COMPARATIVE EDUCATION AND HIGH SCHOOL REFORMS: BRAZIL AND SPAIN IN PERSPECTIVE¹

ABSTRACT:

Comparative education analyzes educational policies and practices across different countries, fostering critical reflection and contributing to teacher education. Comparing reforms makes it possible to identify impacts, convergences, and divergences, clarifying trends and challenges in contemporary education. This article aims to comparatively analyze high school reforms in Brazil and the Bachillerato in Spain, shedding light on convergences and divergences in light of comparative education as both a methodological and formative approach. The study employed the technique of Comparative Research, Epistemology, and Transfer (IET), along with the triangulation of documentary sources, adopting a dialectical methodology and comparative analysis of documents, including Law No. 13.415/2017 (Brasil, 2017), Law No. 14.945/2024 (Brasil, 2024b), and LOMLOE (España, 2020). The comparative methodology assumes a dual role: research and a laboratory for critical reflection on educational policies. The results reveal that both systems respond to the demands of the 21st century, focusing on competencies, curricular flexibility, and connection with the labor market, yet they face structural, cultural, and socioeconomic challenges that limit inclusion, equity, and educational quality. The study underscores the predominance of neoliberal trends and the need to reconcile innovation with specific historical and institutional contexts. It emphasizes the importance of critical teacher education and the construction of democratic and participatory public policies to implement fairer and more comprehensive reforms. It concludes that the practice of comparative education enhances critical analysis, reflective appropriation of international references, and the improvement of integrated educational practices and policies capable of promoting inclusive, high-quality, and citizenship-oriented education in secondary schooling, both in the Brazilian and Spanish contexts. The documentary analysis encompasses recent developments, including Law No. 14,945/2024 in Brazil, which represents a course correction in the face of implementation challenges. The research demonstrates how the Brazil-Spain comparative approach reveals that global curricular flexibilization policies must be adjusted to the profound structural inequalities of Latin America.

Keywords:
comparative education; educational reform; secondary education; Brazil; Spain

RESUMO:

A educação comparada analisa políticas e práticas educacionais em diferentes países, promovendo reflexão crítica e contribuindo para a formação de professores. Comparar reformas possibilita identificar impactos, convergências e divergências, esclarecendo tendências e desafios na educação contemporânea. Este artigo objetiva analisar comparativamente as reformas do Ensino Médio no Brasil e do Bachillerato na Espanha, elucidando convergências e divergências à luz da educação comparada como abordagem metodológica e formativa. Elegeu-se a técnica de Pesquisa Comparada, Epistemologia e Transferência (IET) e a triangulação de fontes, com metodologia dialética e análise documental comparativa abrangendo a Lei n. 13.415/2017 (Brasil, 2017), Lei n. 14.945/2024 (Brasil, 2024b) e LOMLOE (España, 2020). A metodologia comparada assume duplo papel: pesquisa e laboratório para reflexão crítica sobre políticas educacionais. Os resultados revelam que ambos os sistemas respondem às demandas do século XXI, focando competências, flexibilidade curricular e conexão com o mercado de trabalho, porém enfrentam desafios estruturais, culturais e socioeconômicos que limitam inclusão, equidade e qualidade educacional. A pesquisa destaca a preponderância de tendências neoliberais e a necessidade de conciliar inovação com contextos históricos e institucionais específicos. Aponta-se a importância da formação crítica de professores e a construção de políticas públicas democráticas e participativas para efetivação de reformas justas e abrangentes. Conclui-se que o exercício da educação comparada potencializa análise crítica, apropriação reflexiva dos referenciais internacionais e o aprimoramento de práticas e políticas educacionais integradas, capazes de promover uma formação cidadã, inclusiva e de qualidade no Ensino Médio, tanto no contexto brasileiro quanto espanhol. A análise documental abrange os desdobramentos recentes, incluindo a Lei n. 14.945/2024 no Brasil, que representa uma correção de rumos diante dos desafios de implementação. A pesquisa demonstra como o recorte Brasil-Espanha revela que políticas globais de flexibilização curricular precisam ser ajustadas às profundas desigualdades estruturais latino-americanas.

