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Adult Education and Work Contexts: International Perspectives and Challenges

Comparative Perspectives from the 2017 Würzburg Winter School


Edited By Regina Egetenmeyer and Monica Fedeli

Adult education has deep connections with employment contexts. This volume discusses interrelations within transnational contexts studied during the Würzburg Winter School on Comparative Studies in Adult Education and Lifelong Learning (COMPALL). The book shows that adult education and work contexts are influenced by international and transnational developments. The findings are presented in three chapters: Lifelong Learning Policies Targeting Employment Contexts; Transnational Perspectives on Lifelong Learning Policies; Employment Perspectives and Professionalisation in Adult Education.

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Implementing National Qualifications Frameworks: Difficulties in Cambodia and Germany (Lisa Breitschwerdt / Vicheth Sen)

← 100 | 101 →

Lisa Breitschwerdt & Vicheth Sen

Implementing National Qualifications Frameworks: Difficulties in Cambodia and Germany

Abstract: Drawing on Young’s (2009) framework on difficulties during the implementation of qualifications frameworks, this contribution compares the difficulties of implementation in Cambodia and Germany. The main problem in Germany is translating the framework into practice at the professional level, whereas in Cambodia, implementation is being hampered by fragmentation and competition among the involved ministries and institutions.


Qualifications frameworks have been increasingly adopted by countries throughout the world since the 1980s, rendering it a global phenomenon (Young, 2003). Countries such as the United Kingdom, New Zealand, Australia and South Africa are among the pioneers in designing qualifications frameworks. Largely driven by ‘powerful political and economic forces’ and underpinned at the core by the ‘debates about the nature and purposes of education and training’ (Young, 2003, p. 236), this popularity has intensified in the past several years, with more than 100 countries now considering, developing, or implementing qualifications frameworks (Allais, 2011; UNESCO, 2015).

State governments are interested in having their own qualifications framework because they see them as a tool for making educational institutions ‘more accountable’ and for comparing their education system to those of other countries (Young, 2003, p. 228). Qualifications frameworks have been considered a useful policy instrument to improve the relationships between labour markets and education and training institutions (Allais, 2011). They also provide a mechanism that enables governments to recognise prior learning and to ‘validate non-formal and informal learning’ (Bohlinger, 2012, p. 282). They encourage lifelong learning by functioning as a mechanism to integrate initial and ongoing education and training, higher education, and non-formal and informal learning into a unified system (ibid.). In a nutshell, qualifications frameworks offer several benefits: ‘the modernisation of education and training systems and programmes, the promotion ← 101 | 102 → of labour market mobility and transnational cooperation and the promotion of all forms of lifelong learning’ (Bohlinger, 2012, p. 283).

Although there is a common idea of perspectives and benefits, the realisation of a national qualifications framework cannot be based on a uniform concept. The specificity of every country’s circumstances and parameters plays an important role in this. The authors of this paper expect that these country-specific contextual disparities lead to different problems and challenges when it comes to the question of implementing qualifications frameworks. The paper aims to answer the following question: What difficulties do Cambodia and Germany face during the implementation of their qualifications frameworks? What are similarities and differences? The countries were selected because of their different geographical location and societal structures. This allows for determining whether there are similar difficulties despite different contexts. Both countries face linkage needs to regional qualifications frameworks (EU and ASEAN), and both are currently in the process of its implementation.

Therefore, the paper first outlines the main characteristics of the national qualifications frameworks of Cambodia and Germany and identifies comparative categories concerning difficulties in implementing qualifications frameworks. Afterwards, difficulties in implementing qualifications frameworks in both countries, and the commonalities and differences between the two cases will be analysed. Finally, the paper summarises the different difficulties in implementing qualifications frameworks in both contexts and provides an outlook on further research questions.

Characteristics of national qualifications frameworks in Cambodia and Germany

Cambodian Qualifications Framework

The Cambodian Qualifications Framework was born out of a policy process that aims to promote a highly competitive and economically integrated Association of Southeast Asian Nations (ASEAN). In recognition of the varying developmental states and levels of qualifications frameworks of its member states, ASEAN has its own policies and processes for the mutual recognition of qualifications granted by its member states and other associated member states. The process towards the ASEAN Economic Community in 2015 was accompanied by various policy instruments. The ASEAN Qualifications Reference Framework, for instance, was developed to ‘enable comparisons of qualifications across ASEAN Member States’, ← 102 | 103 → focusing on education and training and lifelong learning (Association of Southeast Asian Nations, 2015, p. 4).

