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October 2026 · Task Force Quality Education for Kids

Response to the ACM market study on digital learning materials

On 9 October 2026, Dutch Edtech responded to the consultation version of the ACM’s market study on digital learning materials in secondary education, on behalf of its board and the Task Force Quality Education for Kids.

We agree with the ACM’s diagnosis: the problem is not too few providers but too few switches. When schools rarely switch, they cannot discipline the market, and the market does not discipline itself. We asked for the conditions that make switching possible:

1. The same quality bar for paper and digital, with a burden of proof that grows with the claims a provider makes and the scale of use, not with the medium
2. Open admission with an annual choice, instead of multi-year winner tenders
3. Accessible rails: a workable Edu-V route for small and new providers, and one public identity and access layer in primary education
4. Public money as the rail, and as producer only under four neutrality conditions
5. Usage data per licence as the norm

The biggest gap in the report is primary education, which the ACM left out of scope. We asked for a follow-up study and for primary education to be included in the monitor.

We also committed the sector to its own part of the deal: delivering data, taking part in test environments and holding our own products to the same bar.

The response was shared with the Ministry of Education, Culture and Science (OCW), the Ministry of Economic Affairs, SIVON, Kennisnet, Edu-V, the VO-raad and the PO-Raad. The ACM expects its final report, including the consultation responses, at the end of 2026.

Download the response (Dutch)

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