Comparative Study of Accreditation Systems
An effort of a common system introduction of skills accreditation

By C. Minos and Dr. T. Karayannis of Eurotechniki K.E.K., Volos, GREECE, 1997

Contribution to the EDUVINET "Living Conditions of EU Citizen" subject


Legal responsibility

The legal responsibility for the accreditation of qualifications presents a very complex situation with several layers of provision in each country. In most of the EC countries the Ministries of Education have final legal responsibility for all awards made within the initial education system, whether the awards are for general education or vocational education and training. For the latter this covers the full-time, school-based awards. In some countries it also covers some awards obtained through apprenticeship or other forms of part-time study or alternance.
Other government ministries may or may not have responsibility for accreditation but this will always be limited to certain types of award.
In addition, an initial distinction must be made between two groups of countries. In the first are those in which responsibility for accreditation has traditionally been centralised under the authority of the Ministry of Education. Other government departments have and do hold legal responsibility for awarding but it is limited. In the second group of countries a system of awarding bodies operates. The awarding bodies are organisations which are either set up and mandated by government but autonomous in their action, or they may be independent organisations (created by Royal Charter in the British case) and with the authority to make educational and training awards of a specific nature or range.

This is clearly the case in Italy, France, Luxembourg,Greece and Spain where the Ministries control the complete process of producing qualifications, both academic and sometimes vocational. In Ireland, however, Ministry of Education control applies to school-based qualifications and some vocational training within the educational system. A process of accreditation by the Ministries of Education of the three Communities (French-speaking, Dutch-speaking and bilingual in Brussels) in Belgium ensures final responsibility at this level. In addition, qualifications obtained in establishments run by the Communities are called "diplomes officiels".

There are four common situations. Firstly, that of Ireland where the Department of Enterprise and Employment has a specific legal responsibility for accreditation in these areas though the course certificate is actually conferred by an awarding body (F.A.S. or NTCB/CERT) under its auspices. In Spain there is a similar situation in that the Ministry of Employment certificates its own courses through INEM.
At the other end of the spectrum is the third group, the United Kingdom, Greece and Italy, where the respective Ministries of Employment take financial responsibility but do not play a direct role in accreditation. In the United Kingdom they have only an advisory role.

Establishing the offer

In most countries within initial education and training provision, it is the Ministry of Education which decides on the diplomas to be offered, as well as the level and specialism. This means that all qualifications obtained through full-time or part-time schooling before the young person is deemed to have left the educational system remain the responsibility of the Ministry of Education. There are few exceptions. One type concerns decentralisation. In Belgiumdecisions are made by the individual Ministeres de l'Enseignement for each of the (linguistic) Communities. In Germany also exclusive autonomy is given to each of the Lander with co-ordination at federal level, though the initiative may also come from organi-sations such as professional associations of teachers, parents' organisations, student bodies, etc. For the dual system, it is the Bundesinstitut fur Berufsbildung (BIBB) which takes the initiative in consultation with the Federal Ministry for Education and Science, the employers' and employees' organisations and other professional bodies.
The other exceptions are the two countries in which there is no central decision making about what diplomas should exist: the United Kingdom and Ireland.
In Ireland, though the Department of Education is the organising authority for all school-based education, several types of awarding body exist. As far as the United Kingdom is concerned there is no overarching ministerial control for VET qualifications.
Greece - At present it is the Ministry of Education which has overall authority. Courses for the caring, tourism and marine sectors are jointly validated by the Ministry of Education and the competent ministry. Under current reforms there will be a process of transfer of responsibility for programmes from the Pedagogical Institutes to the OEEK, the authority responsible for developing the national system of vocational education and training.
The situation in Ireland is more complex, both because autonomous bodies have traditionally organised VET accreditation and also because the whole system is under review with a view to making it more coherent under an overarching system. At present each awarding body defines the objectives, content and assessment for the awards it offers. So for youth training programmes and special programmes for the unemployed, it is the F.A.S., the employment and training body under the Department for Enterprise and Employment. Other sector specific bodies do the same for their own areas. In addition there is the National Council of Education Awards which co-ordinates technician-level training. Though there is a National Council for Curriculum and Assessment, it covers secondary-level courses only and no full vocational qualifications can be obtained through the secondary schools system.

