International GCSEs and the DfE ban – was there a better path?

It is reported that the DfE has decided not to allow international GCSEs to be allowed to be used in league tables.

This is not a surprise though I think it is bad policy. I will explain some background, my involvement in discussions about this before I left in January 2014, and why I think it is a mistake.

None of the boards’ iGCSEs counted in league tables pre-2010. We thought this was a mistake. Some of the best private schools used the Cambridge International iGCSE. Some great state schools told us in Opposition that they wanted to do the same. It seemed reasonable to have more diversity in the system and let state schools do what private schools were doing particularly given the huge problems with standard GCSEs and the difficulty with reforming them.

During 2013, as standard GCSEs were being reformed, the issue arose of what to do about iGCSEs.

The issue was complicated by differences among the boards. I have never heard anyone claim that the Cambridge International iGCSE is easier than the standard GCSE. However, there were persistent arguments that other boards’ iGCSEs were not as hard as GCSEs and private schools and others were being conned.

There was a piece of research circulating (from people very well known in the education world who are taken very seriously) that plotted the Cambridge iGCSE against the standard GCSE and another board’s iGCSE, with the former harder than GCSEs and the latter easier than GCSEs. The research was not published because the people concerned were frightened of legal action (itself a telling detail about the epidemic dishonesty in the English debate on exams and standards, a dishonesty that, I think, most who discuss education policy greatly underestimate).

In 2013, officials and Ofqual argued that the reformed GCSEs starting from 2015 should completely replace iGCSEs which should not be allowed in the league tables. MG and I were not keen on this idea. I spoke to people about their concerns. I suggested the following path through (the below is not a quote from my memo, which I will dig out, but includes the main ideas)…

The DfE should announce that anybody who wants their exams, including iGCSEs, to be included in league tables will have to produce clear overwhelming and independent evidence that they are significantly more challenging than standard GCSEs. If they produce such evidence, we will include them; if not, not. This means that we avoid banning things that are obviously better than GCSEs but we also cull those exam boards who are abusing the system. We will also learn from the evidence presented and that exercise will be a useful thing – even if none of the boards submit anything we will learn something valuable. We’re trying to move all of these debates towards people discussing evidence rather than hunches and this is a very good candidate for this approach.

The responses boiled down to two things.

1) Nobody had an argument against the idea as policy.

2) Nobody wanted to do it. The bureaucratic arguments amounted to: a) ‘It’s messy.’ b) ‘We’ll get sued by the exam boards who are always cheating things and will hire fancy lawyers.’ c) ‘Ofqual doesn’t want to.’ Why? ‘It’s messy.’ d) Unstated but hanging over the discussion – ‘it’s a lot of hard work on a marginal issue and nobody is going to attack us for being elitist if we ban them’.

Given this response, MG and spads thought we should try it.

Some time in autumn 2013, I can’t remember when, I was tipped off that ‘David Laws hates your idea, he just wants to ban them, there’s a meeting shortly’. I went to the meeting. I was not optimistic and assumed I would have to torpedo him with ‘SoS agrees with me’, given the state of relationships by then given Clegg’s appalling behaviour. My assumption was wrong.

The issues were explained. I gave him my argument. He had not heard it. I said that the bureaucratic arguments were not relevant – particularly absurd fears about legal challenges (an argument deployed daily) – and the best thing educationally was to give it a whirl regardless of some complexity and irrelevant media noise. Laws listened and asked questions. He was reasonable. He asked officials if anybody had a policy argument against the idea. Nobody did, the main argument was ‘Ofqual really wants us to ban them’. It was also clear though that the issue was not closed and officials knew I was soon leaving.

It is no surprise to see the news today. The bureaucracy now has its clarity, but is it a good decision? Were Nicky Morgan / her spads given an alternative (it would not surprise me if the option was never presented to them)? What will the DfE say when a state school says ‘Eton does the Cambridge iGCSE in X because they think it’s better – why can’t we offer our pupils the same thing, as you promised before the 2010 election?’? Can anybody see a downside to trying the other path, given one could always have reverted to banning everything if it proved unworkable?

