Changing a provision in the regulation for an IT course platform
New regulations on the certification of online courses were to exclude smaller companies. For 3 months we participated in consultations, which resulted in the inclusion of an exception for specialized courses.
CodeMaster Poland faced a legal wall that could have blocked their sales at the level of 38% of previous revenue. New Ministry guidelines favored large, stationary universities, ignoring modern EdTech platforms.
The challenge
In March 2024, the Ministry of Education published a draft regulation on the certification of digital competencies. The provision in point 4b imposed an obligation to have physical examination infrastructure in every voivodeship. For CodeMaster Poland, a company operating 98.4% online, this meant the need to rent 16 offices, which would generate a cost of 427,000 PLN annually. Without these offices, their certificates would become useless for students seeking funding from KFS and PARP. We had only 18 business days to react before the project went to signature.
Our approach
We didn't play at writing empty petitions. The Sgela Education Advocacy team, under the direction of Marek Grzegorczyk, analyzed 114 pages of the act's justification. We found a gap: officials erroneously assumed that online identity verification is impossible to monitor. We prepared a technical report showing how proctoring systems (remote supervision) operate in 14 European Union countries. Then we arranged 3 specific meetings with the undersecretary of state, to which we took not CEOs, but the technical heads of the platform to show the 'insides' of the system.
The solution
We proposed a specific change in the wording of one paragraph. Instead of 'stationary infrastructure', we introduced the concept of a 'secure digital environment with confirmed integrity'. We delivered a ready legal opinion that officials could paste into the report from public consultations as their own conclusion. Thanks to this, the Ministry could announce success without admitting error, and the EdTech industry gained equal opportunities.
Results
Thanks to our intervention, CodeMaster Poland not only avoided huge rental costs but was also one of the first companies in Poland to receive accreditation for the new remote examination system.
Timeline
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March 2024Draft regulation audit and detection of risk for IT platforms.
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April 2024Submission of a 14-page report proposing a change in the exam definition.
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May 2024Last round of consultations at the Ministry and acceptance of the proctoring provision.
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June 2024Publication of the final text of the regulation with our amendments.
"We were sure no one in Warsaw was listening to us. Sgela Education Advocacy showed us that it's enough to change two sentences in the law to save an entire budget year. They know who actually holds the pen in the ministry."