Ministry of Education

The Ministries of Education obviously hold a privileged position in the accreditation process. There is a hierarchy among government departments in this matter. In France, Italy, Luxembourg, Spain, Denmark, Greece, the Netherlands, Portugal andIreland they hold ultimate responsibility for all qualifications obtained through the initial education system. They set up the organisational structure which will determine the offer, define the content, the type of evaluation and its content. Each stage might be carried out solely by the central administration or by one of its agencies or through a structure of representative committees. Above all these Minis-tries assure the homogeneity of the system whereby qualifications are created and developed, as well as the process of evaluation and the results obtained.
The United Kingdom is the outstanding exception. The Department for Education holds only an advisory role in accreditation and plays no direct role in the production of qualifications.

Other ministries

They take a very limited role which is specific to the occupational sector covered. In Ireland, France, Greece, Spain andDenmark various ministries are involved in certificating courses for sectors such as health, agriculture, merchant marine, etc. However in France the certificates obtained have to go through a process of accreditation whereas in Ireland each Ministry has its own accreditation board. In the Netherlands Ministry of Agriculture takes responsibility for this sector.

Permanent committees

A variety of permanent committees exists. The awarding bodies in the United Kingdom have what are usually tripartite committee structures for the different occupations and levels of training covered.

Awarding bodies

The awarding bodies are specific to the United Kingdom and Ireland. They can be either private or state-financed bodies which offer certificates and diplomas for vocational education and training in a range of occupations at varying levels. Their committee structures bring together representatives of government departments as well as those of employers and trade unions. Sector experts and educationalists are also represented. Their awards are nationally recognised.

Social Partners

In Greece current reforms are taking on board the need to associate the social partners in the devising of vocational education and training awards.


In certain highly industrialised countries with an old established craft system, such as Germany, Denmark, Luxembourgand the United Kingdom, apprenticeship was for a long time, or still is, the main way of acquiring a qualification despite differences between these countries. In Ireland in the past, due to the high numbers of people who went to work in the United Kingdom, the British qualifications system, especially for craft occupations, used to be very important. The City and Guilds of London Institute, the main craft awarding body, is still a partner in the Irish accreditation set-up, giving joint awards with the F.A.S. for a limited number of occupations.

While in Germany and Denmark the dual systems of apprenticeship train at skilled worker level, in the United Kingdom and Ireland part-time off-the-job training within the sandwich course structure is common at all levels from I skilled worker to professional.

In both countries employers have been prepared to invest in the future by training young people. In the United Kingdom, however, the effects of the recession of the 1970's on heavy industry (increase in the need for technicians rather than skilled workers in those remaining), and the economic orientations of the 1980's (which on the one hand developed the tertiary sector and on the other introduced legislation reforming training processes), have led to the virtual collapse of craft apprentice-ships, leaving behind a philosophy of adaptable methods of training but few employers willing to carry it out.

It is important to note that both approaches, full-time and apprenticeship, included forms of exclusion which discouraged people from improving their qualifications. Traditional apprenticeship has always been aimed at young people straight out of compulsory education. In the United Kingdom, until the 1980s, regulations covering apprenticeship stipulated an age limit for signing indentures. Few opportunities existed for unskilled or semi-skilled workers to catch up later on in life.

Exceptions to this rule are found in the United Kingdom, the Netherlands and France where from a statutory point of view there is no longer any obligation to follow a course before being assessed. In the United Kingdom, National Vocational Qualifications are outcome-based and developed around defined competences which must be demonstrated (preferably in the workplace). These arrangements are too recent for it to be possible to make any evaluation of their efficiency and effectiveness. In France recent legislation has created Centres de Validation where an individual can be assessed and awarded an officially recognised certificate, or part of one. The relevant legislation also exists in the Netherlands but for the moment has not been broadly implemented.

No apprenticeship routes exist at present in Spain but the idea is under discussion. Greece is in the process of setting up new apprenticeship awards and in Portugal a small number of young people train by this route.