It is of course possible that detailed work was done after I left and this decision was taken for reasons that are not public but are sound. If so, I am sure the new evidence-based DfE will make the technical arguments public.

Please leave comments, corrections etc.

UPDATE 1. This story strengthens my view that one of the most important things for the improvement of education in English state schools is the development of new exams that are outside the regulatory structure of the DfE and Ofqual – exams that are aimed purely at encouraging deep skills in mathematical modelling, extended writing and so on. It is not a coincidence that perhaps the most challenging exam taken in English schools – maths STEP – a) is not created by the domestic exam boards (Cambridge Assessment, not OCR), b) has zero input from DfE, c) is not regulated by Ofqual, d) has a clear educational purpose of encouraging deep skills needed for a serious undergraduate degree, and e) the people who use it as a tool would be horrified at the idea of the DfE, Ofqual, or ‘education policy people’ proposing Whitehall should have anything to do with it. I will blog soon on how I think a new ‘post-GCSE & A Level’ system could evolve.

UPDATE 2. As some emails winging from the DfE say, not all officials wanted the ban and some agreed with the course suggested above. True. (I tend to assume readers of this blog will assume the DfE is not monolithic.) But it was also clear which way  Whitehall’s gravity was pulling.

UPDATE 3. An email arrives from inside the DfE – a senior official who was involved in these decisions… He points to this research on iGCSEs. The C/D borderline figures are the most interesting.

I want to stress – I am not saying that international GCSEs are ‘the answer’ to the problems with the exam system. I do not think they are. I think the problems are much more fundamental and require much deeper changes. My point is that it would have been much better policy to ask the boards for hard evidence about the exams in order that the policy world can examine the issues on the basis of data rather than hunches and just ‘officials say they’re easier’ / ‘well why does Eton do them then?’ etc, which is the level of debate over the past decade. If the DfE made the decision on the basis largely of the evidence in the link above, then it should explain this publicly so people can judge whether their thought process was reasonable, otherwise inevitably many will assume the decision was made for bureaucratic – not educational – reasons.





13 thoughts on “International GCSEs and the DfE ban – was there a better path?

  1. Let me tell you why I might have sued over this as the CEO of a new AO and nothing to do with “cheating” since the whole point of setting up TLM was to improve a broken system without actually destroying the value of practical application in the curriculum. It’s all to do with unfair competition in a market dominated by a small number of players.

    The reason IGCSE is banned is that IGCSE is not a GCSE confusing? GCSEs have to conform to certain criteria. There are other qualifications that count in school league tables that are not GCSEs, the only thing that is different in the case of IGCSE is the word GCSE in the title. It should never have happened in the first place because Ofqual conditions of regulation say that qualification titles should not be misleading and what could be more misleading than having GCSE in the title of a qualification that is not a GCSE. The snag is that Cambridge International Exams trade marked IGCSE and the government does not have a trade mark for GCSE so a lot of potential legal issues there. Presumably CIE used the GCSE name as a brand strengthening exercise in its international markets but outside the UK where there is no Ofqual (or QCA as it was then) regulation they did not have to include coursework or other things that that market might not have found acceptable. The problem is that if the government allow a qualification that is not a GCSE to count as one in a way other qualifications that are not GCSEs can’t, people like me are going to complain because it is giving a commercial advantage to a dominant player in a market.

    So we have the potential for this to be violating Ofqual regulations, it’s arguably against Trademark rules for trademarks not to be misleading and its also potentially falling foul of the 1998 Competition Act. If the government give CIE a privileged position too it’s arguably state aid which is also illegal. On top of that CIE license the IGCSE brand to dominant players in the market but refuse to do so to others so that too could be illegal under the 1998 competition act (chapter 2) if it constitutes dominant players acting as a cartel.

    Imagine Sainsbury, Tesco and Asda putting an organic brand name on a food that was not organic, licensing its use between themselves but refusing to allow any other player in the market to use the brand.