Within this regional context, the Cambodian Qualifications Framework aims to ensure that qualifications within Cambodia and in the region can be compared in terms of equivalence (Royal Government of Cambodia, 2012). The Royal Government of Cambodia considers the Cambodian Qualifications Framework a crucial instrument for the country to standardise its system of education and training, so that its citizens are able to attain qualifications comparable in quality to the regional standard (RGC, 2012). It aims to provide recognition of prior learning and flexible pathways to academic and technical and vocational education and training; promote lifelong learning; encourage the provision of quality education and training relevant to the labour market needs; promote national and international recognition of qualifications attained in Cambodia; and facilitate the regional flow of skilled labour (RGC, 2012).

There are four core elements: levels of qualifications, credit hours, learning outcomes, and study pathways (RGC, 2012, pp. 2–7). There are eight levels of qualifications for technical and vocational education and training; the first four levels lead to a vocational certificate, and technical and vocational certificates 1, 2, and 3, all of which are equivalent to the secondary education standard. For higher education, there are four levels of qualifications. For the Cambodian Qualifications Framework, 15 hours for 1 credit is a measure of the amount of instruction. For teaching activities that involve laboratory work or workshops, 1 credit equals 30 hours. And for fieldwork or internship training activities, 1 credit equals 45 hours.

Learning outcomes are organised into two sets of competence: basic and core competence, both divided into five major areas: (i) knowledge, (ii) cognitive skills, (iii) psychomotor skills, (iv) interpersonal skills and responsibility, and (v) communication, information technology and numerical skills. The five areas of learning outcomes apply to all programmes in technical and vocational education and training. For higher education, only four areas are applicable to all programmes; a fifth area, psychomotor skills, applies to only some programmes. By means of regulations on the accumulation and transfer of credits and the accreditation of prior learning acquired through formal, non-formal, and informal learning, the Cambodian Qualifications Framework provides study pathways that enable individuals to move between technical and vocational education and training and higher education. As of this time of writing, the Cambodian Qualifications Framework has yet to be implemented. ← 103 | 104 →

German Qualifications Framework for Lifelong Learning

In Germany, the development and implementation of a qualifications framework is strongly guided by the European processes and goals, beginning with the Bologna Declaration of 1999 and the Lisbon Strategy of 2000. The main aim of these strategies was to make the European Union a competitive and dynamic economic zone, based on knowledge and including education and training for living and working in this society (European Parliament, 2000, no. 26). The idea was to define the necessary and important areas of knowledge and skills for each educational level to have a quick overview of the workforce and make educational levels comparable across Europe. This was set within the development of the European Qualifications Framework in 2008.

In Germany, two coordination bodies were established in 2007 to generate the German Qualifications Framework. The ‘Federal/State Coordination Group’ (Bund-Länder-Koordinierungsstelle) is composed of government bodies (e.g. ministries); the ‘German Qualifications Framework Working Group’ (Arbeitskreis Deutscher Qualifikationsrahmen, AK DQR) consists of representatives of all relevant areas of society (e.g. education, economic organisations, scientists, and practitioners). The aim of developing a National Qualifications Framework for Germany was to link the German qualification levels to the European levels and take account of the exceptions in the German education system.

According to the recommendation of the EU, Germany developed its framework and linked it to the European Qualifications Framework by the end of 2010, assigned the qualifications, and documented national qualifications and European qualifications levels on national certificates by the end of 2012 (Eckelt, 2016, p. 101). The final framework was officially implemented on 1 May 2013, and since 2014 the process of assigning formal qualifications to the levels of the German Qualifications Framework has been underway. For formal qualifications, an obligatory procedure assignment was introduced, whereas the assignment of non-formal and informal competencies has not taken place yet, but there is a suggestion about the criteria and procedures.

Similar to the European Qualifications Framework, the German Qualifications Framework is structured in eight consecutive levels (starting with level 1 on the bottom) describing the necessary learning outcomes. Levels 5 to 8 are compatible with the German Higher Education Qualifications Framework. Unlike in the European Qualifications Framework, the described outcomes are segmented into four pillars of competence areas, covering ‘professional competence’, subdivided into ‘knowledge’ and ‘skills’, and ‘personal competence’, subdivided into ‘social competence’ and ‘autonomy’ (Arbeitskreis Deutscher Qualifikationsrahmen, ← 104 | 105 → 2011, p. 5). Methodological competence does not appear in the framework as it is considered a part of all other competencies.