Part-time study without an apprenticeship or trainee contract usually takes the form of evening classes In the United Kingdom, most formal qualifications can be obtained through evening classes. One immediate application of this provision is the evaluation of competences of young people who have left the educational system with no qualifications. Much development work has been done in the United Kingdom to increase access to higher education and to VET qualifications via APL, but the number of people who take awards this way remains small in comparison with standard routes. The Dutch government is currently encouraging such developments especially for the unemployed and for unqualified employees. The Portuguese government is examining the feasibility of setting up an accreditation system to allow accreditation of skills obtained through work, and in Ireland two of the major awarding bodies, F.A.S. and NTCB, are developing such schemes.

Greece: Reforms in progress in Greece are taking on board the need for progression routes and building them into new schemes along with modularization of courses. The new institutes, IEK, will offer modularised courses at European Levels 1, 2 and 3, based on a unified approach to assessment.

Ireland: Clear progression routes have been lacking in the system. Recent proposals by the National Council for Vocational Awards are to create a grid system of attainment making it possible for people to pass both vertically and horizontally. In addition the current reforms of apprenticeship take into account the need for progression. The F.A.S. accreditation framework facilitates progression from one level to the next based on evidence of attainment, and a modularised approach provides for different levels of achievement within a common programme

United Kingdom: The aim of NCVQ is to create a grid system which will allow bridges to be crossed between different qualifications and levels. In fact theoretical possibilities for progression from one level to the next have long been quite good, with clear progression routes offered by the main awarding bodies. In practice though flexibility might be hindered by the course content, e.g. a maths level too low to allow progression from level X to level Y. (This type of blockage is very similar to what happens in France). In addition the academic awards at the end of secondary education continue to dominate higher education entry, with each institution accepting candidates with non-typical or vocationally oriented qualifications (the most common being the BTEC National Diploma) on an individual basis. Modularization of all post-16 courses in Scotland has allowed greatly increased flexibility and opened up new types of progression.


Organising principles

There are four main approaches to the organisation of assessment within the national systems in the 12 Member States:

It is important to note that each of these different approaches each guarantee the outcome, i.e. a nationally accredited and valid diploma or certificate.

France, Italy, Greece and Luxembourg adopt a predominantly centralised approach whereby the examinations for VET awards are designed under the responsibility of the Ministry of Education for the most part, but also by other competent ministries. Examinations are anonymous and teachers never mark the papers of their own students. There is of course some variety within these systems, for example the regionally organised and controlled courses in Italy and the new awards in France accredited by the social partners via the Commissions paritaires de l'emploi for the occupational sector.

The situations in Ireland and the United Kingdom are somewhat different due to the presence of the awarding bodies. Awarding bodies guarantee setting and marking examinations or by overseeing the assessment undertaken at local level. Whereas in Ireland the major accreditation boards are mandated by a government department to assess and confer diploma and awards, in the United Kingdom some of the boards, such as City and Guilds of London Institute and the Royal Society of Arts, are long-established private bodies whose awards nevertheless have full national recognition.

Examinations and examiners

A variety of agencies and bodies determine the content of the assessment in Ireland and the United Kingdom. As NVQs become established in the United Kingdom the role of the Lead Bodies increases in that they can stipulate the assessment methods when establishing standards of competence. For other awards, it is essentially the awarding body which either determines content and methods or moderates college-based examinations. In Ireland there is also a range of awarding bodies de-pending on the type of qualification but each is mandated by the appropriate minis-try to carry out assessment.


Systems of vocational education and training, and therefore the accompanying systems and procedures of accreditation are not static but involve a dynamic series of relationships (as shown in the diagrams in the Introduction), which change and develop according to perspectives and the needs of societies. The 1980s was a period of considerable change in many of the EC countries. Reforms have been initiated from different starting points but have in fact often worked towards similar goals.

