Many countries have, or are in the process of developing, a comprehensive National Qualifications Framework (NQF) but the anticipated benefits of NQFs are not easily achieved. This thesis addresses this issue by using a qualitative comparative case study research design to explore the challenges faced by three countries the United Arab Emirates (UAE), Bahrain and Oman. The UAE and Bahrain represent countries that have been in the implementation stage of their respective NQFs for more than five years, but have yet to achieve many of the intended benefits of an NQF such as to recognise lifelong learning, achieve parity of esteem of different types of qualifications and enhanced consistency, mobility, and portability of national qualifications. Oman’s comprehensive NQF is in the final stages of development.

By focusing on the implementation process underlying NQF development, this research aims to better understand how the intended purposes of NQF can be best achieved. Using semi-structured interviews from twenty-one policymakers, consultants and stakeholders who contributed to the NQF development process in each country, this research compares the similarities and differences in the challenges faced during the development process through a policy lending and borrowing lens.

Findings show that the countries differed particularly in the challenges they faced with institutional logics. For instance, while quality assurance systems of all educational sectors fall under a single authority in Bahrain, the UAE has challenges with coordination between the different sectors due to its federal diversity and Oman faces challenges with the governance structure of the framework being situated within an authority historically dedicated to academic qualifications only. The countries faced similar challenges however, in policy learning from early developers of NQFs. They each greatly underestimated and miscalculated a number of elements during the development process, and in the case of the UAE and Bahrain this has caused significant challenges in quality assuring and placing qualifications on the framework register, thereby delaying anticipated benefits.

This thesis highlights the challenges of implementing an NQF when contextual factors have not been taken into account sufficiently. The research has shown that in each of these countries considered, the policy objectives are highly ambitious and the scale of policy intervention required to achieve these presents enormous challenges. In particular, challenges relate to huge underestimation of costs involved and the time required for building local stakeholder competencies and capacity. This study demonstrates the difficulties of policy borrowing for NQFs, and the importance of a broader contextual consideration of factors with respect to the sociocultural and sociopolitical system of both the lending and the borrowing countries.