In the German Qualifications Framework, the concept of competence encompasses all learning outcomes. With this focus on competencies, especially personal competencies, the framework tries to refer to the characteristics of the German education system, which is particularly based on the term Bildung and the related idea of the possibility of enlightening and developing each person through education. This understanding also becomes visible in the definition of competence in the German Qualifications Framework as ‘the ability and willingness of every individual to use knowledge and skills, and also personal, social and methodological abilities and to act deliberately, individually and socially accountably’ (AK DQR, 2011, p. 4).

Categories for comparison

There are different contextual circumstances for the implementation of National Qualifications Frameworks, which refer to the characteristics of the nation. Nevertheless, it is not unusual for problems to occur when implementing big structural reform projects like a National Qualifications Framework (Young, 2009). In this paper, Young’s (2009) comparative categories are used for the discussion of difficulties in implementing national qualifications frameworks. In his overview of implementation problems, Young (2009) distinguishes between three areas or levels of problems: political, administrative, and technical/professional.

By political difficulties, firstly, Young (2009) refers to the fact that the responsibility for developing and implementing a national qualifications framework involves more than one government department (e.g. ministries or departments of education, labour, and trade). This presents major difficulties for a smooth process of implementing a national qualifications framework, simply because each department has its own agenda. Secondly, administrative difficulties refer to problems that accompany the development of new instruments of structure and regulation (e.g. quality assurance, standard setting, and assessment) in the process of national qualifications framework implementation. The main difficulties at this level concern the uncertainty of responsibilities that these new agencies are to perform and the difficulties for them to recruit staff members with appropriate skills and knowledge to perform the tasks in the implementation process (Young, 2009). Finally, Young (2009) understands technical or professional difficulties as problems concerning the concrete realisation of new activities (e.g. assessment, new language standards, and defined criteria) connected with the focus on learning outcomes. These difficulties arise from the fact that the descriptions ← 105 | 106 → for different levels of learning outcomes and for different qualifications are often jargon-laden and prove to be challenging for non-specialists or people outside of a particular sector to understand and relate to. Also connected to this is the question of what knowledge is and how it is acquired and assessed, which presents another layer of difficulties in implementing a national qualifications framework. Besides offering this classification of difficulties, Young also points out that one overall problem of the system of national qualifications frameworks is that the people who are working in the system increasingly become disconnected from it (Young, 2009, pp. 2917–2918).

Comparison of the difficulties in implementing national qualifications frameworks

The goals and objectives of implementing a national qualifications framework are quite similar in Cambodia and Germany: to simplify and support the transparency of qualifications and make them comparable internationally. It should improve and strengthen the overall perspective of the labour market. Nevertheless, there are minor differences, owing to the countries’ different socio-economic status. In Cambodia, the focus lies on the provision of high-quality education, the connectivity to international standards, and the improvement of access to education and training. As a country emerging from prolonged civil armed conflict, Cambodia’s current state of educational development is still in its initial stage and is confronted with many issues that are not present in countries such as Germany. In contrast, Germany is more focused on topics of improving overall permeability in its education and training system and strengthening the orientation on learning outcomes, including the recognition of non-formal and informal acquired qualifications.

These similarities and differences are also shown in the structure of the national qualifications framework outlined in Table 1. Both qualifications frameworks contain eight levels and are divided into the areas of general, higher, and vocational education, with Cambodia explicitly outlining technical training in their vocational education area. Both countries place the bachelor’s, master’s, and doctoral degree at levels 6, 7, and 8. In Germany, there is no qualification at level 5 (transition between general and higher education), because the general higher education entrance qualification is assigned to level 4. In Cambodia, the higher education system is divided into academic (or higher education) and technical and vocational education and training. Both streams offer the highest degree programme at the doctoral level. ← 106 | 107 →

Table 1: The structure of qualifications frameworks in Cambodia and Germany.


← 107 | 108 →


*Further qualifications will be assigned step by step following the jointly agreed procedure.

