Today we submitted our response to the government’s consultation on proposed changes to Progress 8. The consultation proposes changes to the structure of the Progress 8 “buckets” to introduce greater flexibility.

Our response to the government was informed by discussion with our Advisory Group of school and system leaders. While there is recognition that the proposals move in a positive direction, there is also a clear and consistent message: this is only a partial step towards the kind of accountability system schools and learners need.

More flexibility – but still constrained

Government proposals include adjusting the composition of the open and subject-specific slots, adding science as an additional category within the breadth element, and allowing a limited number of technical qualifications to count alongside GCSEs. While the overall framework of eight qualifications remains, these changes are intended to give schools slightly more freedom in how pupils’ subject combinations are constructed within the existing model. These changes particularly affect the “breadth” and “choice” buckets, which are intended to give schools flexibility beyond the core, but remain subject to defined category rules within the model.

Our submission shared that from our Advisory Group there was some hope that the proposed changes introduce some welcome flexibility. Reducing constraints on subject combinations and allowing a wider range of pathways could improve engagement for some pupils and reduce the number being steered into courses that don’t suit them.

However, many of our Advisors feel the reforms do not go far enough. The model still privileges certain subjects and structures, limiting genuine breadth. For example, the continued double weighting of English when both Language and Literature are taken is seen by some as inappropriate, particularly for lower-attaining pupils or those with English as an additional language.

More fundamentally, there are concerns that any “bucketed” structure continues to create subject hierarchies and constrain learner choice. While some supported reform within this framework, others argued for a more radical shift towards a fully flexible system driven by pupil needs and interests.

A missed opportunity on qualifications

One of the strongest themes from our consultation is the need to broaden what counts. While there is support for allowing technical awards into more slots, the proposed cap of two is widely seen as unnecessarily restrictive and undermining parity between academic and technical routes.

Our Advisory Group highlighted that a wide range of rigorous Level 2 qualifications already exist across the arts, digital, technical and personal development domains. These include qualifications such as Arts Award, Cambridge Nationals, and ASDAN’s Certificate of Personal Effectiveness, as well as graded performance qualifications in drama and music. These offer rich, applied learning experiences and often use varied assessment methods such as portfolios, practical tasks and oral exams.

Yet many of these remain marginal within current accountability measures. Our Advisory Group argued that the issue is not a lack of suitable qualifications, but a lack of recognition. There is a strong case for shifting towards a system based on qualification level (such as RQF Level 2) rather than type, to support a genuinely broad and balanced curriculum.

There is also growing interest in recognising enrichment and personal development programmes, such as the Duke of Edinburgh’s Award, which develop leadership, resilience and community engagement.

Concerns about fairness and methodology

A significant area of concern is the proposed move from confidence intervals to percentile-based banding. While intended to simplify the system, many contributors believe this risks making it less fair.

Percentile rankings mean a fixed proportion of schools will always be labelled “below average”, even if all schools improve. This removes important nuance and could disproportionately affect schools serving disadvantaged communities or those prioritising inclusion.

There are worries this could create unintended incentives – for example, discouraging schools from admitting pupils with more complex needs, or encouraging a narrow focus on borderline pupils at the expense of a broader educational experience, including enrichment.

There is strong interest in exploring more contextual approaches to measuring school performance. Models such as the Fairer Schools Index demonstrate how dramatically school rankings can change when pupil background is taken into account, highlighting the importance of context in judging effectiveness.

Supporting all learners without labelling

Views were mixed on proposals for a separate “best-fit” progress measure for pupils with low prior attainment. Some see this as a more useful approach that could better reflect the progress of pupils with complex needs.

Others were more cautious, arguing that it risks labelling and segregating pupils. There was a strong view that a well-designed system should account for differences in background and starting points without needing separate measures.

There was, however, clear agreement that schools should have flexibility for some pupils to study fewer than eight qualifications where appropriate. The challenge is ensuring accountability measures support, rather than distort, these decisions.

A more balanced approach to accountability

Across our consultation, there was a consistent call from our Advisory Group for a more balanced and humane accountability system. Contributors emphasise the need to recognise context, reduce high-stakes pressure, and support schools through collaboration rather than compliance.

There was broad support for providing additional help to schools facing challenges, but a preference for locally driven, peer-led models rather than centralised programmes alone.

A once-in-a-decade opportunity

Overall, our Advisory Group sees this consultation as a significant opportunity. There is strong support for reform, but also a clear warning that incremental changes will not be enough.

To truly support all learners, the system needs to better recognise the full range of qualifications and experiences that matter – including technical learning, creativity, and enrichment. It must also take greater account of context and avoid creating perverse incentives that undermine inclusion.

This is a rare chance to rethink what we value in education. The hope from our Advisory Group is that it is not missed.