The Natural History GCSE consultation can be found here: https://www.gov.uk/government/consultations/gcse-natural-history-proposed-subject-content

Please consider responding to the consultation before the 4th of Sept.

Q1-9 are personal. Please see below for our responses to Q10 onwards:

Question 10: Subject aims  

The next question asks about the aims of the GCSE subject content.  

10. Are the subject aims easy to understand, clear and unambiguous?  

Yes; No  

If no or you wish to give further detail on your views, please explain: 

Question 11 to 14: Subject content  

The following 4 questions are about the requirements set out in the subject content.  

11. Paragraphs 7 – 12 of the proposed subject content detail the requirements for the study of habitats and wildlife in the UK. Do you agree with these requirements? 

Yes; No  

If no or you wish to give further detail on your views, please explain: 

We broadly agree with the proposed requirements for the study of habitats and wildlife in the UK and consider them to provide a strong foundation for developing students' understanding of the natural environment. 

We would, however, suggest a small number of refinements. First, while it is scientifically accurate to recognise that climate change can occur through both natural and human-induced processes, care should be taken to ensure that this does not inadvertently create a false equivalence. The specification should be clear that contemporary climate change is predominantly driven by human activities. 

Second, the inclusion of farmland as a key habitat is appropriate given its importance within the UK landscape. However, the specification should also help students understand that farmland is a human-modified environment that exists as a result of the conversion of natural habitats, and explore the implications of this for biodiversity and ecosystem functioning. 

Finally, we note that there is limited reference to ecosystem services, or nature's contributions to people, within the proposed content. While it is important that students understand the intrinsic value of nature, an understanding of the benefits that healthy ecosystems provide to society, including food production, water quality, climate regulation and human wellbeing, would strengthen the qualification and reflect an important aspect of contemporary nature conservation and environmental policy. This would support the UK in meeting its national target on biodiversity (as outlined in the UK National Biodiversity Strategy and Action Plan) aligned with Global Biodiversity Framework target 11. 

12. Paragraph 13 of the proposed subject content details the requirements for the study of human influence on the natural world. Do you agree with these requirements? 

 Yes; No  

If no or you wish to give further detail on your views, please explain: 

We broadly agree with the proposed requirements and welcome the inclusion of both the positive and negative influences that humans can have on the natural world. 

We suggest that the content could go further in helping students understand the systemic drivers of biodiversity loss and environmental degradation. This should follow the framing of the direct and indirect drivers of biodiversity loss as outlined by IPBES and the Convention on Biological Diversity. In particular, consideration could be given to the role that economic systems, production and consumption patterns play in shaping pressures on nature, reflecting evidence from assessments such as the Dasgupta Review and the IPBES Global Assessment. 

We also encourage the inclusion of a wider range of policy and governance responses to environmental challenges. While the reference to protected sites is welcome, students would benefit from exposure to contemporary approaches to nature recovery and conservation, such as Biodiversity Net Gain (BNG), Local Nature Recovery Strategies (LNRSs), the Environmental Improvement Plan (EIP), and international frameworks such as the Kunming-Montreal Global Biodiversity Framework. This would provide a more comprehensive understanding of how society seeks to address environmental challenges in practice. 

This would also allow reference to how human activity in the UK can impact natural history elsewhere highlighting the role the UK plays in impacting and restoring biodiversity across the globe. 

Finally, the content regarding human influence on the natural world should also cover what action young people can take to improve the state of the natural environment. Many young people experience eco-anxiety so pairing the often negative impact people have on the environment should be paired with actionable behaviours that can be taken to remedy it. 

13. Paragraphs 14 and 15 of the proposed subject content detail the requirements for fieldwork. Do you agree with these requirements?  

Yes; No 

If no or you wish to give further detail on your views, please explain: 

We broadly agree with this fieldwork requirement, as including a wide range of possible fieldwork options will make this more accessible, through allowing schools to select fieldwork locations that are most suitable for them. However, the proposed content could be more explicit about what is acceptable as fieldwork (for instance, if natural history collections can be included, which we believe should be). 

The proposed subject content also includes a clear list of the range of knowledge and practical skills that students should gain from their fieldwork, which provides guidance to schools on how to structure the fieldwork requirement. 

14. Paragraphs 18 and 19 of the proposed subject content sets the fieldwork requirement using a metric of ‘hours’, differing from the metrics used in some other GCSE subjects. This is to support schools to structure fieldwork flexibly across the duration of the course, including during regular timetabled lessons, if they wish. Do you agree with using a metric of ‘hours’ for the fieldwork requirement?  