Palavras-chave:
educação comparada; reforma educacional; Ensino Médio; Brasil; Espanha

RESUMEN:

La educación comparada analiza políticas y prácticas educacionales en distintos países, promoviendo reflexión crítica y contribuyendo para la formación docente. Comparar reformas posibilita identificar impactos, convergencias y divergencias, esclareciendo tendencias y desafíos en la educación contemporánea. Este artículo objetiva analizar comparativamente las reformas de la Enseñanza Media en Brasil y de la educación Secundaria en España, iluminando convergencias y divergencias a la luz de la educación comparada como abordaje metodológico y formativo. Se eligió la técnica de Investigación Comparada, Epistemología y Transferencia (IET) en la triangulación de fuentes, con metodología dialéctica, y análisis documental comparativo abarcando la Ley nº 13.415/2017 (Brasil, 2017), la Ley nº 14.945/2024 (Brasil, 2024b) y la LOMLOE (España, 2020). La metodología comparada asume doble papel: investigación y laboratorio para reflexión crítica sobre políticas educacionales. Los resultados revelan que ambos sistemas responden a las demandas del siglo XXI, enfocando competencias, flexibilidad curricular y conexión con el mercado laboral, pero enfrentan desafíos estructurales, culturales y socioeconómicos que limitan inclusión, equidad y calidad educativa. La investigación destaca la preponderancia de tendencias neoliberales y la necesidad de conciliar la innovación con contextos históricos e institucionales específicos. Se señala la importancia de la formación crítica docente y de la construcción de políticas públicas democráticas y participativas para la implementación de reformas justas y abarcadoras. Se concluye que el ejercicio de la educación comparada mejora el análisis crítico, apropiación reflexiva de los referenciales internacionales y el perfeccionamiento de prácticas y políticas educacionales integradas, capaces de promover una formación ciudadana, inclusiva y de calidad en la Secundaria, tanto en el contexto brasileño como en el español. El análisis documental cubre las decisiones recientes, incorporando la Ley nº 14.945/2024 en Brasil, que representa una corrección de rumos frente a los desafíos de implementación. La investigación demuestra como el recorte Brasil-España pone de relieve que las políticas globales de flexibilización curricular necesitan ajustarse a las profundas desigualdades estructurales latinoamericanas.

Palabras clave:
educación comparada; reforma educativa; educación secundária; Brasil; España

INTRODUCTION

High school reforms have taken center stage in the contemporary educational agenda, both in Brazil and internationally, highlighting the need for thorough analyses of their impacts, challenges, and potential. Within the Latin American context, the evolution of educational policies aimed at curricular flexibility, the enhancement of competencies, and the pursuit of equity has prompted comparative studies (Canário, 2004; Frigotto, 2018; Parente & Villar, 2020). Such research contributes to understanding how different countries address historical and contemporary dilemmas in youth education while adapting their systems to swiftly evolving cultural and technological changes.

In Brazil, recent changes introduced by Law 13.415/2017 and Law 14.945/2024 have redefined the foundations of high school education, aligning discourses on school autonomy, educational pathways, and connections to the world of work with trends in international, particularly European, policies. Through the Organic Law on the Modification of the Organic Law on Education (LOMLOE-Ley Orgánica de Modificación de la Ley Orgánica de Educación) (Spain, 2020), Spain has been renewing Bachillerato (similar to high school) with an emphasis on interdisciplinarity, social inclusion, and preparation for global challenges, highlighting the need for teacher training and the development of competencies for citizenship (Brandão, 2018; Torres-Gómez & Pozo-Andrés, 2019).

Despite the extensive literature on educational reform, there is a gap in comparative analysis of the effects of these reforms on Brazil’s Ensino Médio and Spain’s Bachillerato. This gap is particularly critical when considering the political, economic, and cultural specificities of both countries and the context of Latin American public policy. The significance of this gap is highlighted by recent research by Silva & Araújo (2021) and Silva & Oliveira (2023), which have critically examined the meanings, contestations, and impacts of the Ensino Médio reform in Brazil, focusing on aspects such as curricular flexibility, educational pathways, and implementation inequalities. Therefore, this research is guided by the following problem: What are the main normative convergences and divergences between Brazil’s Ensino Médio (a mandatory stage) and Spain’s Bachillerato (a post-compulsory stage), and how does comparative education offer insights based on recent legislative changes in both countries? The central objective is to conduct a comparative analysis of the reforms affecting these two educational stages, structuring the discussion around specific analytical categories. The rationale for comparing a mandatory stage with a post-mandatory one was that both are the final cycle of basic education before going to higher education or the labor market, considering the social and educational expectations placed on the youth of their respective countries. The research contributes by moving beyond single-country analyses to offer a binational perspective, updated to include the recent Brazilian Law 14.945/2024, showing how the European context intersects with the structural and material challenges of Latin America and providing practical and theoretical insights for the formulation of more equitable educational policies.