Sources: RGC (2012, pp. 3–6); UNESCO Institute for Lifelong Learning (2015, p. 80); Bund-Länder-Koordinierungsstelle (2016); BMBF et. al. 2017, p. 2). ← 108 | 109 →

Although the levels are the same, there are some differences in the definition of categories of learning outcomes. Both the categories of knowledge and skills and the aspects of personal factors are important. But while the Cambodian framework goes deeper into defining the skills needed in a globalised world, such as information technology skills, Germany is more general and focuses on the translation of skills into practice by using the concept of competencies.

As expected in the beginning, a detailed look at the national qualifications frameworks shows some differences. That is why it is not surprising that there are also some major differences when it comes to the question of implementation difficulties. Based on Young’s (2009) categories of difficulties in implementing national qualifications frameworks, the following commonalities and differences can be outlined.

Political difficulties


In the current context of Cambodia’s higher education system, the multiplicity of authorities governing higher education creates major political difficulties that potentially challenge the implementation of the Cambodian Qualifications Framework. Although numerous reform efforts have been made to improve the governance of the system, it continues to be fundamentally fragmented (Chet, 2006; Dy, 2015; Sen, 2013, forthcoming; Sen & Ros, 2013; Un & Sok, 2014). The higher education institutions are under the supervision of a wide range of parent ministries/institutions. According to the 2016 Education Congress Report (MoEYS, 2016), there were 118 higher education institutions located in 19 provinces and the capital; 46 of these were public higher education institutions and 72 private higher education institutions. These higher education institutions were supervised by 15 different parent ministries/institutions. In particular, these supervisory ministries/institutions very often have competing interests and do not necessarily come to common terms, especially in the areas of policies and regulations (Sen, forthcoming). For example, there exists a high degree of competition and a lack of cooperation between two of the main ministries responsible for education and training in Cambodia; namely, the Ministry of Education, Youth, and Sport (MoEYS) and the Ministry of Labour and Vocational Training (MoLVT) (United Nations Development Program, 2011).

Moreover, although the MoEYS is mandated to formulate policies and plans to evaluate the education sector and to improve the quality of education (RGC, 2009), it has the same legal status and jurisdiction as the other supervising ministries/institutions; that is why its authority at inter-ministerial meetings with ← 109 | 110 → other ministries to discuss cross-sectoral issues related to education and training is mainly limited to non-policy discussions (Sen & Ros, 2013). An effort to address this power competition among parent ministries/institutions through the establishment of a national coordination body (the Supreme National Council of Education) proves to be a failed attempt. Although stipulated to be established in the 2007 Education Law (RGC, 2007), a decade later the Supreme National Council of Education has not yet materialized.

Although the Cambodian Qualifications Framework is yet to be implemented, this contextual landscape in relation to the political environment in Cambodia’s current education system presents fundamental difficulties for a successful implementation of the framework. Any implementation of a national qualifications framework will definitely involve inter-ministerial or inter-departmental coordination and collaboration. The current governance structure of Cambodia’s education system does not lay a stable foundation for an effective implementation of the country’s national qualifications framework.


In Germany, the idea of developing a qualifications framework was supported strongly by federal policy. As a consequence, many difficulties in its implementation lay, and still lie, in the administrative process of developing the German Qualifications Framework. The decision to include a huge variety of stakeholders with different interests in the implementation process necessitated many consensus-building discussion sessions between them.

As a consequence, when the German Qualifications Framework was enacted on 22 March 2011, a rough concept of the competence levels and categories was fixed, but the qualifications of the German education system had not yet been assigned to the eight levels. In addition, it was unclear at this time how to include non-formally and informally acquired competencies in the qualifications framework, which was one of the goals. Overall, several compromises were made to reconcile the interests of different actors in the process of enacting the German Qualifications Framework. Sometimes these compromises were hard to understand. For example, the former representative of the Ministry of Education and Research demanded that the competence category ‘self-competence’ be changed to ‘autonomy’, although the task force had worked with the first term for about two years. To make the concept easier to understand for citizens, the term was changed and did no longer conform to the underlying concept of an overall ‘action competence’ (Odenwald, 2012, p. 202). ← 110 | 111 →

Consequently, even though there was the shared political intention to implement a German Qualifications Framework, there were, and still are, many points of discussion, arising not least from the inclusion of so many actors in the process. Especially after the official enactment of the German Qualifications Framework in 2013, further problems and discussions arose concerning its realisation.


