The Question Missing From the DfE’s EdTech Assessment

Before asking whether a technology works, schools and policymakers should ask whether it is necessary, proportionate and safe to use in the first place.

The Department for Education’s new assessment of the education technology market in England is a welcome attempt to make sense of a market that schools are already navigating: fragmented, fast-moving and difficult to assess.

The report does several things well. It maps the market, gathers evidence from suppliers and schools, identifies weaknesses in procurement and evidence, and acknowledges that schools often lack the time and expertise needed to make confident technology decisions.

But there is a more fundamental question that the report does not ask once:

Before asking whether an EdTech product works, should we be asking whether it needs to be there at all?

This matters because the decision to introduce a digital system is not neutral. It can change how children learn, how teachers work and how institutions operate. It can introduce new forms of data collection, monitoring, dependency, cybersecurity exposure and organisational burden. Those consequences do not disappear simply because a product has educational benefits.

The DfE’s proposed evidence criteria are useful. They ask about educational need, theory of change, impact, implementation, data protection, safeguarding and value for money. But identifying a need doesn't establish that a digital intervention is necessary to address it.

Consider a school that wants to improve pupils’ reading fluency. There may be a clear educational need, but that doesn't, by itself, justify purchasing an AI reading platform that requires pupils to log in, generates behavioural or performance data, and introduces another system into the school’s digital infrastructure. The relevant question is first whether the digital intervention provides something necessary that cannot be achieved through less intrusive means — and whether its additional costs and risks are justified by the expected benefit.

This distinction is entirely absent from the DfE assessment as it moves from identifying educational needs towards evaluating and improving the adoption of EdTech, without establishing a prior test of whether the technology itself is warranted. The question isn't simply whether a product works, but whether using it is justified in the first place. A mature assurance approach should therefore establish necessity and proportionality before product evaluation or procurement.

This is a missing step in current EdTech governance. The sequence too often looks as shown in Fig 1.

Fig 1. From adoption to assurance

A governance-first approach would ask an earlier question: Is this intervention necessary and proportionate in the first place (Fig 2)? Only then should we move to questions of product effectiveness, compliance and procurement.

Fig 2. Before adoption, ask four key questions

There is a second problem.

Even when a product has been judged worthwhile, evaluation is not assurance.

A supplier can provide a privacy policy; it can describe its security arrangements; it can provide evidence of educational impact; and it can state that risks are managed.

However, none of this necessarily demonstrates that the relevant controls operate in practice.

That distinction is not theoretical; our EDDS audits found repeated gaps between documented commitments and operational capacity, including weaknesses in data governance, technical assurance and risk management. These assessments demonstrate why supplier claims and independently verified controls should not be treated as equivalent.

The DfE report itself recognises that schools face limited capacity to assess products, contracts and evidence. Yet much of the proposed response remains focused on giving schools better information and guidance.

If schools are being asked to make increasingly complex decisions about technology, they should not also be expected to become the assurance mechanism for the entire EdTech market.

This is where the policy conversation needs to move. We need to distinguish between market intelligence, evidence of educational value and assurance of operational control. They serve different purposes:

• Market intelligence tells us what is out there.

• Evaluation tells us what a product appears to achieve.

• Assurance asks whether the organisation and system can actually operate within the legal, security, safeguarding and governance conditions expected of them — and whether they can demonstrate this over time.

The question is therefore not whether we need more EdTech evaluation but what happens after evaluation. And before that, we need to ask the question that comes before both:

Is this digital intervention necessary and proportionate at all?

EDDS Institute has set out a short critical assessment of the DfE's Assessment of the education technology market in England, examining what the report gets right, where its approach stops, and what an assurance layer could add to current policy and procurement arrangements.

Read the EDDS Institute critical review: From Market Assessment to Assurance.