Cymraeg
NEWS

Published:

14.08.26

Our updated position statement on artificial intelligence

We are continuing to consider the impact of AI models on the qualification system in Wales.

There are four sections in this statement:

  1. The context in which we are considering AI.
  2. The delivery and assessment of existing qualifications.
  3. AI technologies in qualifications in the future.
  4. Our next steps.

1. The context in which we are considering AI

Qualifications Wales is the independent regulator of non-degree qualifications in Wales. We work to achieve two principal aims:

  • ensuring that qualifications, and the qualification system, in Wales meet the reasonable needs of learners
  • promoting public confidence in qualifications, and the Welsh qualification system

Access to generative AI has broadened widely since its emergence in autumn 2022, and there has been sustained interest in its role in learning and qualifications. Stakeholders have also been considering whether other forms of AI could play a role in the qualification system. The capabilities of AI models continue to grow, and mean that they can be used for different purposes, such as generating text and visuals in response to user criteria, or processing large amounts of data to inform predictions and language translations. 

While the applications of AI are wide ranging, the outputs created by AI models are not always reliable. The Welsh Government’s AI Plan for Wales recognises that AI models differ in their levels of adaptivity and autonomy, and use inferences to generate outputs (such as content, recommendations or decisions). As such, outputs from AI need to be monitored to ensure their quality. The UK Government’s AI Playbook identifies some limitations of AI models – bias, data quality, accuracy, transparency and explainability, and cost and sustainability – which can inform monitoring approaches. Given these limitations of AI, care needs to be taken before deciding whether AI models should be used in qualifications and assessments.  

As we consider the role of AI in qualifications, we will consider how this supports the achievement of our principal aims. We will also have a duty to carry out sustainable development, as a public body subject to the Well-being of Future Generations (Wales) Act 2015. Our well-being objectives, through to 2035, are to: 

  • shape qualifications that prepare and support learners in life, learning and work, and promote equality of opportunity
  • develop an agile qualification system for Wales that responds to socioeconomic changes, meeting learners’ needs whilst protecting the value of the qualifications they receive
  • operate as a forward-thinking, high-performing and inclusive organisation that delivers for the people of Wales

The emergence of AI models and their ongoing advances bring both opportunities and challenges to the qualification system. We are positive about the potential benefits that AI models could offer, and recognise that they could play a role in the achievement of our well-being objectives. We also see that these models present challenges to how learners are assessed fairly, and we want to ensure that the integrity of qualifications is protected.

In considering the impact of the wide availability of AI models, we have identified four broad areas which present potential opportunities and challenges:

  • the knowledge, skills and experiences contained within qualifications, and how these are kept up to date
  • the use of AI in learning and teaching 
  • where and how candidates take their assessments
  • assessment and awarding processes

2. The delivery and assessment of existing qualifications

We take steps to monitor impacts of the availability of AI models on the delivery and assessment of existing qualifications by awarding bodies and learning providers. We liaise with the Welsh Government, and other qualifications regulators across the UK, which allows us to share learning and developments which are relevant to qualifications offered in different places.  We also use monitoring and compliance activities to gain an understanding of how awarding bodies are managing potential risks associated with AI models.

We have supported the work of the Joint Council for Qualifications (JCQ), which has developed and refined guidance for teachers and assessors on the appropriate use of AI in non-examination assessments. Unlike examinations, which are usually taken under highly controlled conditions which do not permit the use of the internet, non-examination assessments typically offer greater levels of flexibility. This means that further planning and consideration may be required to ensure the fairness of non-examination assessments. JCQ’s guidance supports centres to do this, including by covering: 

  • examples of AI misuse
  • steps for preventing and identifying misuse
  • marking assessments where AI has been used

We engage frequently with learning providers, including through the Jisc Wales AI Working Group, to maintain our understanding of how centres and learners are using AI in teaching and learning. We have also seen examples of the AI policies and training that centres are developing and implementing, and useful guidance for learners and for staff in further education settings.

We commissioned a research study, part of which explored stakeholders’ views on the risks and opportunities associated with AI and qualifications, which we published in April 2025. The study found that stakeholders sense potential opportunities for AI to enhance assessments and improve efficiency, make aspects of qualification delivery more efficient and for including AI-related content into either a new dedicated qualification or through updating content in existing ones. Stakeholders also noted the importance of human checks of content or judgements made by AI, and of factors involved in using AI which link to the maintenance of trust and confidence in qualifications, These findings form part of an evidence base that informs our policy development and regulatory approach.

Our continuing engagement with awarding bodies has indicated that many are giving active consideration to how AI technologies can be used in their delivery of qualifications. We are also aware that Ofqual has provided guidance and clarification on specific uses of AI against its conditions, such as confirming that using AI models may not be used as a sole marker of learners’ assessment evidence. Recognised awarding bodies in Wales have a legal requirement to comply with our Standard Conditions of Recognition, and we consider AI technologies to be a relevant aspect of compliance against these conditions. While we encourage awarding bodies to innovate when they can, some specific applications of AI technologies are currently likely to lead to non-compliance with our conditions, such as AI models being used:

  • to develop assessments without human review
  • as the sole method of remotely invigilating assessments
  • to fulfil the role of an Assessor (defined on page 68 of our Standard Conditions of Recognition)

3. AI technologies in qualifications in the future

We are engaging widely to understand the opportunities of AI technologies for qualifications in the future. Our discussions with learning providers have shown that some learners and practitioners are currently using AI tools for a wide variety of purposes, such as for accessibility purposes, translation and generating new ideas for tasks in lessons. Centres have told us that promoting a broad understanding of how AI tools can be used appropriately and effectively amongst their staff and learners is becoming increasingly important because of the opportunities for enhancing learning and professional practices.

Our discussions with learning providers have also included ways in which the content of qualifications may include relevant AI technologies in the future:

New dimensions to existing areas of study: Qualifications in computing, digital, engineering and other areas which are highly technologised may see additional areas of study, relating to AI, form part of their corpus in the future, providing further breadth or opportunities for specialisation. 

New disciplines which relate to new or emerging occupational roles: Many qualifications, often taken by work-based learners, relate to defined occupational roles, which are sometimes based on recognised national standards. These qualifications often allow learners to demonstrate their competence in a specific occupational role. As AI practices develop and become embedded, qualifications may emerge, perhaps in roles relating to the design, implementation and maintenance of AI-enabled systems. 

Reflecting updated practices and ways of working: The use of AI technologies may influence and shape professional and disciplinary practices in a wide range of subjects and domains. Over time, these may be reflected in the content of qualifications as awarding bodies ensure they remain valid for learners taking them. 

We are also engaging with software developers and digital solutions organisations to better understand the ways in which AI tools are being developed and trialled in the context of educational assessment. In doing so, we are considering whether such applications could benefit learners, and whether they could be applied in ways which would be predictable, dependable and explainable.

4. Our next steps

  1. We are developing a five-year digital assessment plan, which will include how we will support positive, responsible uses of AI within the qualification system in Wales.

  2. We are developing our Regulatory Strategy 2027-2035, which sets out our vision for a qualification system in Wales that is trusted, fair, agile and inclusive. A key priority of the strategy is innovation, through which we will support responsible, evidence-based innovation, including through the use of AI, while safeguarding standards, fairness and public confidence.

  3. We will continue to monitor how AI is being used within schools and further education institutions, the risks and opportunities presented by relevant software developments, and for increases in AI-related malpractice.
     
  4. We will continue to engage closely with Welsh Government, our partners within the education system in Wales and other qualifications regulators on the use of AI in qualifications and assessment.