Cambodia and Germany face political difficulties at different levels. In both cases, the main difficulty is the clash of competing interests that have to be negotiated. While in Cambodia the final implementation and practical realisation of the Cambodian Qualifications Framework is still prevented by the issues of system fragmentation and communication between the involved ministries and institutions, in Germany, where the German Qualifications Framework has been successfully implemented, this problem arises again in the ongoing development process, preventing the finalisation of the Qualifications Framework. In Cambodia, it is more about the governance structure of the education system in the first step of implementation; in Germany, there is the challenge of including the educational needs of the different parts of a highly divisive education system in the second step of implementation.

Administrative difficulties


Administrative difficulties in implementing the Cambodian Qualifications Framework are another major challenge rooted in the current quality assurance system. If the implementation of the Cambodian Qualifications Framework were to be undertaken under the same structure and regulation of quality assurance, a wide range of administrative difficulties would be imminent, particularly the capacity of the quality assurance body (Sen, 2016, forthcoming; Sen & Ros, 2013). Established in 2003, the Accreditation Committee of Cambodia (ACC) plays a central role in accrediting education programmes offered at higher education institutions, both academic and technical and vocational, across the country (RGC, 2003).

However, the ACC has not moved beyond accrediting the foundation-year programmes at most higher education institutions (Dy, 2015; Un & Sok, 2014; Touch, Mak, & You, 2013), although it was led by qualified individuals. The question of the quality of higher education in Cambodia remains a major issue (Dy, 2015; International Labour Organization and Asian Development Bank, 2015; MoEYS and the World Bank, 2015; Sen, forthcoming; Un & Sok, 2014). This issue ← 111 | 112 → may be attributed to the rapid and uncontrolled expansion of the number of higher education institutions over the past 15 years, which has overwhelmingly exhausted the capacity of the ACC to sufficiently carry out its tasks (Dy, 2015; Sen, forthcoming). In particular, it was and remains challenging to recruit and train assessors with relevant knowledge and expertise (Un & Sok, 2014). Coupled with these challenges is the shortfall of funding (Dy, 2015; Sen, 2013; Sen & Ros, 2013).

It remains to be seen how the new instruments of structure and regulation in relation to quality assurance, standards setting, and assessment for the implementation of the Cambodian Qualifications Framework will be developed. However, lessons from the existing quality assurance mechanism have shown that there are numerous challenges in doing this. There is a need to rethink the organisational structure and approaches at the administrative level in the context of Cambodia.


Eckelt (2016) states that a lot of the problems in the German process of implementation are grounded in the type of administrative procedure chosen, for example the dominance of vocational training and the precarious position of the field of continuing education (Eckelt, 2016, p. 107). In the years after the German Qualifications Framework came into force, the interest groups discussed a lot about the assignment of formal qualifications and have not even reached a partial agreement now. For example, there is continuing discussion and disagreement about the position of general and vocational education in the framework. The general qualification for university entrance should be assigned to level 5, whereas the assignment of occupations varies from level 3 to 5. This means the school leaving examination has a higher value than a vocational training programme, which lasts for three or three and a half years. This was criticised sharply by the trade unions and the economic representatives, resulting in a long gridlock until general school leaving qualifications were finally assigned in March 2017 (Bundesministerium für Bildung und Forschung, 2017). In addition, there were discussions about the formulation of learning outcomes, such as the nature of the scientific problem-solving competence, which was perceived as too vague by the higher education sector as compared to the field of vocational education from the perspective of its representatives (Böllert, 2010, p. 96). Representatives of continuing education in particular currently criticise the previous procedure of assignment, which they say neglects the value of informal education by focussing on formal qualifications first. The idea of a comprehensive understanding of education in which formal, non-formal, and informal education stand side by side equally was so far ignored in this process (ibid, p. 97). ← 112 | 113 →

Next to these problems of assignment and formulation there are difficulties caused by the adoption of foreign models with too little reflection or without creating own models during the implementation process. One example is the establishment of accreditation agencies based on the Anglo-Saxon model, which are responsible for the quality assurance of German study programmes (Immer, 2013, p. 3). Recently, there was a resolution of the Federal Constitutional Court (Bundesverfassungsgericht, 2016) concerning study programs in the state of North Rhine-Westphalia, stating that the process of accreditation conflicts with the right to academic freedom in Germany, as it intervenes directly into the formation and contents of scientific teaching. As a result, legislators have to pass a new law by 31 December 2017 showing that the steps of developing their own structures and rules as part of the fast-paced implementation process must not be neglected by the responsible authorities (ibid., pp. 3–6).