These goals can be summarised as follows:

Preoccupations are not dissimilar in some of the Northern European countries. As economic and technological change in the 1980s altered the parameters of the labour market, they have been forced to renew and rethink their VET provision; both the structures and frameworks as well as in curriculum terms. The development of coherent progression routes for technicians and from skilled worker level have been significant in recent French policies. The same preoccupation is behind the fundamental reform processes in the United Kingdom and Ireland, which are reshaping VET provision and accreditation. It is intended that one result will be a better trained workforce and fewer barriers to qualifications for young people and adults alike. The issue in these countries has not just been one of creating new specialisms but also of rationalising and updating existing provision, even eliminating courses which no longer ensure either labour market entry or further training. Though in the Netherlands the basic system has not been modified, there has been a process of rationalisation and extending provision to an adult public. Likewise training provision in Denmark has had to take into account, though more recently, the reality of unemployed adults needing retraining.
Preoccupations are not dissimilar in some of the Northern European countries. As economic and technological change in the 1980s altered the parameters of the labour market, they have been forced to renew and rethink their VET provision; both the structures and frameworks as well as in curriculum terms. The development of coherent progression routes for technicians and from skilled worker level have been significant in recent French policies. The same preoccupation is behind the fundamental reform processes in the United Kingdom and Ireland, which are reshaping VET provision and accreditation. It is intended that one result will be a better trained workforce and fewer barriers to qualifications for young people and adults alike. The issue in these countries has not just been one of creating new specialisms but also of rationalising and updating existing provision, even eliminating courses which no longer ensure either labour market entry or further training. Though in the Netherlands the basic system has not been modified, there has been a process of rationalisation and extending provision to an adult public. Likewise training provision in Denmark has had to take into account, though more recently, the reality of unemployed adults needing retraining.

Working towards the objectives outlined above necessitates a range of measures to suit different needs. Some of them have already been referred to in Chapter 11 and this section pulls together the types of measures enacted to increase participation and qualification levels. Modularization of courses, coherent progression routes, accreditation of prior learning and provision for open-learning are all part of packages designed with these purposes in mind. Some of the developments in these areas will be summarised below. Most of them are at early stages of implementation or, de-pending on the country, still in the developmental stages .
Modularization has several objectives (already discussed above in Chapter 11). It is one outcome of a trend towards mass higher education and can affect curriculum organisation and the accreditation of the individual. Modularised courses facilitate access for working people, allowing them to obtain a qualification at a slower rate than full-time students. Each module is accredited and the qualification is awarded when the full number have been obtained. In the same way increased flexibility allows students to proceed at their own speed without being obliged to complete a fixed number of courses each semester. Equally it allows better horizontal movement in so far as students can take common modules which lead on to several different specialisms.
The British and Irish systems are attempting to set up the necessary infrastructures in colleges and other centres to accredit prior learning. The competences accredited give exemption from courses. Under the NVQ system in the United Kingdom, this accreditation will give NVQ units which can be cumulated to gain the full qualifications. Reform proposals in Spain and Portugal are looking at the feasibility of infrastructures required for similar systems.
In most of the EC countries there is no direct or obligatory link between certificates or diplomas obtained and employment and salary level. Qualifications indicate a certain level and/or type of training undergone. They indicate also that the person has achieved certain knowledge in the theoretical or academic subjects which is sometimes more important than the specific skills acquired. As technological change has affected an increasing number of occupations, as well as the speed and rate of change for some of them, firms are taking on young people for their capacity to adapt and integrate change, rather than for their specific skills. This, as well as high unemployment levels, has led to an inflation in qualifications with firms continually looking for higher levels of qualification to take up posts previously filled by lower skill levels. Combined with the reduction in absolute terms of the numbers of posts available to skilled workers, this leads to an ever increasing pressure on that end of the labour market. It is not surprising, in this context, that in-creasing numbers of young people stay in education and training and the European countries are seeking to develop adequate progression routes from skilled worker level.