To achieve our objective, this article is organized into sections that begin by presenting the adopted methodology, grounded in the Comparative Investigation, Epistemology, and Transfer (IET) technique and the triangulation of documentary sources. Subsequently, it analyzes comparative education between Brazil and Spain, exploring the influence of the Spanish educational system on Brazilian secondary education. The study proceeds with a comparative documentary analysis of the differences between the educational systems, examining categories such as curricular structure, principles and objectives, access and certification criteria, and assessment mechanisms. It then discusses the vulnerabilities and strengths of both systems, including a section on recent educational reform between 2022 and 2025, analyzing the significant curricular restructuring driven by Law 14.945/2024 in Brazil. This approach highlights the study's relevance and timeliness, updating the analysis to reflect the most recent changes implemented in both countries. Finally, the conclusion summarizes the key convergences and divergences identified, highlighting the contributions of comparative education to improve educational policies and critical teacher training.

MATERIALS AND METHODS

This study is based on the methodological approach of comparative research in the social sciences, grounded in the principles from Tylor (cited in Marconi & Lakatos, 2022) and Fachin (2017). The comparative method, as proposed by Tylor, is an approach aimed at understanding human behavior by studying the similarities and differences among different groups, societies, or cultures. This method analyzes two series or phenomena of a similar nature that originate from different social contexts or other fields of knowledge, allowing the identification of shared elements. Its application supports the ability to analyze large human groups situated in distinct, and even geographically remote, contexts. Thus, it becomes feasible to conduct research comparing societies separated by vast distances across a wide range of topics, depending, naturally, on the researcher's background and objectives (Fachin, 2017).

This study used a comparative documentary research approach (Marconi & Lakatos, 2022) to examine the reforms of Ensino Médio in Brazil and Bachillerato in Spain, investigating and explaining their normative, curricular, and pedagogical similarities and differences. The empirical scope covered key legislation currently in force, such as Law 13.415/2017 (Brazil, 2017) and the Law on Guidelines and Bases of National Education (LDBEN-Lei de Diretrizes e Bases da Educação Nacional - Law 9.394/1996) (Brasil, 1996) for Brazil, and the LOMLOE (España, 2020) and Real Decreto 243/2022 (España, 2022) for Spain. To complement the normative analysis, selection criteria were adopted for secondary sources (academic and institutional): scientific relevance (peer-reviewed articles and works by leading authors in the field); thematic pertinence (direct focus on the implementation of the reforms in question); and temporal scope (publications contemporary to the transition and implementation periods of these policies in both countries).

The process of drafting this text began within the course Enseñar en Perspectiva Comparada (Teaching from a Comparative Perspective), part of the Stricto Sensu Graduate Program in Education at the Universidade Regional Integrada do Alto Uruguai e das Missões (URI)—Frederico Westphalen Campus, Rio Grande do Sul, Brazil (PPGEDU/URI/FW/RS/Brazil)—in partnership with²Universidad Pontificia de Salamanca (UPSA), Spain. The study used a research technique based on Comparison, Epistemology, and Transfer of Results (IET)³. Documentary content analysis was conducted through a structured comparison of analytical categories defined a priori, that is, established theoretically before the regulatory review, based on established literature regarding the organization of educational systems (Zabala, 1998; Sacristán, 2000). These categories were: 1) curricular structure; 2) principles and purposes; 3) access and certification criteria; 4) assessment mechanisms; and 5) teacher training policies. The selection of these five categories comprises the fundamental structural axes that enable the operationalization of the dialectical approach proposed by Minayo (2013). Each dimension was analyzed in a structured manner within both contexts, examining convergences, unique characteristics, and the implications of reforms based on the legal frameworks, curricular guidelines, and observed impacts of each educational system.

