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Exam Update - Latest Guidance

on Monday, 26 April 2021.

Since our last blog, the 'JCQ Guidance on the determination of grades for A/AS Levels and GCSEs Summer 2021' has been published, giving some much anticipated detail of how schools will need to approach teacher-assessed grades for AS/A Levels and GCSEs.

We strongly recommend that key staff ensure that they are familiar with this document, as well as the Ofqual guidance Information for heads of centre, heads of department and teachers on the submission of teacher assessed grades, and the supplementary advice and materials which individual exam boards are producing.

We summarise below the key provisions and set out recommended actions from a legal, compliance and risk management perspective.

Centre Policy

All centres are required to have a Centre Policy for teacher-assessed grades (TAGs). Draft policies must be produced and submitted to JCQ for approval along with a summary form by Friday 30 April.

The policy must provide a framework for grades to be assessed in compliance with this year's arrangements and, in particular, JCQ says that they must:

  • outline the roles and responsibilities of individuals in the centre
  • detail what training and support will be provided to centre staff involved with the process, including any training around bias and objectivity in assessment and grading decisions
  • confirm the approach to be taken when determining TAGs, including consideration of evidence and how that evidence informs students’ grades
  • detail the internal quality assurance processes that are in place
  • detail any provision for Private Candidates, if applicable.

JCQ has provided a template policy which can be adopted wholesale or adapted as needed. We recommend its use on the basis that it is comprehensive and sector-approved, albeit that it is imperative that you ensure that it is compatible with your school's operation, including the school's proposals for the management of parent and pupil expectations and relationships with them and compliance with the school's broader statutory duties, including those under the Equality Act 2010 and Data Protection Act 2018.

Evidence Base

Key points of note from the guidance include:

  • Assessments must reflect the standard at which a pupil is performing, not their potential.
  • Evidence should be drawn from the course of study, not a pupil's broader academic record.
  • Schools should consider the sources of evidence available and the quality of that evidence, taking account of factors such as:
    • how recently the evidence was produced
    • the breadth and depth of coverage of the relevant specification
    • the conditions in which the relevant work or assessment was completed.
  • It is expected that the evidence base used will be consistent on a subject-by-subject basis where possible, although exceptions can and should be made where evidence is affected by exceptional circumstances or where access arrangements or reasonable adjustments have not been applied (in cases of pupils with SEND).
  • Schools must inform pupils of the evidence upon which grades will be assessed, although they are not required to inform them of the TAGs themselves (in England at least). Schools should consider whether and when disclosure of TAGs may be appropriate.

Objectivity in Grading

Ofqual has revised and reissued its guidance from last year on taking an objective approach to grading. This guidance seeks to highlight the scope for bias to impact judgements, so that, through awareness, teachers are supported to make objective decisions. It is recommended, as a minimum, that all those involved in the TAG process read this guidance in advance of assessment and that schools record that they have done so. Exam boards are likely to scrutinize this aspect of TAGs in their own quality assurance checks and clear and accessible records of relevant training for staff will ensure your school is well placed to engage with exam boards, as well parents and pupils.

Quality Assurance

The arrangements for quality assurance this year are more stringent than last.

The Centre Policy is a key part of ensuring consistency of approach and of standards. Internal standardisation is also key. As with last year's arrangements, grades must be considered by at least two subject teachers, one of whom is the department head/subject lead. Centres are also encouraged to consider historic performance data to check that they are meeting the general requirement that it should be no easier or harder this year to attain a particular grade. The guidance could be interpreted as suggesting that historic data should not be considered until after the initial assessments have taken place. Final grades submitted must reflect the evidence of each student's performance and where there are the greatest disparities between assessed grades and historic results, external quality assurance by exam boards is more likely, so it will be important to be able to justify each and every TAG. This should be done on the basis of the evidence and schools should record their review of TAGs against historic data, and the school's reasons for retaining or reviewing preliminary TAGs carefully.

Exam boards are themselves offering a number of resources, including assessment materials, training, mark schemes and grade descriptors, to assist schools with robust data points and quality assurance processes. The assessment materials are again said to be optional, but the thrust of the JCQ guidance suggests that grade descriptors are an essential tool to ensure accurate judgements and a consistent approach to grading and we would recommend their use.

Record Keeping

This year, schools must retain all of the evidence on which a student’s grade is based, including copies of the student’s work and mark records, at least until the appeal window closes. We would suggest that these are retained for a longer period given the risk of complaints, claims or malpractice investigations.

Schools should also keep records of any discussions with students - and we would suggest parents - around the evidence on which grades will be based to support quality assurance and appeal.


As with last year, schools must ensure that they follow the guidance in assessing grades. They should not reveal TAGs to parents or pupils prior to the publication of results. Failure to do so can constitute malpractice and could result in sanctions against staff and schools. This year, schools have been asked to report instances where parents and pupils have sought to influence grades, which they may do, for example, by seeking a differentiated approach to performance evidence, without legitimate reasons. We think this may help to manage inappropriate challenges and suggest that this requirement is included in communications with stakeholders and centre policies.


This year, every pupil will have a right of appeal to the exam board, where professional judgements can be reviewed.

Details as to how that process will work are not yet clear, but Ofqual has now published its consultation document on the appeals process which can be accessed here. We will update you when those arrangements have been published.

Whilst the arrangements for appeals are different from last year, there remains scope for parental complaints and subject access requests  relating to grading, and we would recommend that you plan for adequate resource to respond to appeals and related procedures over the summer.

We are running an exams webinar for independent schools on 17 June 2021 to help your planning process. Register your interest by contacting our Events team.

In the meantime, if you have any questions about any of the issues raised in this article, please contact James Garside in our Regulatory Compliance team on 07468 698937, or complete the form below.

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