Access concerns all the countries in different ways. It means both increased access for adults (employed and unemployed) to courses leading to accredited qualifications and access to initial vocational education and training for young school leavers, especially the under achievers. The access issue, in a broad definition, includes questions of modes of study as well as those concerning progressives routes.
The above cannot of course be a guarantee of good progression for individuals. This is true both in Denmark and the Netherlands where the infrastructure for progression exists. To what extent the bridges established are used will also depend on social and labour market factors as well as the individual's motivation and the possibility of financing one's progression. Barriers to progression may also come from the theoretical content of a lower level course which will not allow the trainee to keep up on the higher level course. This for example has been noted on some British courses in technical areas and is also the case in France for the holders of a baccalaureat professionnel who register on university courses. This obviously raises the issue of bridging courses, or adapting teaching to suit different publics and backgrounds if access and progression are really to be facilitated.
Due to the decentralisation of the Irish and United Kingdom systems, and the relative independence of institutions, parity of esteem has come about in a less formal fashion. Individual colleges or universities have been able to decide by themselves to take students with non-typical qualifications or to set up foundation courses to prepare students.
While pan-European projects are investigating in the field what equivalences can be established, other bilateral agreements are experimenting with joint accreditation. It is not possible to mention here all the pilot schemes and experimental projects under way. One example is the European Social Fund financed project, Euroqualification, a sector-oriented initiative which aims to promote greater coherence and convergence of training programmes, thus laying a basis for mutual or joint recognition. For several years now there have been isolated examples of joint awards such as some British technician awards made by BTEC which can be obtained jointly with, for example, French equivalent awards. These experiments are often limited to particular institutions. On the other hand the French state's accreditation commission has recently officially accredited five Irish awards which are therefore obtained with the joint validation of the French and Irish systems.
The above, while remaining partial or pilot examples, are encouraging and emphasise the need for developing information structures. This comparative analysis has demonstrated the immense complexity of the systems and the variety of issues and preoccupations. Some are common to most of the countries, others concern the specific structuring and (re-) adaptation of a system to a fast moving industrial environment. The social partners will be required to play an increasingly important role in an adapted and adaptable accreditation system, whether through consultation procedures, participation in examinations, accreditation of occupational sector-based awards or in their essential role as providers of sufficient numbers of training places for young and adult trainees.
The issue common to all the European partners is that of providing a sufficiently flexible approach to accreditation of skills and competences to allow as many young and adult learners as possible to benefit from courses and accreditation. Equity, in terms of reducing barriers of age, sex and educational background and taking on board special needs are major keys to flexible and accessible systems. Alongside these social preoccupations is the need to develop an approach to quality assurance adapted to each national system reflecting the role of the different partners in the education and training process.

Full-time and school-based awards


Technikes Epangelmatikes Scholes certificate; OEEK- IEK Apprenticeship Certificate (at the planning stages);


Vocational Preparation and Training 2 and Post Leaving Courses; Joint FAS/City and Guilds Certificates; Teagasc Horticulture Skills course;

United Kingdom

NVQ Level 2/3, SVQ Level 2, GNVQ and gSVQ Level 2 but also still City & Guilds craft certificate, RSA certificates, BTEC First Diploma.

Technician awards

There are two types of award at this level:


Technika Epangelmatika Lykia; EPL - Certificate of Integral Multi- discipline Lyceum; Naftika Lykia (Merchant Navy); OEEK-IEKApprenticeship Certificate (at the planning stages);


National Council for Educational Awards ~NCEAJ National Certificate; FAS Advanced Skills training courses

United Kingdom:

GNVQ and gSVQ Level 3, BTEC National diploma, SCOTVEC National diploma.

Higher technician awards

Work-based awards for initial VET


Meses Technikes Nosileftikes Scholes (Health care certificate); Scholes Touristikon Epangelmaton certificate; OAED-Scholes Mathitias or Kentra Epangelmatikis Katartisis-K.E.K. (Apprenticeship certificate)


National Craft Certificate (3 years); NTCB Craft Certificate; Teagasc Farm Apprentice Certificate;

United Kingdom:

NVQ and SVQ level 2/3, City and Guilds, RSA, BTEC First Certificate.

Technician Awards


currently no award for alternance training at this level but some OEEK/IEK courses in planning stages;


City and Guilds Advanced Craft Certificate;

United Kingdom:

SVQ and NVQ level 3/4, BTEC National Certificates, SCOTVEC National Certificates, City and Guilds Advanced Craft Certificate.

Higher Technician Awards


Anoteres Scholes Emporikou Naftikou (Merchant Navy); Anotera Scholi Touristikon Epangelmaton; other Anotores Scholes (music, theatre, etc.);


awards of certain professional bodies;

United Kingdom:

SVQ and NVQ level 4, BTEC Higher National Certificates, SCOTVEC Higher National Certificates and awards of certain professional bodies.

