ALL response to DfE GCSE MFL Proposals 2021

ALL full response to DfE GCSE MFL subject content proposals – FINAL

ALL full response to GCSE MFL subject content proposals

The Association for Language Learning (ALL) has as its raison d’être the encouragement and promotion of learning languages, and the development in those learning a language of a broader world view or Weltanschauung embracing an understanding of and respect for other cultures.

As such, our members welcome proposals or initiatives to increase the take-up of pupils learning languages. However, in the context of the current review of GCSE content, many members are concerned that the proposals, although well-intentioned, will have the opposite effect and lead to a lowering of standards and fewer pupils choosing to study GCSE MFL. This response comments on the proposals as put forward by the DfE and consciously is not putting forward alternative proposals, because ALL believes strongly that the whole consultation should be halted and a wide discussion held with the language community and stakeholders.  This would be the time for other proposals to be made and carefully considered.

ALL is a broad church and our language teacher members have a spectrum of views and approaches. ALL has worked hard to raise awareness and understanding of the Content Review process and recommendations in the context of what would be the most radical change to MFL teaching and assessment since the introduction of GCSEs back in 1988.

Gauging the views of members

Because language teachers in schools are currently under exceptional pressure of work, due not least to this year’s examination arrangements, there was a risk that many would not have been alerted to the extent of the proposed changes. We therefore took the step of holding a well-attended public webinar on 29th March to outline the proposals in detail, and to examine and explore their implications. We collated and published online the key points raised in writing in the Chat.

Once schools had returned from the Spring Break, and in order to gauge views on the Subject Content review and its outcomes, we held a second webinar, for ALL members, where those attending were able to submit responses electronically in real-time to questions formulated in line with the key points raised previously, and the response number totals were displayed for all to see. Views and questions contributed via the Chat were again collated and published, and all the information relating to the webinars is freely available on the ALL London website:

This information was widely advertised to all ALL members through ALLnet, our weekly e-newsletter, and other channels, and the further responses have been very much in line with the views expressed in the webinars, which are included below in our detailed response.  We can therefore be confident that the views we are expressing are representative.

Concerns regarding the DfE Consultation process

There is concern around timing of this consultation process; we fear that many teachers and senior leaders were, and still are, unaware of the extent of these major proposed changes. Ironically, the consultation ends on May 19th, around the time when teachers complete their work on the exams process, when they would have some time to consider wider issues.

There is also concern that many of the questions are predicated on the introduction of a defined list which is the same for productive and receptive skills, and that the questions are limiting and leading. The DfE consultation does not have any questions regarding equalities impact (unlike Ofqual), so there is no opportunity to highlight the restrictive and potentially discriminatory nature of the proposals.

Overall response

A very high proportion of those polled at our webinar rejected the core proposal which is to replace a context / topic / theme-based communicative approach with a vocabulary list constructed in a tightly defined way from general purpose corpora.

This rejection was for many reasons, including:


Communication is a core reason for learning a language

Communication is of course central to the principles of the National Curriculum for MFL, and to reflect that, from the outset of the GCSE MFL in 1988, there has been a focus on communication as a key purpose and access to a wide-ranging, relevant vocabulary; that communication takes place in a context where it makes sense, and encompasses work in the areas of Listening, Speaking, Reading and Writing. All of this, it is suggested, would be replaced by a focus on phonics, a restrictive vocabulary list and an extensive list of grammar.

Cultural context is important

Although culture is mentioned in the aims of the new subject content, in practice, the removal of the requirement to have a theme of culture, and of the requirement to have authentic resources in the exam, means that there is no imperative for teachers to cover this vital area. An important point is that currently there is a requirement to have a cultural context, while the cultural content itself is not examined; in our webinar there was support for maintaining the principle of not testing cultural content, whilst there was strong rejection of removing the requirement to have a cultural context. Unfortunately, the DfE question on this (Q.22) conflates these two completely separate points.

Moreover, at this crucial time in our history, post-Brexit and in a period of unprecedented global migration, language learning has a significant role to play in the apprenticeship of our young people as global citizens. Fostering the practices of understanding and appreciating differences, and of developing intercultural competence, is at the heart of language teaching. We are concerned that this seems to have been omitted from the proposals.

Investment in current approach both in resources and teacher time

The current GCSE has only been examined twice in 2018 and 2019 with the disruption caused by the pandemic preventing this in both 2020 and 2021. Much has been invested by teachers in preparing resources and schemes of work, and by schools in purchasing textbooks and digital resources, and in training for teachers. Unlike other previous changes where there may have been significant overlap, the proposed switch to a totally different approach would mean jettisoning all of this effort and quality material.

Restrictive and anomalous word list arising from inappropriate corpora

The permissible corpora are general purpose compilations including financial, political and industrial contexts which are not appropriate for a language examination intended for all 16-year-olds. The key issue we return to is that of motivation and recruitment of students into KS4 language study and the EBacc route; members have alerted us to anomalies in the proposed word-lists which would limit the potential of planning student-focussed content, e.g. in the theme of sport where, in French, only wrestling and fishing are included. The omission of aspects of communication, as well as of culture in its broadest sense, again reduces scope for generating the extrinsic interest of teenagers.

With reference to the Equalities issue mentioned above, it is very concerning that the corpora are very Western-centric, so that French and Christian are included but African and Muslim are not. This is especially serious in the light of current political developments in the field of social justice.

Aspects of the proposals welcomed

Some aspects, particularly in relation to the assessments, were widely welcomed: the rubrics and comprehension questions in English and the slowing to a moderate pace proposed for the listening test.

With reference to specific questions in the DfE consultation

Question 10

ALL does not agree with the requirement that 90% of words must be taken from the top 2000 most frequently occurring words in the most widely spoken standard forms of the language.