Methodological rigor was achieved through the triangulation of documentary and theoretical sources (Minayo, Assis & Souza, 2005). This triangulation was effectively implemented by directly cross-referencing the literal text of normative legislation, institutional documents regarding curriculum guidelines (such as the BNCC in Brazil), and critical academic literature. This cross-referencing enabled a thorough comparison between the official discourse established by law and the practical challenges faced in implementation, infrastructure, and teacher training. By clearly defining the analysis criteria and maintaining an ongoing dialogue with the international debates, we ensured analytical rigor in the binational comparison of educational policies.

COMPARATIVE EDUCATION: BRAZIL AND SPAIN

Comparative education between Brazil and Spain is a strategic formative exercise that allows an analysis of how distinct sociopolitical contexts address common challenges in the reorganization of secondary education, particularly in scenarios shaped by contemporary curricular, policy, and pedagogical reforms. This approach enables the identification of trends and national specificities, providing a foundation for critical teacher training. It is recognized as indispensable in both the fields of research and educational practice (Garrido, 1997; Cowen, 2019; Matarranz, 2019; Parente & Villar, 2020).

This study analyzed the reforms of Ensino Médio in Brazil and Bachillerato in Spain, using the IET technique alongside the comparative method. This approach is based on the concept of transfer of learning (McKeough et al., 1995; Haskell, 2001), which guides the critical appropriation of what has been learned and the reflective integration of diverse educational frameworks and practices. Transfer of learning represents the essence of the learning process, an aspect not always realized, as research, methods, and results often accumulate without being shared (Haskell, 2001). Transfer of learning is the ultimate goal of both teaching and student learning. Teachers should support students who wish to apply what they have learned, following the effort invested in acquiring that knowledge, by demonstrating the ability to use the learned material competently (McKeough et al., 1995).

Overcoming the inertia of superficial learning in comparative studies needs active engagement, interest, and persistent effort, dimensions associated with the concept of communities of practice, which foster shared meaning and collective improvement (Kuh, 2003; Wenger, 2011). Thus, the IET technique plays a crucial role in reinterpreting knowledge by integrating contextual analysis, epistemological categories, and possibilities for adaptation across different realities. This approach is vital for the participants' intellectual, critical, and ethical development (Wenger, 2011). It involves rich and intense interactions between students and professors, enhancing social integration within communities of practice (Kuh, 2003).

The study is guided by recent legal reforms, such as the LOMLOE (España, 2020), and compares the Spanish post-mandatory secondary education system (specifically Bachillerato) with the Brazilian Ensino Médio⁴. It highlights changes in curricular organization, teacher training, and pedagogical approaches inspired by these educational reforms. The study also discusses current labor market demands and the importance of aligning educational policies to prepare students to face the challenges of the contemporary world.

The decision to compare Brazil and Spain is supported by the similarities and differences within their political-administrative processes, particularly regarding educational decentralization and the regulatory reforms of the 1990s. These reforms were largely influenced by global trends toward democratization, efficiency, and quality (Parente & Villar, 2020; Souza, 2009; Bolívar, 2009). In Brazil, this decentralization often failed to guarantee genuine autonomy for schools and teachers, frequently resulting in little more than the transfer of resources and the appointment of school administrators (Souza, 2009). In Spain, autonomy is linked to a management tradition and a vast body of legislation, with a focus that may not always encompass the daily school life but rather on administrative decentralization (Bolívar, 2009).

In addition to these organizational dimensions, the study also investigates the development of communicative competencies, bullying prevention measures, and the promotion of a culture of peace in schools as categories of analysis (Alonso et al., 2020; Alonso et al., 2021; Alonso & Nestar, 2022). These areas are fundamental to understanding how comparative systems address current challenges regarding inclusion, social coexistence, and active citizenship (Canário, 2004).

This comparison enables us to identify convergences and divergences between the Brazilian and Spanish educational systems. It highlights how reforms and institutional arrangements shape a democratic education, guided by solid historical-political and epistemological frameworks. The drafting of the 1988 Brazilian Constitution and, specifically, the 1996 LDBEN were influenced by Spain and other European countries (Souza & Batista, 2018). In addition to identifying normative similarities, the analysis emphasizes the historical, political, and social mediation in the international circulation of educational references. Without this mediation, there is a risk that complex processes will be oversimplified into mere model transpositions. In this context, the next section explores the influences, limitations, and possibilities of the dialogue between Brazil and Spain regarding secondary education.

