In the discussion paper it has been outlined that "there is a strong desire amongst different stakeholders to move towards a multi-level modular approach" instead of the current structure of EQE. Not knowing who the stakeholders are that have this desire, it seems that this design is a burden to most users of the system. On the one hand, who shall do invigilation for those tests, when they can be sat at any time? Who shall do the marking? Presently, EQE examiner, most of them epi members doing it in their free time, plan some time in spring/early summer for marking. When they will have to do it all over the year will there be enough markers? Most important, the highest effort in this examination lies in drafting the papers. When you multiply the number of tests at the same time you mulitply the work of the drafters. Is there enough (wo)man power to do this? It seems that the proposed changes have not been discussed with EQE examiners although they will have to do the work.
Furthermore, the proposed design will also be a burden for the supervisors. When candidates are "in examination" every 4 months this might change working routines a lot. Many patent attorney offices/patent departments offer regular courses and workshops for their candidates. This will all have to be newly organized. Therefore, the question is what do you gain by changing to a multi-level format?