All of these questions 10 to 14 (apart from 14.2) together are predicated on the implementation of the core DfE proposal to replace a theme-based approach by a high frequency general purpose corpora approach, an approach ALL strongly rejects.

Firstly, there are mixed views about having a defined word list at all, varying across the four skills.

Secondly, there was a strong rejection (over 90%) of the proposal to base it on the criterion in the question.

When offered a multiple-choice question about other options for compiling a word list, the most popular was a 50:50 mix of high frequency words and a set specified by the exam boards in keeping with retaining themes (see Q.15)

  • from highest frequency occurrences in a corpus relevant to 16-year-old (53%)
  • from themes specified by DfE or by exam boards (43%)
  • 50% from the highest frequency list with 50% specified to match themes (69%)

Question 11

ALL does not agree with the requirement for foundation tier pupils to know no more than 1200 words and higher tier to know no more than 1700 words.  See response to Q.10.

Question 12

ALL does not agree that the vocabulary lists proposed for GCSE should set out all the content required for GCSE.  See response to Q.10.

Question 13

ALL does not agree that cognate words should be included and counted in the defined vocabulary in the proposed way. See response to Q.10.

Question 14.1

ALL does not agree that no more than 2% of words in any given higher tier text that fall outside the vocabulary list should be in a glossary. See response to Q.10

Question 14.2

ALL agrees that proper nouns such as cities or countries, not listed in the most frequent 2000 words and not deemed easily understood should be included in an adjacent glossary.  This makes it more valid rather than presupposing geographical knowledge

Question 15

ALL is very concerned about the removal of the current overarching themes and specific topics in the revised subject content.

There was very strong rejection of this proposal (over 90%), and linked with this a very strong support that there should be an agreement between exam boards for a common set of themes so as to promote collaboration, comparison of standards, transferability of textbooks, etc., noting that without this the exams were unlikely to be valid and reliable.

Question 16

ALL strongly disagrees with the principle of a high frequency vocabulary list defining the content for the revised MFL GCSE.  See answer to Q.15

Question 17

ALL strongly agrees (over 90% support) that where questions are designed to test comprehension of written and spoken texts in the assessed language, they will be constructed in English. Removing mixing skills in this way will remove the “double penalty” which invalidates an assessment – i.e. if target language is used to set a question (requiring reading) this results in a mixed skill exercise where failure to perform one skill leads to failure to be able to show what you know, understand and can do in the other skill.

Question 18

ALL agrees with the proposal that all the rubrics will be in English. See answer to Q.17.

Question 19

ALL disagrees with the requirement for pupils to read aloud short sentences in the written form of the language and demonstrate understanding of them. These assessment types are then forcing mixed skill testing (leading to potential ‘double penalty’ affecting the validity of the test) and in turn that is forcing Ofqual to move to two mixed skill assessment objectives rather than the 4 separate skills. (All skills can be authentically tested as separate skills. While mixed skills may arise naturally in the classroom, it is not a valid and fair way to test pupils in a high stakes GCSE examination.)

ALL is concerned that the DfE, which is responsible for specifying the subject content, has again (as it did in 2015) strayed into specifying the way the content is to be assessed, which should be the remit of Ofqual.

Question 20

ALL disagrees with the requirement that pupils undertake dictation exercises as part of assessment.  See answer to Q.19

Question 21

ALL agrees that where pupils are expected to understand spoken extracts, these extracts will be delivered at a pace which is no faster than moderate pace.

Question 22

ALL disagrees with “whilst students will continue to learn about the culture of the countries where the language is spoken, cultural content will not be specified or tested in the revised subject content?”

Although culture is mentioned in the aims of the new subject content, in practice, the removal of the requirement to have a theme of culture, and of the requirement to have authentic resources in the exam, means that there is no imperative for teachers to cover this vital area.

This is a logically poorly worded question because

(a)   it begins with the premise that students will continue to learn about the culture, and yet that has been removed as a requirement in the subject content (in 2015 it was a required theme)


(b)   it asks ‘will not be specified or tested’ thus combining two separate points.

The last sentence in italics in the DfE document says: “therefore, it is proposed that students will continue not to be marked on their cultural knowledge.”  There is general support for the continuation of the current arrangement where students are not tested on the cultural content per se but on the other hand, there was very strong support that a cultural context should be required.  Therefore the ‘No’ is to “not specifying it” as a theme, rather than ‘No’ to the “not testing”. Unfortunately, the wording of the question on this conflates these two completely separate points.

ALL has found widespread support that a cultural context should be specified, that authentic materials should be required and that the themes should include culture.

Question 23

ALL disagrees that the grammar annexes are comprehensive, unambiguous and easy to understand. This is such a broad question that it gives no opportunity to comment in detail on the proposals, in particular the proposal that there be no ‘receptive only’ grammar at either tier.

ALL believes that, as with the vocabulary, there should be “receptive only” elements to reflect the way language is learnt (as evidenced in research e.g. Professor Milton).

Question 24

ALL does not agree that the revised subject content is unambiguous, clear and easy to understand.  The reasons for our rejection are outlined in the introduction to this document.

ALL strongly disagrees (over 90% support) that the DfE should be specifying the pedagogy teachers should be using.

There was overwhelming rejection (over 95%) of the proposals which reduce the emphasis on communication and downgrade the statement of purpose for learning and using a language.


The widely held view was that these proposals would have a very negative impact in many ways and would be damaging to the take-up of GCSE MFL. As a result, we strongly recommend that the consultation should be halted, and wider discussions held to find a way forward which commands the confidence of the MFL community and will benefit the pupils taking GCSE MFL.

Association for Language Learning

17th May 2021