INFLUENCE OF THE SPANISH EDUCATIONAL SYSTEM ON BRAZILIAN SECONDARY EDUCATION

Educational reforms implemented in Spain have significantly influenced recent transformations in Brazilian secondary education, particularly regarding curricular structure and teacher training. In this process of international dialogue, we highlight the development of the LDBEN (Brasil, 1996), aligning with LOMLOE (España, 2020) and Real Decreto 243/2022 (España, 2022). These regulations define the organization and minimum parameters of the Bachillerato in Spain. Brandão (2018) notes that this influence is also evident in the formulation of the National Common Curricular Base (BNCC) proposal (Brasil, 2018), bringing the structural frameworks of both countries closer together.

According to Torres-Gómez & Pozo-Andrés (2019), the influence of Spain's educational reforms on Brazil is evident, as in both the drafting of the 1996 LDBEN and recent Brazilian curricular proposals for upper secondary education. The parallels between the Spanish and Brazilian reforms illustrate how international contexts can effectively shape the formulation of national public policies, in ways adapted to local specificities.

The focus on developing competencies and skills rather than merely transmitting content is one of the key legacies of the Spanish experience, an aspect emphasized in the Brazilian debate. According to Pérez-Gómez (1998), the Spanish pedagogical paradigm is grounded in fostering problem-solving abilities, collaborative work, effective communication, and other skills that go beyond the accumulation of theoretical knowledge, encouraging the students' holistic and autonomous development. Thus, the importance of preparing students to tackle real-world situations and diverse challenges becomes evident, highlighting creativity, flexibility, and critical thinking as essential attributes of a quality education.

A significant aspect of the Spanish reform that was an inspiration for the Brazilian context is the promotion of interdisciplinarity and the contextualization of knowledge. This approach is to guide instruction towards a critical and reflective understanding of the subject matter (España, 2020). The integration of a culture of peace and active citizenship is another key feature for student development (Canário, 2004). In terms of teacher training, reflective practices, educational research, and collaborative learning, characteristics of the preparation provided in Spain have been highlighted as a model to be followed in Brazil (Imbernón, 2011).

The reform of Brazilian high school education, consolidated by Law 13.415/2017, sought to incorporate these trends by making the curriculum more flexible and allowing students to select some of their subjects based on their interests and life plans, fostering autonomy and youth agency. The reform emphasizes practical activities, projects, and outreach initiatives, aligning school with the concrete needs of contemporary society and the demands of the labor market.

The encouragement of greater integration between basic education and the professional sphere is another convergence with the Spanish model, consolidating the provision of subjects and learning pathways that align with entrepreneurship and employability. The BNCC (Brasil, 2018) recognizes the importance of fostering reflection on the world of work from the early stages of basic education, considering the socioeconomic diversity and local challenges in Brazil.

However, while such a curricular approach holds potential, the adoption of international models must be fundamentally mediated by a critical analysis of the cultural, economic, and social specificities of the Brazilian context. The automatic transposition of practices and norms does not necessarily offer solutions for the challenges faced by Brazilian schools. These challenges include historical inequalities, structural limitations, and distinct dynamics of exclusion and social vulnerability. Although the exchange between educational systems is valuable, policies must be adjusted through a dialogic and participatory process and attentive to local demands, avoiding the mere importation of paradigms and instead promoting the critical adaptation of international experiences.

DIFFERENCES BETWEEN EDUCATIONAL SYSTEMS

A comparative analysis of the educational systems in Brazil and Spain showed significant structural differences beyond the pedagogical area (Canário, 2004), encompassing institutional, cultural, and economic dimensions. However, both countries are not directly comparable, given their distinct historical-social and economic-institutional contexts (Brandão, 2018). Any attempt to transplant models between these contexts faces significant limitations, as the nations operated from different historical, political, and socioeconomic premises. While Spain is a developed nation, Brazil operates at a different level, facing the specific challenges associated with peripheral economies, a factor that impacts education funding as well as the implementation of public policies and educational reform projects.

By using analytical categories such as curricular structure, principles and objectives, access and certification criteria, assessment mechanisms, and teacher training policies, we observe different features and specific points of convergence. These differences influence not only the planning and implementation of educational practices but also the outcomes regarding equity and the potential for inclusion.

