Welsh Curriculum Consultation 2020 – Religion, Values and Ethics (RVE)

The REC wishes to emphasise its unequivocal support for the teaching of non-religious worldviews and for the appointment of non-religious representatives as full  SACRE and ASC members. It also wishes to emphasise its neutrality with respect to the provision of RE in religious character and community school contexts. This response should not be read as indicating otherwise.

The Welsh Government is currently holding a consultation on its proposals to amend its legislation for Religious Education. This is a really important consultation – the resulting legislation could have lasting and serious consequences for RE both for Wales and beyond.

A small team of REC Board members recently met with representatives of the Wales Association of SACREs (WASCRE) to discuss the proposals and how best to respond. We agreed on the responses below, which have been sent in the name of the REC, but would encourage all Member Organisations and individuals to make their own response, as numbers of responses are taken into consideration!

You may like to use the responses below to inform your own reply, but please take care not to copy and paste, even if you agree completely with what we have said. There is software in use that can detect an organised ‘campaign’ and that could dilute the strength of replies.

The consultation and online response form can be found here: https://gov.wales/legislative-proposals-religion-values-and-ethics

The consultation ends on 28th July 2020.

REC Responses: 

Question 1 – Do you agree that religion, values and ethics (RVE) should encompass both religious and non-religious beliefs that are philosophical convictions (in line with the European Convention on Human Rights) as described in the consultation document?

Neither agree nor disagree

Agreement depends on satisfactory resolution of the following concerns:

  1. The consultation document leaves the choice of specific philosophical convictions too vague and would leave local authorities or schools open to legal challenge over their curriculum choices.
  2. Proposed changes to SACRE composition may have an unintended impact on human rights and rights of representation for religions and their denominations, particularly if the current condition for LAs to make a judgement about which traditions appropriately reflect local representation is changed or removed.
  3. The proposal needs to be accompanied with a commitment to support teachers’ professional learning.
  4. The change of name to RVE is too broad and may lead to over-emphasis on citizenship and ethics at the expense of religious and non-religious worldviews and in helping children to learn about what really matters in the subject. In addition, the name RVE raises questions about what the perceived distinction might be between values and ethics, which are in any event whole school issues. The REC’s preferred name is ‘Religion and Worldviews’. [See also answer to Q9 below.]


Question 2 – Do you agree that agreed syllabus conferences must have regard to statutory guidance when they are developing their locally agreed syllabus?

Neither agree nor disagree

Agreement depends on satisfactory resolution of the following concerns:

  1. A common RE Framework has been published in the past (2008) that all ASCs ‘had regard to’ without the need for a change in the law of this nature, and all SACREs adopted/adapted it without being prescriptive. There have been supportive relationships between the WG and the SACREs and Churches without this kind of legislation so there may not be a need for a change in legislation here. The way the proposal is worded is also a hostage to fortune, leaving the relationship, along with local democracy, vulnerable to a different legislative body of the future.
  2. Inconsistencies in different sections of the document around the phrases ‘must have regard to..’, ‘required to..’ and ‘in accordance with..’ leave a lack of clarity and a feeling of imbalance. This will lead to confusion for LAs, SACREs, ASCs and schools.
  3. Proposal should read EITHER, ‘the’ locally agreed syllabus (not ‘a’) otherwise schools will have the right to follow any agreed syllabus even if it’s one from a different LA or from over the border, OR ‘an agreed syllabus in Wales’.
  4. It is unclear who will monitor whether ASCs conform to this instruction or how it will be done. There is a risk of difficult and potentially costly legal proceedings.
  5. It is unclear whether the RVE Framework would be part of this statutory guidance and, since this has not yet been published, it is not possible to give this question wholehearted approval.


Question 3 – Do you agree with our proposal that community schools and foundation and voluntary schools without a religious character must be required to have regard to an agreed syllabus in designing and implementing RVE?


  1. The phrase ‘must be required to have regard to..’ is unclear and weakens the status of the agreed syllabus, perhaps fatally in some of these schools. This is counter to the intentions of the Donaldson Report. Currently these schools have to teach RE ‘in accordance with’ the Agreed Syllabus, moving to ‘have regard’ is a step down. Change in wording could lead to schools not offering formal qualifications in RE even if it is required in the locally agreed syllabus. Similarly, schools might depart from the teaching of RE-specific essential skills as required in the current syllabuses. SACREs are best placed to ensure that RE as part of the curriculum for Wales is ‘local’.
  2.  ‘Some discretion’ suggests that it will be up to the school to decide, but will there be a formal process for schools choosing to depart from this, as is the case currently with determinations, along with criteria to follow within this process? Who will monitor this and how will it be done?
  3. Although the phrase ‘an agreed syllabus’ would allow more flexibility to schools it would be more correct to say ‘the locally agreed syllabus’ especially if complexity is to be avoided in schools selecting syllabuses outside of Wales.


