Reform, resist, or rethink: Responses from CIPA, the PEB and the Paralegal Committee to IPReg's Education Review
Rose Hughes
Reform, resist, or rethink: Responses from CIPA, the PEB and the Paralegal Committee to IPReg's Education Review
Just as the dust was settling on one exam overhaul, IPReg opened the door on a much larger one. The Patent Examination Board (PEB) had spent the best part of four years reworking the Final Diploma syllabus. Before that process had even finished, IPReg launched something far more sweeping, an Education Review asking whether the entire route into the patent and trade mark attorney professions, not just the exams at the end of it, is still fit for purpose. The latest edition of the CIPA journal publishes the responses of CIPA, the PEB and the IP Paralegal Committee. In summary, CIPA suggests substantive reform, the PEB pleads to be left more or less alone, whilst the IP Paralegal Committee offered a practical rethink of how the work actually gets done.
Background on IPReg, CIPA and the PEBThose of you who stay away from UK patent attorney politics and bureaucracy can probably be forgiven for forgetting what the difference is between IPReg, CIPA and the PEB. As a reminder, CIPA (the Chartered Institute of Patent Attorneys) is the profession's membership and representative body. It is also the approved regulator under the Legal Services Act 2007, but it delegates the actual regulating to IPReg (the Intellectual Property Regulation Board), the independent body that sets the education and training rules. The PEB (the Patent Examination Board) sits somewhere between the two as a self-governing committee of CIPA, accredited by IPReg. Its job is to set and mark the qualifying exams, the Foundation Certificate and Final Diploma papers that stand between a trainee and the Register.
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| Trainee Kat |
What happened with the PEB's accreditation
Before considering the latest review, it also helps to understand the recent scrutiny by IPReg on the PEB. Since a Board decision on 30 October 2019, IPReg publishes all accreditation assessments and their implementation plans. The Final Diploma exams were formally re-accredited in 2023, following an assessment exercise carried out in 2022. That accreditation came with strings attached, namely 19 Requirements and 2 Recommendations to be met over two years under a published implementation plan.
In 2024, IPReg commissioned a formal review of whether those conditions had been met. The assessors' final report went to the IPReg Board on 15 May 2025. The report flagged several urgent matters that had to be fixed before the 2025 exams could safely go ahead. Most of these arose from malpractice and online-invigilation problems during the 2024 sitting. The assessors called for an urgent review and reprocurement of the online proctoring provider, clearer malpractice reporting lines between the PEB, CIPA and IPReg, revised complaints and appeals policies, and an external check that reasonable-adjustments arrangements complied with equalities law. The PEB addressed these points, and the assessors reviewed its response in a further short report.
That was enough to keep the show on the road. In July 2025 the IPReg Board confirmed sufficient assurance to accredit the FC and FD exams for October 2025. At its January 2026 meeting the Board re-accredited the FC exams and accredited the FD exams for delivery from 2026. Longer-term questions about governance, quality assurance and assessment arrangements remain under discussion.
IPReg Education review
The IPReg Education Review's stated aim is to test whether qualification routes "remain high-quality, responsive to needs, accessible, and sustainable." Its scope is deliberately wide. It covers how "day-one" professional capabilities are changing, which parts of IPReg's existing competency framework should survive, how generative AI is reshaping both training and practice, how proportionate regulation should be for a profession this small, and how entry can be widened without lowering standards. Two things were explicitly carved out of scope, namely the near-term question of EQE equivalence and IPReg's CPD framework, which was already overhauled in 2023.
IPReg's Call for Evidence ran from early February to 30 April 2026. Responses will feed into proposals developed over the summer and autumn of 2026. A full public consultation is expected to run into 2027, followed by Legal Services Board approval and an implementation timeline pencilled in for as late as 2028/29. On past form, reviews like this move slowly.
CIPA's response to the IPReg Education Review
CIPA's submission, by a working group of its Education Committee, is by some distance the most detailed and ambitious of the three. CIPA's central caution is that UK reform cannot be designed in isolation. An estimated 85% of UK patent attorney work touches the EPO. Most trainees qualify as European Patent Attorneys alongside their UK registration. And, pointedly, UK registration isn't actually required for most UK patent work. If the UK route becomes more burdensome than the EQE route, CIPA warns, trainees and employers will simply prioritise Europe and let UK qualification slide, "already the case in some instances." This particularly applies to the field of pharma and biotech, where UK-only patents can have relatively limited value.
On substance, CIPA would drop nothing from the competency framework but add plenty. AI competency is treated as an emerging day-one requirement for trainees in its own right. This means not just using AI tools, but understanding their limitations, prompting them safely, and knowing the ethical and confidentiality risks. Alongside AI, CIPA points to commercial and strategic awareness (especially for in-house trainees), advocacy skills across the UK IPO, EPO and UPC, and basic IT and client-management competence as capabilities now expected far earlier than before. More advanced technical and litigation skills could move to after registration, under supervision.
CIPA firmly opposes mandating formal accreditation of trainers. It argues this would deter the profession's informal, volunteer-driven training, such as Informals lectures and ad hoc mentoring, and hit hardest the small firms and in-house teams least able to absorb the burden. It does, however, want IPReg to keep requiring clarity for trainees up front, backing formal training contracts.