While high school education in Brazil (Ensino Médio) is structured as a three-year program entered after Middle School (Ensino Fundamental), Bachillerato in Spain constitutes the post-mandatory stage. It typically lasts two years, though it may be extended to four under special circumstances. In this context, Brandão (2018) highlights that this difference in duration shows different conceptions on mandatory school and educational specialization, reflecting diverse historical and political contexts.

In terms of curriculum, Brazilian legislation organizes High School based on fields of knowledge, aiming to foster an interdisciplinary and integrated view of learning that aligns with civic education and preparation for the labor market and social life (LDBEN, 1996). In contrast, the Bachillerato in Spain is structured into specific tracks (Sciences and Technology; Humanities and Social Sciences; Arts), with both core and elective subjects, with an emphasis on specialization and preparation for higher education (España, 2020).

The principles governing the educational systems demonstrated differences: the LDBEN (1996) highlights equality, freedom of learning, pluralism, and tuition-free education, while the LOMLOE (2020) reinforces cooperative learning, inquiry-based methods, a gender perspective, and inclusive policies aimed at students with specific needs (Articles 3 and 35 of the respective regulations). Both systems agree in holistic development for social, intellectual, and professional life, emphasizing citizenship, personal growth, and the enhancement of technological and communication skills. However, the focus in Brazil is the preparation for the labor market and the exercise of citizenship and Spain emphasizes intellectual and personal maturity, the deepening of knowledge, and the acquisition of skills for higher education (Articles 32 and 35).

This legislative and conceptual connection also reflects the economic and cultural differences between both countries, influencing school practices, teacher training, autonomy, and education funding. These aspects are explored in greater depth in the subsequent curricular and training analysis.

Beyond curricular and educational differences, there also differ in assessment methods and certification criteria. Brazil relies on continuous assessment models, parallel remedial opportunities, and standardized national systems (ENEM, SAEB), which are not always fully understood or implemented in practice. However, the Bachillerato in Spain uses specific continuous assessments and allows for flexible remediation of outstanding subjects, linking the educational pathway to higher education access through specific entrance exams (Articles 36 and 37).

To provide a systemic overview, Table 1 summarizes the main distinctions between the normative and organizational arrangements of Brazil’s Ensino Médio and Spain’s Bachillerato, based on the comparative categories adopted in this study.

Table 1
- Comparison between the educational systems of Brazil and Spain, according to current legislation

ASPECTS	ENSINO MÉDIO IN BRAZIL (LDBEN)	BACHILLERATO IN SPAIN (LOMLOE)
Access Passes	It requires completing elementary and middle school (grades 1 through 9) within the regular education system, or the elementary and middle school program for youth and adults (aged 15 and older) (Art. 38).	It requires a Mandatory Secondary Education diploma or a qualification in Vocational Training, Visual Arts/Design, or Sports Education (Art. 32, 2).
Functional Structure	Three-year duration; entry typically between ages 14 and 18; includes mandatory and optional (elective) subjects; mandatory stage up to age 18.	Two years (standard duration), extendable to four years; intended for the 16-18 age group; modalities: Science and Technology, Humanities/Social Sciences, Arts, and General; core, track-specific, and elective subjects.
Principles	It is founded on equality, freedom of learning, pluralism of ideas and values, and tuition-free education (Art. 3).	It values learning, teamwork, research methods, educational and vocational guidance, a gender perspective, and support for specific needs (Art. 35).
Purposes	It seeks comprehensive education geared towards work and citizenship (Art. 35).	It aims at human, intellectual, and social development by integrating knowledge, skills, and attitudes for active life, professional competencies, and access to higher education (Art. 32, I).
Objectives	Consolidation and deepening of knowledge, preparation for work and citizenship, preparation for social and political life, and personal and professional development.	Development of capabilities for democratic and global citizenship, personal and social maturity, equality, foreign language expression, mastery of Information and Communication Technologies (ICT), technical/scientific knowledge, and an entrepreneurial, artistic, or sporting spirit (Art. 33).
Values	It prioritizes ethics, solidarity, justice, social responsibility, and sustainability.	It prioritizes democracy, tolerance, respect for diversity, equal opportunities, and social cohesion.
Organizational Rules	It follows the guidelines of the LDBEN (1996), which establishes principles and norms for the organization of national education.	It follows the guidelines of the LOMLOE (2020), aiming to enhance educational quality and inclusion, and to promote equal opportunities.