Question 4 – Do you agree with our proposal that parents/carers of learners in schools without a religious character must no longer be able to request provision of RVE in line with tenets of a particular faith?


  1. In practice this rarely happens and, where it does, there is usually an informal arrangement facilitated by the school following a helpful dialogue with the parent about the RE they offer. If the proposal were to become legally required the opportunity for this dialogue would be immediately removed.
  2. If the right of withdrawal is not included in the new curriculum this could lead to a moral dilemma for parents/carers belonging to particular religious groups who may feel their beliefs have not been taken into consideration in curriculum arrangements. It could even lead to an increase in the number of parents/carers withdrawing their children from the maintained sector. Alternatively this may lead to a legal challenge with reference to the Human Rights Act 1998, Article 2, which states that “No person shall be denied the right to education. In the exercise of any functions which it assumes in relation to education and to teaching, the State shall respect the right of parents to ensure such education and teaching in conformity with their own religious and philosophical convictions.”
  3. This proposal, removing the right of parents/carers to request denominational RVE in schools without a religious character, does not match the proposal regarding the right of parents/carers to request agreed syllabus RE in schools with a religious character. It could thus be seen as being detrimental to equality.


Question 5 – Do you agree with the proposal that voluntary-controlled schools with religious character can teach RVE in accordance with the trust deeds of the school or the tenets of the faith of the school if requested by parents/carers?

Neither agree nor disagree

To some extent this statement reflects the situation as it currently stands but full agreement depends on satisfactory resolution of the following concerns:

  1. The statement appears to suggest that only one parent/carer need make the request for the school to have to provide RVE for all its learners, whereas currently a parent/carer can only request RE in line with the trust deeds or tenets of the faith for their own child. This should be clarified or it could create a workload issue for teachers and funding implications for schools.
  2. The language of the proposals is inconsistent, creating an imbalance. Here the proposal requires RVE ‘in accordance with the trust deeds..’ whereas previous statements speak of schools being required ‘to have regard to an agreed syllabus..’
  3. NB Trust deeds of schools currently refer to RE not RVE.


Question 6 – Do you agree that voluntary-aided schools with a religious character should be required to teach the agreed syllabus where a parent/carer requests it and should not have discretion to refuse to do so?


  1. This question references ‘the’ agreed syllabus where as it references ‘an’ agreed syllabus in others. This is inconsistent and imbalanced.
  2. The proposal amounts to a dilution of faith education. Research by Leslie Francis and Tania ap Sion has shown that after taking into account other influences (e.g. home environment), value is still added by VA schools at secondary level in ways that promote individual well-being and societal well-being with an enhanced sense of purpose in life being central to this.
  3. The proposal gives some parents/carers rights that they do not currently have, and removes rights from other parents/carers (of children who attend community schools).
  4. The proposal that schools may have to offer two separate curriculums for RVE would place an undue burden on schools and staff, e.g. in terms of teaching resources and materials, professional learning, budget, increased workload.
  5. It is not clear whether the two curriculums for RVE would have equal value and time, how division within the school might be ameliorated and how it would work in practice if the school were choosing to take an interdisciplinary approach.
  6. The compulsion involved in the proposal is unnecessary. Both the Church in Wales and the Catholic Education Service Wales have engaged with new curriculum development from the start and will be producing their own guidance which will ‘have regard’ to the statutory guidance.


Questions 7 and 8 are generic requirements of all consultations in Wales.

The REC left these questions unanswered.


Question 9 – We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them.

  1. The alternative name of ‘Religion and Worldviews’ should be reconsidered, as this title marks out the field of study – Religion (singular, and inclusive of all the issues raised in and by religion) – and is inclusive of religious and non-religious Worldviews. In addition the name has widespread and growing support amongst RE researchers, teachers and professional bodies internationally. This would also make the name more appropriate than RVE at GCSE and A level, and affords an opportunity to lead the way in legislation.

It is likely that many teachers in Wales were not knowledgeable enough about worldviews prior to the consultation in order for them to make an informed decision on the best name for the subject. Many of us have ‘been on a journey’ as far as the term ‘worldviews’ goes; often disliking the term at first, but then liking it more and more as we consider its inclusivity and appropriateness to the changing religious, educational and social landscape.

  1. Point 28 of the document appears under the VA schools section, but was probably intended as a separate point apply to all schools? Some grammatical corrections are including in square brackets below.

‘Schools will continue to need to assure themselves that their RVE provision satisfies the pluralistic requirement created by human rights legislation[,] and SACRES, ASCs and Local Authorities will continue to need to assure that any agreed syllabus their [they] develop and then adopt also meets these requirements.’

If the legislation included just this paragraph this could be sufficient to secure the appropriate changes without adding extras layer of complication.


Dave Francis

Deputy Chair, REC