The following letter was written to the Minister of Education, Erica Stanford, and ERO Acting Chief Executive and Chief Review Officer, Ruth Shinoda.
Tēnā koutou,
We are writing on behalf of the AIMHI Principals’ Group, representing Auckland secondary schools with high numbers of priority learners and high EQI contexts. We have significant concerns about the new ERO reporting format planned for introduction from Term 2.
ERO’s recent email to principals outlined the purpose of the new reports: to provide clear, useful information, support Te Ara Huarau, strengthen collaboration, and help parents understand their school. After reviewing the newsletter and the draft reports, we do not believe the new format achieves these goals. In several areas, it actively undermines them.
In particular, our concerns are:
The Reports Do Not Match ERO’s Stated Purpose or School Improvement Framework
The new colour-coded front page can be easily shared without explanation and can lead to misinterpretation, school comparisons, and public ranking. This damages trust and does not reflect Te Ara Huarau’s collaborative, improvement-focused approach. In particular, the simplified ‘traffic light’-style system does not provide real insight into complex school contexts, especially in high-EQI communities. It will reinforce misunderstanding, not clarity. Despite ERO’s statements, the reports are already being promoted online by parents as a tool for choosing schools, which strengthens harmful “good vs bad schools” narratives.
We also note the comment that “highly effective schools that are excelling across all SIF domains will see equitable and excellent outcomes for learners.” This is already disproven in the Intermediate Exemplar report that shows ‘excelling’ in the majority of areas, and in all of the areas directly in the school’s control, but still is listed as “Working Towards” in the three achievement-based criteria. This highlights a key issue: in high-needs schools, achievement is often shaped by systemic inequities, not the quality of teaching or leadership. The new model fails to reflect this reality and instead unfairly links achievement outcomes to school quality.
There is also insufficient clarity around how ERO will distinguish between achievement and progress in its reported judgements, particularly in relation to literacy, numeracy, and overall achievement. For example, progress is explicitly mentioned in the Achievement section of the secondary exemplar online.
In the interests of transparency, the data thresholds underpinning these judgements should be shared with schools, e.g., whether the ‘Most’ category of 90%+ meeting expectations is required for an “excelling” judgement, or what specific cut-off points differentiate “developing,” “embedded,” or “excelling.” This lack of transparency makes it difficult to understand the basis for the evaluative statements and to determine the consistency or robustness of the conclusions drawn.
Use of EQI
The Equity Index values are included at the end of the report; however, they are not referenced in the analysis or used to support, explain, or contextualise any of the findings. As a result, the EQI data appear disconnected from the evaluative narrative and do not contribute to the overall interpretation of reasons for current school performance. The reporting format does not acknowledge the real challenges faced by high-EQI schools. Without this context, lower achievement indicators become misleading and punitive; they distort public perception and potentially harm the schools working hardest for the learners who need the most support.
We also note the lessons from the Tomorrow’s Schools reforms of the 1990s, when increased competition between schools and the myth of ‘choice’ led to significant socioeconomic flight. These changes deepened inequities, the effects of which are still being felt in communities like ours and continue to drive many of the disparities we see between schools today.
Increased Risk for Principals
While we note the recent removal of the principal’s name from the end of the report in the exemplars, continuing to include the principal’s experience length under the ‘Leadership’ section, along with the colour-coded report of ‘quality,’ still exposes leaders to online criticism and ‘name and shame’ behaviour. This is particularly concerning for principals in high-EQI contexts where achievement data is easily misinterpreted. We would call for this entire row of the table to be removed.
A ‘One Size Fits All’ Model With No Evidence Base
There is no evidence, internationally or locally, that high stakes, public and simplified reporting such as that in these exemplars improves student outcomes.
However, there is strong evidence that such systems have the follow impacts:
Perpetuates inequities; disproportionately harms marginalised and under-resourced
communities. (Leader & Pazey, 2023; Foster, 2024)
Score gains often reflect test-specific inflation, not real learning; weak evidence of
achievement improvement. (Stecher; Koretz et al.)
Narrows curriculum; reduces teacher autonomy; shifts focus to test preparation. (Foster, 2024)
Increases stress, pressure, and burnout; diminishes autonomy. (Stecher)
Creates high-pressure environments, defensive behaviours, and reduced morale. (Tunnell, 2025)
Sanctions and rewards drive compliance behaviours that prioritise results over meaningful improvement. (Tunnell, 2025)
High-stakes systems are methodologically flawed; balanced, multi-measure systems are recommended. (Burger & Krueger, 2003)
In addition, we see the real risk that such reports:
stigmatise schools in low socio-economic areas
increase inequity
reduce trust in review organisations
drive competition between schools
narrow teaching and leadership practice
A model with no research foundation should not be implemented nationally.
High performing systems such as Finland do not use high-stakes inspection frameworks. Since 2000 one of the very highest performing school systems of Singapore has used a self-appraisal style quality-assurance system, the results of which are not publicly released by school so the focus remains on continuous improvement not public accountability that increases competition between schools. Instead they release data at the nationwide or system level to support ongoing improvements across all schools.
Reinforcing “Good vs Bad School” Narratives / Misalignment with Te Ara Huarau
Despite ERO’s assurance that the system is not for comparing schools, the format is already being positioned as a decision-making tool for parents. This reinforces unfair and inaccurate assumptions that harm schools serving priority learners the most. For the parents in our communities, the majority are not in the position of privilege to ‘choose’ their school. For those with the means to pay or to travel beyond their local school, this will continue to contribute to schools in our communities losing students to our low-equity-index neighbours.