    So I think in this instance perhaps the politicians were sensible to be cautious 😉


    • I don’t understand what this means – ‘The reason IGCSE is banned is that IGCSE is not a GCSE confusing?’
      I agree there are some tricky issues regarding names / brand and the law.
      I disagree re the ‘state aid’ point. It is almost always possible – and happens daily – to construct some general argument as you have along such lines but in vast majority of cases the issue is easily dealt with IF you have a sensible process and reasonable goals. Most ‘state aid’ bogey men are like ‘EU procurement’ bogeymen – they are problems mainly because of Whitehall’s utter dysfunction. Having had many such arguments, I was not at all worried re ‘state aid’ challenges IF we had instituted a sensible process along the lines I describe above.
      IF one wanted to, one could work out the issues you describe quite easily.
      But that is not the real point about the nature of decisions over exams.
      Best wishes


      • Sorry missed a vital full stop after GCSE and before confusing – just to confuse you more :-). It’s not just names. GCSE has specific requirements laid down by Ofqual. As soon as you say those don’t matter why should one non-GCSE be given preference over any other? The definition of a GCSE is the GCSE subject criteria. IGCSE does not meet them so it is not a GCSE. That is why it is confusing. Most people even the SoS probably thought IGCSE was a GCSE. The devil really is in the detail.

        The point about process and goals is that Ofqual has them. They are laid down in the conditions for regulation. The DfE has them in its conditions for providing points for league tables. Not much point in having these if you just drive a coach and horses through them on a whim of a SoS who doesn’t understand the market. You seem to think this is easy to work out. The only ways I see to work it out are as follows,

        1. Scrap GCSE and the need for subject criteria.
        2. Scrap league tables and points as it is all about them really.
        3. Redesign IGCSEs to fit GCSE subject criteria in which case they would be GCSEs.
        4. Pay compensation to all the other commercial interests that would be damaged by giving preferential treatment to one player in the market.

        I should think 1, 2 and 4 would be politically unacceptable and 3, probably the owners have too much to lose by sacrificing the flexibility in their international markets.

        I have put some more detail below to show why even if you discount state aid, there are other significant problems that are not easy to resolve. It’s just not worth the hassle.

        You have to remember that this is a commercial market. It is not just a set of public sector provisions. If the Minister for food stood up and said the government preferred Tesco’s beans to Sainsbury, Asda or your local corner shop with no objective reason other than say popularity it would give an unfair advantage to one supplier over the others and reinforce a monopoly. Only a court would be able to decide if that constituted state aid or not but I should think the case is at least arguable. OK, forget state aid, how about a challenge on the grounds that Ofqual conditions have been flouted?

        E2.3 An awarding organisation must ensure that each qualification which it makes available, or proposes to make available, has a title which it uses consistently in its advertising and in its communications with users of qualifications.

        E2.4 An awarding organisation must ensure that the titles of qualifications which it makes available, or proposes to make available, are not misleading to users of qualifications.

        On E2.3 the use of iGCSE has been used widely for marketing when the trademark is IGCSE. Think the “case” is trivial? Ask Apple, I think they will take a different view. “i” implies to do with the internet or Apple branding. IGCSE is nothing to do with technology. But more misleading is the term GCSE itself. It isn’t a GCSE so it is misleading. Incidentally I asked Ofqual if we could rebrand our qualifications under EGCSE since we did them across Europe and they are electronically delivered. Answer was no it would be misleading. So how come IGCSE isn’t? As a start up company we have enough problems competing with large established monopolies without having to play uphill on a tilted playing field.

        I won’t go into competition law as there is no time here but given I got a major investigation initiated over Microsoft Schools Agreement on that I think I do know something about it. MS Schools agreement is no longer in operation.

        Incidentally why do you think IGCSE is particularly high quality? Is it because private schools do them, because they are more difficult to pass than GCSE? Evidence? The latter does not seem likely to me as I know a number of state schools that do them for the exact opposite reason. See Tim Burkard’s comments. No doubt some people love IGCSE but you could say that about a whole raft qualifications scrapped after the Wolf report.