Yes; No  

If no or you wish to give further detail on your views, please explain: 

Using the metric of ‘hours’ will allow schools to be much more flexible regarding where and when the fieldwork requirement takes place, therefore making it more accessible to schools with varying resources. This requirement being 20 hours over the course of the GCSE does seem sufficient, as this is likely to be split over multiple fieldwork sessions of different types. This means that students are more likely to experience a range of habitats and gain more knowledge on different forms of fieldwork than they would have done otherwise.  

Question 15: Appendix 1 – Use of mathematics and statistics in natural history  

15. Are the proposed range and extent of mathematical and statistical techniques, set out in Appendix 1, easy to understand, clear and unambiguous?  

Yes; No  

If no or you wish to give further detail on your views, please explain: 

Question 16 to 17: Appendix 2 – Examples of wildlife typically found for each habitat  

16. Appendix 2 provides a list of different types of species within each of the following 6 habitats (Urban, Freshwater, Woodland, Grassland, Farmland and Marine).  

The department has proposed this is an advisory list from which awarding organisations can use to create their own, equivalently sized list for each habitat, when writing GCSE specifications. Do you agree the list set out in the subject content should be advisory? 

 Yes; No  

If no or you wish to give further detail on your views, please explain: 

17. Are the requirements, set out in Appendix 2, easy to understand, clear and unambiguous?  

Yes; No  

If no or you wish to give further detail on your views, please explain: 

Question 18: Appendix 3 – Habitat coverage requirements  

18. Appendix 3 provides a list of illustrative options for focus of study for each habitat.  

Are the requirements, set out in Appendix 3, easy to understand, clear and unambiguous?  

Yes; No  

If no or you wish to give further detail on your views, please explain: 

Question 19: General  

The following question is general and allows you to provide feedback on anything that you wish to, which has not been asked.  

19. Is there anything you would like to feed back that is not covered in the questions above?  

Yes; No  

If yes, please explain: 

Education is a key enabler for change toward sustainability, and a powerful solution to address the environmental and social crises that society is currently facing. The Global Biodiversity Framework, which the UK is a signatory of, recognises education as a fundamental mechanism for transformative biodiversity action. It calls for transformative, innovative and transdisciplinary education at all levels, including formal, informal and lifelong learning; identifies education as an implementation pathway to achieving Targets 21 (access to biodiversity knowledge and informed decision-making) 16 (sustainable behaviours), and 22 (meaningful participation of children and youth in biodiversity decision-making). We strongly welcome the introduction of a Natural History GCSE and believe it has significant potential to improve ecological literacy, strengthen young people's connection to nature and support the development of future environmental skills. The proposed content provides a robust foundation in species identification, habitats, fieldwork and the relationship between people and the natural environment. 

However, we also believe that current systems of education do not yet meet the needs for eliciting whole-of-society transformative change needed to live in harmony with nature. We believe the introduction of a Natural History GCSE represents an important step towards improving ecological and environmental literacy amongst young people. However, given the increasing significance of biodiversity loss, climate change and nature recovery as societal challenges, we encourage the Department for Education to consider how natural history education can become a core part of secondary education rather than remaining a specialist optional subject. We therefore look for Biodiversity to be integrated in formal education curricula at all levels and across all relevant subjects, not only in natural sciences. Over time, consideration should be given to making Natural History a more widely available and accessible qualification, with status equivalent to the established sciences. We would also welcome the development of a corresponding A Level qualification to allow students to continue their studies and develop more advanced knowledge and skills in ecology, conservation and the natural environment. 

We also emphasise that environmental and natural history education should not be confined solely to this GCSE. While the qualification provides an excellent opportunity for students with a particular interest in nature, an understanding of biodiversity, climate change, sustainability and humanity's relationship with the natural world is increasingly relevant to all young people. These themes should therefore continue to be embedded across the wider curriculum, including within science, geography and other relevant subjects, ensuring that all students develop a baseline understanding of the environmental challenges and opportunities that will shape their futures. 

Additionally, unequal and inequitable access to nature remains a significant challenge in the UK (based on race, socio-economic status and geographical location) and it would be important to ensure that the introduction of this natural history GCSE supports the reduction rather than escalation of this issue. To the degree possible, efforts should be made to encourage uptake across a wide range of schools (including in urban, ethnically diversity, and more working class and lower-income areas). For example, we would strongly support the introduction of the GCSE to be coupled with additional targeted funding for uptake aligned with the existing nature-related government priorities and projects.  

Taken together, these measures would help ensure that natural history education reaches the broadest possible range of students, whilst also creating clear pathways for those who wish to pursue further study, careers or leadership roles in environmental and conservation fields. Teaching staff should also be provided holistic training on biodiversity-related matters to support this endevour. 

