As the European Union continues to develop the European Qualifications Framework (EQF), much can be learned from a comparative study of qualifications systems in other parts of the world. New Zealand, South Africa, and to some extent Australia, have developed standards based qualifications frameworks that incorporate both academic and vocational learning and have made (or are making) significant changes to the certificates that senior secondary students are awarded on leaving high school. These countries have also realigned their curricula by specifying in more detail the learning outcomes expected of students, and their progression across compulsory and post-compulsory schooling, as well as the means by which student learning is monitored, assessed and recognised for certification. At the same time, systems for incorporating both school and post-school academic and vocational qualifications within a common framework have been developed. New Zealand, for example, has implemented a major reform of secondary qualifications since 2002, which incorporates academic and vocational learning within a common certificate (the National Certificate of Educational Achievement), as well as allowing students to gain credits towards a range of vocational certificates. This has attracted interest in the United Kingdom, Australia, South Africa and elsewhere. It is a standards-based system, whereby learners meet explicit ‘standards’ (either achievement standards or unit standards, which are both statements of expected knowledge and behaviour with clear assessment criteria) to gain national qualifications. Similar developments have occurred in South Africa, and in some states of Australia, such as Queensland and South Australia, where considerable changes in the composition of school leaving certificates are underway. The purpose of this paper is to review critical studies, including official reports and research investigations, of the development and efficacy of such systems and frameworks (Philips, 2007). A theoretical analysis is used based on two components, firstly, notions of policy borrowing and how policies are modified within new settings and, secondly, six themes based on a comprehensive analysis of the development of the National Qualifications Framework in New Zealand, to understand these developments in New Zealand, different Australian states, and South Africa. The six themes are concerned with: the purpose and content of post compulsory education and training, desired standards of performance, the options available to students, accountability for the expenditure of public funds, the structure and development of qualifications, and equity or increased participation of all members of society in gaining qualifications (Philips, 1998).

Research findings and policy statements in official documents focusing on the issues embraced by the themes, are used both as a method for illustrating the types of issues that arise when QFs are developed and implemented, and to draw out possible implications for qualifications developments in the EU, such as the EQF. In addition, in order to highlight similarities with recent developments in member countries of the EU, and to explore the relevance to educators in the EU of the comments made about developments in the Southern hemisphere, reference is also made to recent qualifications’ developments in Scotland and England. A number of sources are used to highlight the key issues and to show different solutions that have been proposed or implemented in various countries using qualifications frameworks.

Debates continue to rage about the purpose of standards based systems for recognising students' achievement, and whether it is methodologically possible to define learning outcomes with sufficient clarity to allow consistent assessment by different assessors. However, it is generally accepted by policy makers and many academics that students are entitled to know exactly what they are supposed to achieve, and that users of qualifications require assurance that holders of national qualifications have indeed met the specified criteria of achievement. Overall, it is claimed that understanding the different positions that can be taken in respect of each of the six themes and how ideas about QFs in one part of the world can influence developments in Europe, will assist researchers and officials in the EU in evaluating potential impacts of the EQF, both intended and unintended, while the EQF is being developed and implemented.