Reasonable adjustments in end-point assessment and apprenticeship assessment
How reasonable adjustments work in apprenticeship assessment and EPA after the 2025 reforms, who decides, what evidence helps and a timeline for providers.
Guide · Law and duties
A practical guide to JCQ exam access arrangements for FE colleges in 2026/27, covering extra time, Forms 8 and 9, normal way of working and new arrivals.
Guide at a glance
Checked against official guidance. Updated 9 October 2026.
Access arrangements are agreed before an exam so that a disabled candidate, or one with a learning difficulty or temporary injury, can show what they know without changing what is assessed. In FE colleges the SENCo or equivalent leads the process under the JCQ Access Arrangements and Reasonable Adjustments regulations, which JCQ says continue to apply in 2026/27, and every arrangement must reflect the learner's normal way of working.
September in an FE college brings a wave of new learners, many resitting GCSE English and maths, many arriving with a school’s access arrangements, and some with none despite clear need. The exam access arrangements process has to work at speed, with evidence that stands up to a JCQ centre inspection. This guide sets out what the current JCQ regulations require, what is different for colleges, and a practical routine for the year.
It summarises the rules. The JCQ document is long and detailed, and it is the authority. Read the relevant sections before you make decisions.
Access arrangements are agreed before an assessment. They let a candidate with special educational needs, a disability or a temporary injury access the assessment and show what they know, without changing the demands of the assessment. The JCQ regulations say the aim is to remove barriers to assessment without compromising its integrity or giving an unfair advantage.
They sit alongside the legal duty. Awarding bodies, as qualifications bodies, must make reasonable adjustments for disabled candidates under section 96 of the Equality Act 2010, and Ofqual requires them to publish their arrangements. The JCQ document, Access Arrangements and Reasonable Adjustments, is how the JCQ member awarding bodies set out those arrangements for general and many vocational qualifications.
Special consideration is different. It is applied after an exam, where illness, injury or another event affected a candidate at the time. The access arrangements glossary entry gives a short definition.
The current document is valid from 1 September 2025 and was updated in March 2026. JCQ states that these regulations continue to apply during the 2026/27 academic year. JCQ also publishes supplementary guidance, infographics and forms, some updated for 2026/27, including a Form 9 for 2026/27 and a guide to evidencing 25% extra time in colleges. Check the JCQ regulations and guidance page at the start of each term for updates.
The SENCo, or an equivalent member of staff within an FE college, leads the process. JCQ is clear that the decisions rest with the centre, not with outside professionals. In practice, most colleges have an access arrangements lead or team within learning support, working with the exams office.
The lead needs to:
It is the support the candidate actually uses in class, in tests and in mock exams. JCQ says arrangements must not suddenly be granted at exam time. If a candidate has never used an arrangement, it is not their normal way of working.
This is the most common gap in colleges, for a simple reason: learners arrive in September and sit some exams in November. The JCQ guidance for colleges is practical about this:
They are the evidence forms for the two main routes.
| Form | Used for | Key requirements |
|---|---|---|
| Form 8 | Learning difficulties, where standardised test scores are used | Part 1 is completed by the centre before the assessment and, as a minimum, includes teacher feedback and evidence of normal way of working. Part 2 is the assessment, carried out by a qualified assessor no earlier than the start of Year 9 |
| Form 9 | Communication, sensory, physical, medical, or social, emotional and mental health needs | A profile of need from the SENCo, supported by appropriate evidence such as specialist or medical evidence, or an EHC plan |
The assessor’s qualification must be evidenced. A Form 8 acts like a passport that can travel with the candidate, but the receiving SENCo must check it is complete, signed and dated.
For learning difficulties, a candidate generally needs two below average standardised scores of 84 or less, in two different areas of speed of working. One score of 84 or less plus one of 85 to 89 can also qualify. Two scores of 85 to 89 need an online referral to the awarding body.
For candidates with communication, sensory, physical, medical or mental health needs, the route is Form 9, without standardised scores.
Other points from the regulations:
Most of the college-specific rules are about reusing school evidence. JCQ’s 2026 guidance for colleges says:
Transition is the best time to collect evidence. Ask schools for access arrangements information as part of school-to-college transition, and use the transition information summary template so the right documents arrive in July, not October.
A simple annual routine:
Fictional example. Tom joins a college in September to resit GCSE maths. His school sends a complete, signed Form 8 with the assessor’s qualification evidence, showing 25% extra time. The college checks it, records Tom’s view that extra time helps but he also struggles to read long questions, and his maths teacher sets two short timed tasks in October. Tom uses extra time in both. The access arrangements lead processes extra time using the school Form 8, and arranges a separate assessment to look at whether a computer reader is appropriate before the summer series.
JCQ rules cover the qualifications its members offer, including GCSEs, A levels, Functional Skills and many vocational qualifications. Other awarding organisations publish their own reasonable adjustments policies, as Ofqual’s Condition G6 requires. Apprenticeship assessment is decided by the assessment organisation; see reasonable adjustments in end-point assessment.
Access arrangements evidence is often health and disability information, which is special category data. The current JCQ document says the candidate personal data consent form and the data protection confirmation form are no longer required, but candidates must be told that their applications are processed through Access arrangements online in line with UK GDPR and the Data Protection Act 2018. Keep evidence where only the people who need it can see it, and keep it only as long as your retention schedule says. See our guide to special category data in education.
Inclusion Studio is learner support software being built for FE colleges and apprenticeship providers in England, currently pre-pilot with a prototype using fictional learners. It is not an exams system and does not process Access arrangements online applications. It is designed to hold the learner support side: what the learner says helps, the support plan they agreed, documents in private storage released only to authorised people, and delivery records that can show support used in class. Access arrangements decisions stay with the SENCo or equivalent under the JCQ regulations.
The JCQ Access Arrangements and Reasonable Adjustments document, valid from 1 September 2025 and updated in March 2026. JCQ states that these regulations continue to apply during the 2026/27 academic year.
The SENCo, or an equivalent member of staff in an FE college, leads the process and makes sure arrangements are appropriate. Decisions rest with the centre, with some arrangements needing awarding body approval through Access arrangements online.
JCQ guidance for colleges says Forms 8 and 9 from schools may be reused for GCSE resits and Level 1 and 2 vocational qualifications if they are complete, signed and dated, with evidence of the assessor's qualification for Form 8. Otherwise new evidence is needed.
Under the learning difficulty route, two below average standardised scores of 84 or less in different areas of speed of working, or one score of 84 or less and one of 85 to 89. Two scores of 85 to 89 need a referral to the awarding body.
Not any more. The current JCQ document says the candidate personal data consent form is no longer required, but candidates must be told that applications are processed through Access arrangements online.
Official guidance changes. Check the source before relying on any detail, and take professional advice for individual cases.
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