On the long-running Foundation-route debate, CIPA leans on its own published data (from the December 2019 and July/August 2018 CIPA Journals), showing that candidates who sit the PEB's Foundation Certificate (FC1) outperform university-route candidates at Final Diploma stage (although the numbers are low for concluding anything with statistical significance). CIPA nonetheless stops short of endorsing the Mercer Review's Recommendation 8, that PEB exams be made compulsory at both Foundation and Final Diploma level. Instead it argues for a middle path, with the PEB as the ultimate gatekeeper, with university foundation courses allowed to continue provided their content maps onto the FC syllabus. CIPA also attaches its proposed new Patent Scientist/Patent Engineer Level 6 degree apprenticeship.
Finally, CIPA also flags two practical irritants for IPReg to fix regardless of the Review. The first is recurring online invigilation problems “which can be distressing for candidates”. The second is a new timing clash created by EQE reform. Paper F can now be sat after just a year of training, clashing with UK Foundation-level study and overloading trainees.
The PEB's response
The PEB has in the past received a hard time from trainees and IPReg. Its current response maintains its familiar defensive and cautionary tone (although, to be fair, being a member of the PEB committee is a rather thankless task, with the PEB often on the receiving end of candidate ire when things go wrong).
Where CIPA's submission runs to detailed proposals and appendices, the PEB's response is relatively brief. The PEB opens by reminding everyone of its own rigour, exams "designed and marked by members of the patent attorney profession," a "comprehensive quality assurance process," and external examiners. PEB's message to IPReg then boils down to a plea not to make any overly radical changes or increase regulation:
"This is particularly important — and challenging — in a comparatively small profession. For example, the PEB is reliant upon a small pool of professionals to engage in assessment through the various examiner roles… We look forward to an increasingly risk-based and 'right-touch' approach to regulation in the future."
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| "Progress for progress' sake must be discouraged" |
The PEB goes on to explicitly caution IPReg against any "radical reimagining of the professional learning journey”, as the cost associated with this “could discourage firms from engaging with the process”. However, as CIPA points out, it seems more likely that not changing will lead to increased disengagement with the UK exams versus EPO qualification. On widening access, the PEB notes that its role in this is "very limited." It indicates some support for CIPA's apprenticeship proposal and suggests that the Review consider non-exam assessment methods. However, it also cautions that exams are cheaper to run and are already perceived as rigorous within the profession. Unlike the other two responses, the PEB does not mention AI.
However, for this Kat, there is still a big question as to how exams should evolve in the new AI-age. The Review following 2023 Assessors’ Requirements and Recommendations for accreditation of the Final Diploma (Qualifying Exams) cited multiple instances of suspected or actual malpractice, including the use of AI, that the PEB had not adequately dealt with or reported. The PEB has now introduced a malpractice policy document and new procedures for examinations to ensure candidates are aware. However, malpractice is just part of the picture. With the use of AI becoming increasingly the norm in daily practice, the question remains how, and if, the examinations should adapt to stay relevant.
The IP Paralegal Committee's response
A third response to the Review comes from CIPA's IP Paralegal Committee. The central argument from this committee reframes the whole debate. Day-one capability, it suggests, has shifted. It is no longer about personally performing every step end-to-end, but about delivering effectively within a modern, team-based and technology-enabled service model. Newly qualified attorneys focus on judgement, supervision and accountability rather than manual execution.
From that starting point the Committee argues that much of the procedural and administrative work historically used to train junior attorneys, such as formalities management, recordals, portfolio coordination and deadline control is now routinely and competently handled by trained paralegals and records professionals. The implication for the Review is one of proportionality. Rather than requiring trainees to master tasks that specialist teams already deliver safely, qualification should concentrate on genuinely attorney-level skills, namely supervision, delegation, risk-spotting and complex advice. Like CIPA, the Committee treats AI literacy, confidentiality, auditability and human oversight as core day-one requirements rather than optional extras.
On widening access, the Committee makes a pointed observation of its own. Whilst experienced paralegals do sometimes qualify as trade mark attorneys, the route into the patent attorney profession remains far more limited in practice. That is a structural barrier for people who already hold valuable procedural expertise. It points to existing frameworks such as the Introductory and Advanced Patent Paralegal Courses as models of how experience, structured learning and assessment can be aligned to real service delivery. It also backs CIPA's apprenticeship work as a way to widen entry without lowering standards.
Final thoughts
All three responses share some common ground. First, keep workplace-based training as the foundation of qualification. Second, keep any reform proportionate to a profession that is small by regulatory standards. All three back an apprenticeship pathway as a legitimate way to widen entry without disturbing the core model (although the PEB offers only general support as opposed to the specifics of the CIPA proposal). The main difference between the responses is one of ambition and appetite for change. CIPA used its submission to make some radical suggestions for change, with some new proposals for education reform. The IP Paralegal Committee reframed the question around how IP work is now actually delivered, through multidisciplinary teams. The PEB, by contrast, mostly used its submission to defend the status quo. Interestingly, both CIPA and the Paralegal Committee treat AI literacy as a core day-one requirement, whilst the PEB does not mention AI at all.
The three submissions are now with IPReg to consider, and we await their proposals that will feed into a public consultation expected later this year. Stay tuned!
Further reading