IMI Response to the Government's 16-19 Pathways Reform Consultation

Overall position

IMI supports the ambition to simplify the 16–19 qualifications landscape and strengthen parity of esteem for vocational pathways. However, the proposed reforms represent a significant structural change to how technical competence, safety, and progression are developed in the automotive sector.
Automotive is a technically complex, safety-critical industry undergoing rapid transformation driven by electrification, digitalisation, and new service models. Qualification design choices made now, particularly around size, depth, standards, and classification, will directly affect workforce readiness, employer confidence, and the sustainability of the automotive talent pipeline.

IMI’s core position is that clarity and simplicity must not come at the expense of technical depth, safety, or occupational credibility. Without sufficient flexibility and strong employer-led governance, there is a real risk that the reforms weaken progression routes and reduce confidence in vocational qualifications at a critical moment for the sector.

IMI’s key concerns

1. Loss of technical depth and progression routes

•    Fixing V Levels at 360 GLH risks provision that is too broad to develop credible occupational competence in automotive.
•    Removing medium-sized qualifications risks hollowing out established progression routes, particularly for learners not yet ready for a full T Level but requiring more than introductory vocational learning.
•    IMI is concerned that reliance on T Levels alone to provide depth will leave gaps in the system and exclude some learners.

2. Safety and sequencing of learning

•    Automotive roles are increasingly safety-critical, particularly in relation to electric and hybrid vehicles and high-voltage systems.
•    Progression must be sequenced, with robust foundational learning at Level 2 before exposure to advanced systems at Level 3.
•    IMI is concerned that learners could be allowed to progress without sufficient safety competence being secured.

3. Occupational standards and system fit

•    Many current occupational standards do not reflect rapid technological change in automotive.
•    Building new qualifications directly on outdated or unstable standards risks embedding obsolete content and creating delivery challenges.
•    IMI also highlights the lack of alignment between occupational standards used in England and National Occupational Standards (NOS), which risks fragmentation and reduced transferability across the UK.

4. Classification risk for automotive qualifications

•    How automotive V Levels are categorised (e.g. engineering vs transport) will strongly influence content and employer perception.
•    Previous automotive T Levels were classified as engineering, leading to manufacturing-focused provision that did not reflect the automotive aftermarket, where most employment exists.
•    Repeating this error would undermine employer confidence and learner outcomes.

Where IMI needs greater clarity or assurance

IMI is seeking clear answers on a small number of high-impact issues:

Qualification design and standards
o    What “broadly linked” to occupational standards means in practice.
o    Whether standards are fixed for the lifecycle of a qualification and how updates are governed.

Level 2 pathways
o    Clear articulation of the purpose and content of Foundation and Occupational Certificates.
o    How Level 2 provision underpins safe and credible progression to Level 3.

Employer recognition
o    How employers — particularly SMEs — will be supported to understand and trust new qualifications.

Implementation and rollout
o    Confidence that providers, awarding organisations, and employers will be ready for parallel rollout of Level 2 and Level 3 reforms.

What IMI supports

IMI supports reform where it strengthens vocational credibility and progression, including:

•    A simpler, more coherent qualifications landscape, provided flexibility is retained where sector need is evidenced.
•    Broad V Levels that introduce shared foundational skills and support informed progression decisions.
•    A single Foundation Certificate at Level 2, where it includes light-touch sector contextualisation and supports safe progression.
•    Variable-sized Occupational Certificates driven by occupational requirements rather than fixed GLH limits.
•    Applied, practical assessment aligned to real workplace environments.
•    Strong, ongoing employer involvement in qualification design, content, and assessment