• Source: Created by the authors based on data from LDBEN (1996) and LOMLOE (2020).

Table 1 shows that the Brazilian choice of a holistic education, centered on human development and preparation for exercising citizenship, is aligned with Freire’s (1970) critical pedagogy. However, Spain’s choice focuses on multidimensional competencies and skills aligned with the international movement toward competency-based education, a topic extensively discussed by Perrenoud (1999). These differences are reflected in each country's curricular organization. In Brazil, a structure based on fields of knowledge predominates, fostering interdisciplinarity, the contextualization of content, and the integration of different forms of knowledge. In Spain, organization by academic discipline prevails as a model that tends to deepen knowledge specialization, even though it may limit a more integrated understanding of reality.

According to Zabala (1998), curriculum organization influences teaching and learning processes, potentially making them more or less meaningful for students. In this sense, the curricular structure not only guides the selection and distribution of content but also shapes how individuals build relationships with knowledge, develop competencies, and assign meaning to school learning.

However, both approaches emphasize fostering critical citizenship committed to society, highlighting the importance of education for human and social development. When analyzing the curriculum, the Brazilian model encourages reflection on complex realities and the integration of knowledge, while the model in Spain prioritizes greater depth in specific areas, flexible learning pathways, and progressive alignment with students' career choices. We observed that both models acknowledge the need for periodic curriculum reviews to respond to rapid global changes and to promote inclusion, creativity, active citizenship, and the development of democratic values.

The contexts also differ in teacher training. Brazil emphasizes practice-oriented training focused on subject-specific teaching, predominantly at the undergraduate level. This can foster active participation in knowledge construction but may also lead to anxiety regarding practical skills and a limited reflective dimension (Imbernón, 2011). Spain has a four-year initial training program combining theory and practice, followed by postgraduate studies in didactics and pedagogy. It aims to prepare teachers to work in various settings and encourages innovative practices, though it faces challenges related to job stability and the equitable distribution of professional opportunities.

On the other hand, teacher training in Spain, with its broad, specialized theoretical-practical approach combined with supplementary didactic-pedagogical training, provides the proper tools to help students. Also, they offer a competitive examination process for entering the teaching profession, and the large number of education graduates who are unemployed or who have transitioned from other professional fields to obtain teaching certification, often with questionable vocational motivations.

Araújo & Barros (2019), Matarranz (2019), Kramm (2019), Aguiar & Dourado (2019), Nóvoa (2022), and Amaral et al. (2021) point out that teacher training is a complex topic involving more than the acquisition of specific technical skills. A variety of approaches is required, including theoretical studies, classroom practice, and continuous personal development. Educational systems need to provide teacher training that is balanced and tailored to the needs of each specific context. Teacher training can have significant consequences for classroom pedagogical practice. There should be a balance between theoretical and practical approaches, adapted to local realities, to ensure quality education for all students.

The pedagogical approaches adopted by each country seem to be quite significant. Brazil has a more conservative foundation that emphasizes content, while Spain follows a more open perspective, prioritizing skills and competencies that are pertinent to the professional field and access to higher education. According to Sacristán (2000), this difference can influence how teachers and students perceive the teaching-learning process.

It is essential that the governments of Brazil and Spain, within their educational mandates, invest in improving the quality of secondary education, specifically Ensino Médio and Bachillerato, by fostering a more integrated and comprehensive educational experience. This approach should prepare students for labor market demands, for democracy, and for the exercise of active, critical citizenship. Both countries need to constantly review and update their educational policies. This does not imply constantly changing education laws, but rather ensuring, through a formal agreement, that education aligns with the principles established in each country's Constitution. Such policies must respond to social, cultural, technological, and economic shifts, among others, enabling students to face the challenges of the contemporary world equipped with the necessary education, creativity, communication skills, and entrepreneurial spirit.

The continuous updating of educational policies also includes providing the necessary infrastructure to implement the changes proposed by the laws governing both countries, the LDBEN and the LOMLOE, such as information and communication technologies, up-to-date equipment and teaching materials, and ongoing teacher training, among other resources.

Table 2 compares Brazil’s Ensino Médio and Spain’s Bachillerato, addressing aspects such as objectives, instructional hours, mandatory and elective subjects, and final assessment for the stage, among others.

