The Court of Appeal ruled for private colleges on 6 July 2026. HMRC has permission to appeal to the Supreme Court. Latest position

Education Exemption - College VAT Reclaims

VAT rules

Are examination services VAT exempt?

Last reviewed 28 September 2026. Checked against HMRC guidance, legislation and the judgments linked under Sources. General information, not tax advice.

Short answer

Examination services are exempt when an eligible body supplies them, or when any provider supplies them to an eligible body or to a person receiving exempt education or funded vocational training. They include setting and marking exams, assessments, certification and registering candidates. Supplied to anyone else, they are standard-rated.

What counts as examination services

HMRC's guidance includes:

  • setting and marking examinations
  • making assessments
  • other services that make sure educational and training standards are maintained, such as validation and accreditation
  • certification
  • registering candidates
Rows of desks in an examination hall

Who you supply decides the answer

SupplierCustomerVAT treatment
Eligible bodyAnyoneExempt
Any providerAn eligible body, such as an FE college or universityExempt
Any providerA learner receiving exempt education or funded vocational trainingExempt
Any providerA business for its staff, with no exempt education involvedStandard-rated

Examples

  • An awarding organisation that sets and marks exams for FE colleges supplies exempt examination services.
  • A commercial assessment centre that assesses employees for a company, outside any exempt course, charges VAT.
  • A company that accredits training courses run by other commercial providers charges VAT, unless those providers are eligible bodies.

The St Patrick's question

If a private college's courses were exempt because of the St Patrick's ruling, its students were receiving exempt education. It is not yet clear whether exam services supplied to those students or to the college follow that treatment. Anyone relying on this should take advice, because the Supreme Court appeal could change the answer.

Sources

  1. VAT Notice 701/30, examination services: GOV.UK
  2. VAT Act 1994 Schedule 9 Group 6: legislation.gov.uk

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