Swedish Council for Universities and Higher Education (UHR)

Swedish Council for Universities and Higher Education (UHR)

Consultation response UHR Proposal for regulations amending the Swedish Council for Universities' regulations (2015:3) on the higher education entrance examination

SFS believes that the proposed changes are more extensive than necessary. At present, the regulations are the only publicly available document that describes how the higher education entrance examination is to be implemented. The proposal to delete large parts that describe the implementation makes it more difficult for test takers and other stakeholders to know what to expect. Transparency and legal certainty are reduced, which the impact assessment has not taken into account. SFS sees a risk that the proposal opens up for more changes in implementation between different test occasions without such changes needing to be anchored with stakeholders. SFS proposes that only the necessary changes to the regulations be implemented and that UHR refrain from implementing the additional proposed amendments that involve a major rework.