        If we really want to challenge the top 10% of the attainment range let them start Level 3 qualifications earlier. Get their GCSE A*s out of the way at the end of year 9 or 10 and do say 4, 5 or 6 A levels starting in Y11. Maybe do a Level 4 qual. in an area of particular interest at 18. IGCSE is another red herring in strategies for raising standards, there are far better ways of stretching bright kids without having to “re-organise the system”. There is already too much shuffling of deckchairs under the guise of “reform” or “rigour”.

        Cheers, have a good weekend 🙂


  2. I work with a chemistry teacher who was enthusiastic about the Cambridge IGCSE because it is logically structured, and almost completely devoid of green propaganda and ‘how science works’ rubbish. He reckons that he could get better results with low-ability pupils because of the former factor, but that many teachers (and quite possibly Ofqual) reckon that pupils with a marginal grasp of Chemistry could still get a C grade by parroting environmentally-correct phrases. Outside of the industry, relatively few people understand how exams work: rigorous material is included, but the pass rate is set so low that almost any marginally-literate child can get a C by answering a few brain-dead questions.


  3. Working in a history department currently running a brilliant iGCSE on International Relations in the 20th Century. It is a shame that now the school is thinking about changing out of it due to league table concerns.


  4. I wholeheartedly agree with the arguments deployed in the italicised paragraph. Frankly, I think schools should do the iGCSEs and sod the league tables, if they think that’s in their pupils best interests. I’ll bet admissions tutors at Oxbridge etc will continue to see the Cambridge International iGCSE as, at the very least, an acceptable alternative to GCSEs, and possibly a superior version.


  5. Update 1

    It’s very easy to write difficult maths exams, if that’s all you want I’ll do it for 10k a year, deliver them on-line and get them marked for £5 a candidate, then you can scrap all the rest of the bureaucracy. (I have real evidence that this is possible) And you don’t need a multi-million pound monopoly to do it either. The snag is you’ll need to think of something for all the other things like FE funding accountability, school league tables and all the adult education qualifications that need licenses to practice among other things. What is your plan?

    Update 2

    Government bureaucracies are risk averse, they do innovation badly but then again so do megalithic private sector or “not for profit” bureaucracies. Improving the current situation is not that difficult, but cocking up a lot of people’s lives is even easier 😉


  6. Pingback: “IGCSE qualification forbidden is!” | e=mc2andallthat

  7. Pingback: Standards In English Schools Part I: The introduction of the National Curriculum and GCSEs | Dominic Cummings's Blog

  8. The assumption that boards/exams that are not regulated by Ofqual will inevitably produce better qualifications does not hold up, Dominic.

    Have you ever looked at the unregulated “International A Level” produced by Cambridge? It’s the big brother of their iGCSE, and if you compare with A Levels, you’ll see they appear to be (at least in History) narrower and less demanding than the bona fide A Levels offered by any of the English boards.


  9. DS – this is my second reply, I deleted the first because I thought you were commenting on a different blog.

    I do not think exams produced outside the regulatory system will ‘inevitably’ be better. I do think that we need some experiments with such exams though given a) we have an existence proof that the approach can work and b) the current system is bad.

    I have been told different things re CI A Levels from experts in different subjects. It would be a surprise if Singapore used an inferior version of Cambridge Assessment’s maths or science A Levels – ie. if the international version is worse than the domestic version (OCR) and Singapore uses the former, I would be surprised (but I do not know the answer).

    Best wishes


  10. I will soon take up my first teaching post – English – at a decent public school. I recently looked back at their exam results and discovered that when they switched from GCSE English Language to IGCSE English Language the results leapt from an average of 65% A*/A over the previous five years to over 90% A*/A. Since then, this level has been maintained. I asked various faculty members about the increase and they told me that they believed the IGCSE was ‘easier’. This flies in the face of everything I had previously read on the subject of IGCSEs. Unfortunately, I don’t have any recent experience of the qualifications so I can’t make a good judgement either way.




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