On the Federal Government’s draft Vocational Training Qualification Modernisation Act


Resolution by the 143rd Senate of the German Rectors´ Conference

The Senate of the HRK reacts with astonishment to the Federal Government’s draft Vocational Education Modernisation Act (BBiMoG).

The draft directly enshrines in the BBiG the three vocational training levels already developed in the regulatory practice of the Federal Government, and recommended by the Standing Committee of the Federal Institute for Vocational Education and Training (BIBB). Upon a qualification being recognised across Germany by legislative decree under the BBiG or the Trade and Crafts Code (HwO), these levels are to be assigned the uniform, autonomous  names  “Certified Vocational Specialist,” Bachelor Professional” and “Master Professional”.

The Senate of the German Rectors’ Conference as the representative of 268 universities across the entire country, emphatically opposes these  names modelled after higher education qualifications for the reasons outlined below. The Senate calls for the proposed  names to be replaced by authentic vocational education terms that do justice to the tradition and autonomy of this important educational sector. The Bundesrat has likewise addressed a corresponding request to Parliament.

1.    As long ago as 2016, the HRK and social partners affirmed the objective of making the German qualification system more transparent and supporting quality assurance in relation to the German Qualifications Framework[1]. They jointly described the respective autonomous profiles of vocational  training qualifications and higher education, in order to clearly emphasis the equal value of the education sectors. The draft law runs counter to that objective.

2.    The  names of qualifications must be transparent and unambiguous. In the proposed amendment, however, completely different educational pathways are given almost identical  names. This creates obfuscation, because the unambiguous assignment of a qualification title to the academic or vocational education sector is essential for both sectors. Furthermore, the draft law also creates confusion in vocational orientation for young people, and in job advertisements and staff recruitment by businesses.

3.    The introduction of these  names for qualifications will infringe upon the distribution of powers in the federal system of the Federal Republic, because the Bachelor and Master  degrees constitute higher education qualification titles that fall within the power of the federal states. A legal opinion obtained by the Standing Conference of the Ministers of Education and Cultural Affairs of the Länder in the Federal Republic of Germany, emphatically reaches the same conclusion.

4.    It would accord with the law and serve more purpose to develop a proprietary and unmistakeable nomenclature for vocational training qualifications. In fact, changing the designations of vocational training levels to “Bachelor Professional” or “Master Professional” in no way results in an upgrading of vocational training compared with university qualifications. The opposite effect is more likely to be the case. Modelling the names after the higher education sector does not take account of the practical relevance of vocational education, weakens established brands such as Meister [Master] or Fachwirt [Business Management Specialist] and suggests to students interested in transferring that vocational training qualification is a type of “catch-all” or “substitute”.

5.    Aiming to reduce the inequality between the educational pathways by deliberately blurring the difference between higher education and vocational training qualification is the wrong approach. Neither does it do any service to vocational education, because it does not adequately recognise the practical relevance and the development of professional competences in vocationaltraining qualification. Instead, they are hidden behind the guise of an academic approach.

6.    The consequence of the draft legislation would be that in the European context, in particular, misunderstandings would constantly arise to the detriment of graduates and businesses, given that Bachelor and Master are quite clearly seen as higher education qualifications and are exclusively awarded by universities across Europe.

7.    Above all, however, the draft law that has been tabled endangers the objectives of the Bologna Process that have already been achieved, and thereby one of the most important European reform projects of recent decades jointly supported by the Federal Government, the federal states and the universities.

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[1] "DQR muss Transparenzinstrument bleiben." [GQF must remain an instrument of transparency] Appendix to 2016 position paper by BDA, DIHK, ZDH, DGB and HRK www.dqr.de/media/content/DQR_Positionspapier_BDA_DIHK_ZDH_DGB_HRK_3_2016.pdf (available only in German)