In both cases, the common challenge at this level concerns the uncertainties about the roles and responsibilities of the accreditation agencies. While in Cambodia the existing accreditation agency does not have a good history of having adequate capacity to carry out its tasks, the case of Germany involves the role of accreditation agencies, in particular in the context that these agencies are established based on foreign models without sufficient attention paid to adapting them to the country’s own system. Moreover, in Germany, the administrative procedure adopted for the implementation of the German Qualifications Framework creates tension between higher education and vocational education in terms of assigning certifications. In Cambodia, in contrast, this kind of tension between the Ministry of Education, Youth and Sport, and the Ministry of Labour and Vocational Training is present at the political level; however, it is highly likely that it trickles down to the administrative level when the implementation of the Cambodian Qualifications Framework commences.

Technical or professional difficulties


The main challenge to implementing the Cambodian Qualifications Framework at the technical or professional level involves the fact that Cambodia’s higher education institutions, both academic and technical and vocational, are severely underfunded. In general, Cambodia’s higher education institutions are basically teaching-based institutions and support themselves through tuition fees (Ahrens ← 113 | 114 → & McNamara, 2013; MoEYS & World Bank, 2015; Peou, 2015; Sam & Dahles, 2017). Teaching itself is largely lecture-based and rarely informed by research (MoEYS & World Bank, 2015). While 80 per cent of the revenue for public higher education institutions is privately funded (Ahrens & McNamara, 2013), all private higher education institutions do not receive government funding and rely almost totally on tuition fees (Sam & Dahles, 2017; Sen & Ros, 2013). Government funding for public higher education institutions is mainly to cover the institutions’ basic operational costs (Sen, forthcoming).

The academics at both public and private higher education institutions engage in heavy teaching because there is no funding source for research for them to apply for and engage in research activities (MoEYS & World Bank, 2015). Within this contextual reality, both public and private higher education institutions find it extremely challenging to respond to the new demands of the Cambodian Qualifications Framework, particularly in relation to developing a new language of standards, units, and levels that defines assessment criteria applicable to the learning outcomes of the Cambodian Qualifications Framework. In this context, where lecturing and marking exams is the predominant aspect of higher education instruction, responding to the kinds of assessment required by different levels of learning outcomes in the new Cambodian Qualifications Framework would prove to be a major challenge for the stakeholders concerned at the higher education institution level.

Added to this series of challenges is the fact that research is virtually non-existent at Cambodia’s higher education institutions. So the question related to different types of learning and knowledge acquisition might not even be considered by the actors involved at this level of implementation. Although this may not be necessarily a challenge to implementing the Cambodian Qualifications Framework, the lack of discussion on this issue among the concerned actors may in fact present a cause of concern over the lack of critical evaluation of the outcomes-based qualifications framework.


After enactment, the most challenging step of implementation lies ahead: educational practice. The change of focus from learning contents to learning outcomes requires educators to rethink the practice of teaching and learning. There are no valid statements about the acceptance of the German Qualifications Framework in German educational practice yet.

First surveys and interviews of people involved in the implementation process indicate that the German Qualifications Framework is accepted as an important ← 114 | 115 → instrument that generates opportunities for the modern and international education system (Neß, 2009). There are differences in acceptance between the various areas of education, which are partially justified by the state of assignment of the formal qualifications in the German Qualifications Framework and their relevance to practice. For example, the representatives of school education have reservations because of the continuous assignment of its formal degrees, whereas representatives of vocational education and training are encouraged by the visibility of their field in the far advanced process of assigning degrees (Eckelt, 2016, pp. 364–365). In contrast, estimating the extent to which the German Qualifications Framework is accepted and realised in the field of continuing education, which does not work with formal degrees, is difficult, because a system for the assignment of non-formal and informal competencies does not yet exist. In other cases, providers in the area of continuing education nevertheless are quite interested in using the German Qualifications Framework and started to assign the non-formal qualifications they offer to the different levels (ibid., p. 370). This comparison shows that it is important to include the actors working in the field of education in the further process of implementation (Neß, 2010, p. 37). Furthermore, it is necessary to inform and educate the personnel about the new approach of qualifications frameworks and the implementation of new wordings, concepts, and understandings relating to it (Fuchs, 2011, p. 7).