The statements made in the exemplar “School of Concern” report, including that ERO does not have confidence in the leadership of the school, are also of considerable concern to us as a group. Te Ara Huarau is intended to be collaborative, contextual, and focused on improvement. The new reporting model is categorised, simplified, and designed for public comparison. These approaches do not align.
We also note that the report framework does not include the Te Tiriti o Waitangi section from the School Improvement Framework, despite being listed as the foundation for success (page 2 of SIF).
The Reports Do Not Support Schools Identified as “Of Concern”
In the primary school example online, a school labelled “of concern” also had strong teaching and leadership. The report provides no context, no explanation, and no meaningful guidance. It simply labels the school publicly as a failing school. This is not support. It is stigma.
Impact on Teacher Recruitment and Retention
New Zealand is already facing a serious teacher shortage, especially in high-needs schools. Publicly colour-coding schools as low-achieving—without context—will make these schools even harder to staff, widening inequity and reducing access to quality teachers for the learners who need them most.
Ministry Interventions Are Ineffective, and This Model Will Increase Use of Them
Existing Ministry interventions, especially Limited Statutory Managers, often add compliance pressure without providing practical help. These interventions do not address deep structural or community needs. If more schools are labelled “of concern,” the ineffective intervention system will be triggered more often, increasing pressure without improving outcomes. The current ERO research into the impact of School Support and Interventions would be good as a starting point but should be done before a report is introduced that includes greater numbers of schools in this category.
Some potential changes we would like considered:
Removal of the ‘front’ colour coded section that is easily ‘clippable’ for the media / social media.
Move the items under the direct control and leadership of school to the front of report e.g. Teaching, Leadership, Progress.
Remove the Achievement areas that are heavily dependent on school context from the colour coded area – include only in the narrative sections.• Specify exactly what is needed to be demonstrated to move a school from one category for another.
Allow for the report to be updated online as soon as the school can demonstrate the specified actions.
Development a list of support / resourcing / interventions that would be available to support schools requiring additional help.
Remove the Leadership section that gives the experience years of the principal.
Request for Action
Given the concerns outlined above, we respectfully and strongly request that ERO:
Pause the Term 2 roll-out
Undertake an urgent and meaningful review of the proposed reporting format
Engage directly with principals from high EQI schools, including AIMHI schools
Ensure any future reporting model is contextualised, evidence informed, safe for leaders, and aligned with Te Ara Huarau
Ensure that a range of positive supports with additional funding and resourcing are available to support schools before the roll out
Consider how these reports could be updated to better show improvement and progress
Our schools and communities deserve a reporting system that builds trust, deepens understanding, and supports genuine improvement - not one that oversimplifies, labels, and harms.
We look forward to your response.
Ngā mihi nui,
AIMHI Principals’ Group
L Addison - Edgewater College
S Craggs - Papakura High School
C Pili - Sir Edmund Hillary Collegiate
P Jones - Manurewa High School
D Suasua - Rosehill College
F Enari, P Enari - Pacific Advance Secondary School
T Filipo - Te Haikura ā Kiwa
L Webb - Aorere College
K Jefferies - Alfriston College
G Tuiletoa Tagaloa – Mangere College
C Bean – Tangaroa College
References
Leader & Pazey (2023)
Leader, J. A., & Pazey, B. L. (2023). More Than a Test Score: Toward a More Balanced School Accountability System. School Leadership Review, 17(2). Discusses how high-stakes test-driven accountability has failed to reduce inequities and often deepens them. [files.eric.ed.gov]
Foster (2024)
Foster, S. M. (2024). High-stakes Standardized Testing: Its Disproportionate Impact on MarginalizedCommunities. California State University, Chico. Shows narrowed curriculum, reduced autonomy, and disproportionate harm to disadvantaged communities. [link.springer.com]
Stecher (JSTOR Chapter)
Stecher, B. M. (Year unknown). Consequences of Large-Scale, High-Stakes Testing on School and Classroom Practice. RAND/JSTOR. Explains score inflation, distorted instructional practices, teacher stress, and undermined test validity. [mdpi.com]
Koretz, Linn, Dunbar & Shepard (1991)
Koretz, D. M., Linn, R. L., Dunbar, S. B., & Shepard, L. A. (1991). The Effects of High-Stakes Testing on Achievement. National Education Policy Center. Demonstrates that early gains are often illusory and do not generalise across assessments. [prrac.org]
Tunnell (2025)
Tunnell, K. (2025). High Stakes Testing in the U.S.: Evaluating Its Impact on Student Outcomes. Education Advanced, Inc. Discusses emotional stress, school culture distortion, and strategic behaviour encouraged by high-stakes accountability. [nature.com]
Burger & Krueger (2003)
Burger, J. M., & Krueger, M. (2003). A Balanced Approach to High-Stakes Achievement Testing: An Analysis of the Literature with Policy Implications. University of Alberta Press. Reviews research showing flaws in high-stakes systems and advocates for multi-measure assessment frameworks.



This auditing system was implemented in UK and was directly linked to the suicide of a Principal. A court case ensued and after investigation and deliberation the Judge decided the system was unsafe, harmful and did not provide a full picture of efforts by Leadership and teachers.