofqual, promptly upon receipt by Pearson, and by no later than 4pm on Friday 4 April 2025.

9. Any actions required by the audit will be monitored by the Pearson Plc Audit Committee. Details of those actions, along with timeframes for completion and progress updates will also be shared with Ofqual through an action plan, to be produced by Pearson, and agreed with Ofqual.

10. Pearson undertakes to comply with the action plan that is agreed with Ofqual which will include progress updates on any actions identified by the audit, within agreed timescales.

The Objectives of the Undertaking

1. 11. Pearson expects completion of the undertaking will:

   1. a) Allow it to identify, manage and mitigate any aspect of its current processes and procedures which creates or contributes to avoidable risks to the identification, monitoring and management of conflicts of interest.

   2. b) Inform the development and implementation of revised processes and procedures which minimise the incidence of avoidable risks and promote a right-first-time delivery model,

   3. c) Inform its approach to the identification and management of emerging risks, allowing it proactively to resolve any risks which could affect the safe and valid delivery of its qualifications,

   4. d) Support it to build, train and retain its in-house expertise in relation to the development, delivery and award of its qualifications, which will reinforce a right-first-time model and increase its ability to react to emerging issues.

Declaration

1. 12. In giving this undertaking, I acknowledge on behalf of Pearson that:

   1. a) The rules of interpretation and definitions outlined in General Condition J1 shall apply to this undertaking;

   2. b) Ofqual will publish this undertaking on a date to be confirmed following consultation with Pearson;

   3. c) Ofqual may provide information to the Department for Education (DfE) and the Institute for Apprenticeships and Technical Education (IfATE) about Pearson’s undertaking, including Pearson’s performance under the undertaking and the sharing of any updates provided by Pearson and Ofqual’s analysis of it1;

   4. d) Ofqual may take regulatory action in respect of any failure to comply with the terms of this undertaking which may include the issue of a direction, the imposition of a monetary penalty, withdrawal of Recognition, costs recovery, and/or any other such action as it deems appropriate, acting in accordance with Ofqual’s ‘Taking regulatory action’ policy (20122);

   5. e) Nothing within this undertaking restricts Ofqual’s ability to conduct its own review, audit, investigation and/or other monitoring activity of Pearson at any time.

Signed:

Name: Cath Jadhav
Responsible Officer
Pearson
Date: 14 March 2025