The two countries face similar difficulties in the sense that the introduction of national qualifications frameworks represents a shift from content-based to outcomes-based learning. This will require rethinking in terms of teaching, learning, and assessment. However, a major challenge for Germany concerns the uncertainties regarding a system of assigning competencies in the areas of general, vocational/technical, and continuing education. On the contrary, while Cambodia may face the same challenge, one important challenge for Cambodia is that the country’s higher education institutions are teaching-intensive institutions and follow a traditional model of assessment, that is, examinations as the primary assessment of learning. Therefore, implementing the new qualifications framework, which requires a move towards a new model of assessment based on learning outcomes, presents a significant challenge. This is particularly so in the Cambodian context, where higher education institutions are severely underfunded by the government. ← 115 | 116 →


It could be shown that there are several challenges in implementing qualifications frameworks, and that Germany and Cambodia face different challenges. There may be many reasons for that. First, the differences can be attributed to the large disparities in the education systems. In Germany, there already is a highly standardised education system with standardised training programmes for teachers, compulsory education until ninth grade, and various fixed pathways for students. The implementation of a standardisation instrument like the qualifications framework can build on these qualities of the Germany education system, which now asks for more international transparency. Furthermore, Germany could gather experiences with standardisation processes when it implemented the Bologna Process and the three cycles of the Higher Education Qualifications Framework relating to it. The Cambodian system, in contrast, although characterised by high centralisation in its educational system at the governmental level, has few nationally standardised structures at the local level, which is one result of prolonged civil armed conflict in recent history. This means the country is facing the challenge of implementing a system of standardisation for its whole education system without having any experience in that regard. This becomes visible in the fragmentation of Cambodia’s governing authorities. Furthermore, the differences can be caused by the structure of management and participating stakeholder groups. Whereas Germany’s educational system is broadly linked to governmental funding and control, Cambodia’s is characterised by stronger private engagement in education, with the government’s role rather focused on passing and implementing laws and quality regulations.

But in addition to the differences, the two countries, although they are very different from each other, also face similar difficulties. By implementing a national qualifications framework, both countries follow the global trend of more standardisation and transparency in qualifications. Their shared goal is to adjust to global needs, as laid down in the respective regional qualifications frameworks, develop their education and training system, and strengthen the labour market. Given their long history of national education systems, influenced by changing political, societal, and cultural circumstances, both countries now face the challenge to reconcile the call for international transparency with the particular needs of their local education system.

Although the overall goal of transparency is widely accepted and the implementation of different national qualifications frameworks is underway, there also has to be further reflection on the importance and influence of this development in general. Especially when looking at the importance of the historically grown ← 116 | 117 → national educational systems, it is important to note that some aspects of the global rise of qualifications frameworks also give reasons for concern regarding the direction this development is taking. Noticeably, the general idea of improved transparency, efficiency, and mobility is linked to the ideas of neoliberalism and human resource management, which focuses on the improvement of qualifications first but not necessarily on human beings themselves. In this context, Lauder (2011) warns against the global orientation taking place in the world of business and employment, which is linked to the increasing development of national qualifications frameworks. Based on key trends in the global economy, like the the reducing of costs of knowledge work, which results from the global rise in the supply of graduates, one may raise ‘fundamental questions about the nature of knowledge and skills’ (Lauder, 2011, p. 213) in general, and national qualifications frameworks in particular. Therefore, a suggestion for further research would be to compare the extent to which qualifications frameworks may be contributing to promoting an individualistic, private consumption of education rather than the dimension of education as a public good.

Implementing a national qualifications framework is not only about fulfilling the requirements of an international context on paper; it also has an important influence on the national educational system and labour market and requires sensitivity from all concerned stakeholders. Therefore, further research about the processes and difficulties in implementing national qualifications frameworks is needed to increase reflection on the reasons for the implementation and the factors and circumstances which accompany the whole implementation process. This means observing and analysing countries like Cambodia and Germany in the further process, especially because they are facing problems on very different levels within the implementation process.


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