Awards specially designed for young people who have left the system with no qualifications


no provision at present but some IEK and KEK courses in the planning stages;

Ireland: courses run by FAS (Basic Skills and Pre-Vocational Introductory Level) and Skills Foundation Programme endorsed by City and Guilds and the Department of Education; CERT basic skills and Teagasc courses; Youthreach Foundation Level programmes;

United Kingdom: Youth Training (available to all school-leavers): NVQ and SVQ normally Level 2 awards but Level 1 may also be taken e.g. for special needs trainees or as first step).

Continuing education and training (CET) qualifications

Awards for continuing education and training exist at all levels. There is the same problem of accreditation as above. The presentation has been limited to two categories of award: those which are part of the national system, or accredited to it, and those which though outside the system have value on the labour market.

Certificates given by private training organisations and which have no value other than the prestige of the training firm have not been included if they are outside all procedures of control, verification and validation. It is obvious that training certificates given by prestigious companies will be of use to the individual but cannot be included in a description of the systems and procedures for accreditation in the Member States. In addition, whereas recognised vocational qualifications are intended to ensure the mobility of the individual, private certificates may on the contrary limit the individual to a particular firm or occupational sector.

Though in the private sector continuing education and training awards are rarely linked directly to promotion and salary increases, they are often essential for promotion in the public sector. Presenting a full picture of CET qualifications is further complicated by the practice of "add-on skills", e.g. commercial language training enhances a secretarial quali-fication but does not really change its nature (NB add-on skills should not be confused with joint awards such as a joint secretarial and language course where a comparable level is obtained in both areas. The same is true of word-processing skills, telephone skills, group dynamics and the many other short courses on offer (public or private). These courses are not mentioned (as such) below.

CET qualifications cover several situations which must be kept in mind. There are the additional qualifications and skills which the active population acquire during their working life. They also offer a "second chance" to those who left the initial education and training system either without qualifications, or with a low level of qualification. As such it can, for example, give the possibility of obtaining higher education awards. This latter orientation is not mentioned specifically in the list below.

The distinction between the adult education sector and CET is not always easily made. Though the former is not directly linked to employment, it may well be the means by which a person can return to the labour market. In some countries adult education has played a very important role, e.g. the Volkhochschule in Germany and the Folk High Schools in Denmark. Many possibilities exist for adult education and they cannot all be presented.


  1. OAED short courses, not accredited, leading to Levels 1 and 2.;
  2. private and semi-public centres give non-accredited awards which are recognised for the labour market;


all FAS, CERT/NTCB and Teagasc awards available as well as accredited awards for retraining and skills training; NTCB Supervisory Level or Advanced Skills training; Vocational Training Opportunities Scheme;

United Kingdom

  1. all previously mentioned recognised qualifications can be taken under CET;
  2. some of the awards of the awarding bodies cover CET only;
  3. awards specific to private centres have no formal recognition.


  1. CEDEFOP, Systems and procedures of certification of qualifications in European Community, Comparative Analysis, Thessaloniki 1996
  2. EISENSTADT M., WASON P., Learning. Education and Certification, Athens 1985.
  3. HOPE A., TIMMEL S., Training for Community Workers, A handbook for Community Workers, Book 1, Gweru 1984.
  4. HURLEY L., TREACY D., Models of Youth work, A sociological framework, Dublin 1993.
  5. KARAYANNIS T., MINOS C., Training needs identification of small enterprises, FORCE 1992-94, Volos 1995.
  6. KARAYANNIS T., MINOS C., Open and Distance learning, Volos 1995
  7. LIONARAKIS A., Open and Distance learning. Alternative adults training forms and the Open Universities, IDEKE, Athens 1995-96.
  8. OAED, Hellenic qualifications certification system, Ministry of Labour, Athens 1995.

• • Copyright © IWB e.V. 1996-2000 Webmaster: • •
• • 800 x 600 recommended
• •

|Introduction & Sitemap| |EDUVINET Didactically & Methodically|  
|Full Text Teaching Materials| |EDUTALK Discussion Forum| |Link Collection|
|EDUVINET Authors| |Add your URL & Materials| |EDUVINET Logos|
|Mailinglist| |Guestbook| |Search & Search Engines| |Homepage|