Has pilot training got its knickers in a twist?
The role of Ofqual isn't to know about the subjects for which they regulate exams.
They do not need to know about any of the academic or vocational qualifications which they regulate.
Ofqual is there more to enforce academic and operational standards in terms of how courses are organised, conducted and examined.
As an example, you could start an exam board quite easily in principle and decide to offer a new GCSE, lets say in law, economics or philosophy.
Ofqual would regulate you as an exam board in the way described above.
Similarly, you could in principle submit a flying course to be regulated as a vocational qualification.
The question is that if you decided to take a different approach to the theoretical aspect of the course, how would the CAA and EASA react to this?