You can find more information on the UK youth priority for transformative education here: https://gybn.org/wp-content/uploads/2026/03/GYBN-Education-Policy-Brief-April-2021-ENG.pdf 

Finally, one additional aspect that would be valuable to include, but is currently not captured, is reference to the biodiversity and natural history of the UK Overseas Territories (UKOTs) and Crown Dependencies (CDs). 

We understand that the majority of schools and students undertaking this GCSE will be based in mainland UK. However, several of the UK Overseas Territories and Crown Dependencies, including St Helena, Ascension Island, Tristan da Cunha, the Falkland Islands, Cayman Islands, Guernsey, Jersey, Gibraltar and the Isle of Man, also deliver GCSE qualifications. It is therefore important that the qualification reflects the full breadth of the UK's natural heritage rather than focusing solely on Great Britain and Northern Ireland. 

The UK Overseas Territories are home to more than 90% of the species found nowhere else within the UK and encompass globally significant biodiversity, with exceptional levels of endemism and many iconic and charismatic species. These islands and territories contain unique ecosystems, from subantarctic islands and tropical coral reefs to cloud forests and volcanic landscapes, making a substantial contribution to the UK's global biodiversity importance. Including these examples would help students understand that the UK's natural history extends beyond its mainland shores and highlight the critical role that islands play in the evolution, conservation and protection of unique flora and fauna. 

Incorporating UKOT and Crown Dependency case studies throughout the specification would raise awareness of this internationally important biodiversity while providing engaging, real-world examples of ecological processes, evolution, species conservation, invasive species management and habitat restoration. It would also make the qualification more relevant and inclusive for students studying the GCSE within these territories, many of which have direct experience of habitats, species and conservation challenges that differ from those found in mainland Britain. 

Recognising the biodiversity of the UK Overseas Territories and Crown Dependencies within the Natural History GCSE would ensure that the qualification more accurately represents the UK's natural heritage and reflects the diversity of environments, species and conservation successes that collectively make up the UK's natural history.  

Question 20 to 21: Equalities  

The following 2 questions are about equalities.  

In accordance with the Equality Act 2010, ministers must have ‘due regard’, when making decisions, to the need to eliminate unlawful discrimination; advance equality of opportunity; and foster good relations, in relation to protected characteristics. The Department for Education has been taking this requirement into account in developing the proposed draft subject content.  

The relevant protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.  

20. Do any of the proposals have the potential to have a disproportionate impact, positive or negative, on specific groups, in particular those who share a 'protected characteristic' (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation)?  

Yes; No 

If yes, please explain: 

The GCSE will have a positive impact on young people within the UK and should remain accessible to all despite disability, gender, race, religion, sex and sexual orientation etc. 

As highlighted in question 19, the implementation and uptake of the GCSE could either address inequity of access to nature and nature-based learning or exacerbate it. This would depend on the role out of the GCSE being coupled with targeted support for schools in urban, ethnically diversity, and more working class and lower-income areas for uptake to support elements of the course that require additional resources (eg. Fieldwork).

21. How could the proposed subject content of the GCSE be altered to:  

• better eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Equality Act 2010;  

• better advance equality of opportunity between persons who share a protected characteristic and those who do not;  

• better foster good relations between people who share a protected characteristic and those who do not?  

Please provide evidence to support your response. 

Question 22: Environmental principles  

The environmental principles (EP) duty came into force on 1 November 2023. In accordance with the Environment Act 2021, ministers must have ‘due regard’ to the environmental principles policy statement when making decisions on new or revised policy. The Department for Education has been taking this requirement into account in developing the proposed subject content.  

The introduction of the EP duty means we must assess the effects of any new or significantly revised policy on the environment.  

22. Do any of the proposals have the potential to have an effect, positive or negative, on:  

• the use or management of land in the UK;  

• the atmosphere;  

• any type of inland, coastal or marine water body;  

• wildlife; 

• the supply of raw materials from natural sources;  

• opportunities for outdoor recreation?  

Yes; No  

If yes, please explain: 

The proposals are likely to have a range of positive environmental impacts. Most directly, the fieldwork requirement will increase opportunities for outdoor recreation and engagement with nature. More broadly, improved understanding of biodiversity, ecosystems and human impacts on the natural environment can help foster greater environmental awareness and stewardship among young people. 

Over time, this may contribute to more positive attitudes towards wildlife conservation, habitat restoration and sustainable land and water management. We do not anticipate any significant negative environmental impacts arising from the proposed subject content.