Table 2
- Comparison of the operational organization of Brazil’s Ensino Médio and Spain’s Bachillerato

ENSINO MÉDIO/ BACHILLERATO	BRAZIL (LDBEN)	SPAIN (LOMLOE/REAL DECRETO 243/2022)
Duration	3 years, with the possibility of failing curricular components.	2-year formal program with the possibility of extension up to 4 years and the opportunity to make up outstanding components; entry age: 16 to 18.
Mandatory subjects	Portuguese, Mathematics, Biology, Physics, Chemistry, History, Sociology, Philosophy, Geography, Foreign Language, Physical Education, and Art.	Core subjects (Physical Education, Philosophy, History of Philosophy, History of Spain, Languages) and mandatory requirements based on the chosen curricular area (tracks)
Elective courses	Limited; subject to availability and state regulations; curricular pathways provide flexibility.	Autonomy of the autonomous communities to offer elective subjects, organized according to regional and institutional preferences.
Assessments	Continuous evaluation, integrated tests, parallel remediation; external exams (SAEB, ENEM).	Continuous assessment specific to each subject; final certification exams; remedial work on aesthetic or conceptual components throughout the academic term. Differentiated assessment; and remediation of outstanding subjects during the second year of the Bachillerato.
Certification	High school certificate after full completion of the curricular stages.	Bachelor's diploma after completion of required and elective courses, including supplementary technical training.
Access to higher education	Via the ENEM and private university entrance exams; national public policies facilitate admission.	Specific exam (Selectividad/EBAU) with grade weighting for admission to public or private higher education.

• Source: Prepared by the authors based on LDBEN (Brasil, 1996), BNCC (Brasil, 2018), LOMLOE (España, 2020) e Real Decreto n. 243/2022 (España, 2022).

Brazilian high school (Ensino Médio) was modified by Law 13.415/2017, which increased the minimum annual instructional time from 800 to 1,000 hours and established a new, more flexible curricular structure aligned with the National Common Curricular Base (BNCC). Law 14.945/2024 redefined aspects of this reform, strengthening general basic education and reorganizing educational pathways. High school in Spain, the Bachillerato, lasts two years and its operation is different from the Brazilian model. Mandatory Secondary Education (ESO-Educação Secundária Obrigatória) is the mandatory four-year stage (from 12 to 16 years old). Post-mandatory education consists of the Bachillerato, the focus of our comparative study, which covers ages 16 to 18. After completing the Bachillerato, students may take the university entrance exam, popularly known as Selectividad and officially designated as the Bachillerato Assessment for University Access (EBAU-Evaluación del Bachillerato para el Acceso a la Universidad); the resulting score determines admission to the corresponding university program or degree (España, 2020), resulting in a longer educational trajectory with greater organizational flexibility.

These operational systems show distinct organizational and educational models, the advantages and limitations intertwined with the history, economy, and social policies of each country. While Brazil faces challenges regarding infrastructure, inequality, and teacher training, Spain reveals efforts to adapt to European regional demands, without escaping difficulties linked to decentralization, regional inequalities, and the need for greater investment.

This analysis emphasizes that, although there are common elements such as a focus on competencies and increased flexibility, the curriculum design, assessment and certification policies, and access to higher education must be understood in the context of each system's specific characteristics. A critical understanding is essential to ensure that any processes of transfer or international cooperation between the Brazilian and Spanish educational systems consider local nuances and existing structural challenges.

An integrated analysis of Table 2 shows that the reforms in Brazil and Spain, while sharing the aim of making educational pathways more flexible and aligning competencies with contemporary needs, demonstrate local responses characterized by a balance (or tension) between innovation and the preservation of educational traditions (Canário, 2004; Brandão, 2018; LDBEN, 1996; España, 2020). The expansion of curricular flexibility and the recognition of the need to prepare students for multiple pathways (academic, technical, and vocational) align with global demands regarding social inclusion and employability (Perrenoud, 1999; Brazil, 2018). However, their success depends heavily on the objective conditions within each country: adequate infrastructure; teacher training and professional valuation (Imbernón, 2011; Amaral et al., 2021); the updating of teaching resources; and support for diversity (Navarro et al., 2021; Brazil, 2015).

Tensions continue to exist regarding school autonomy, particularly in Spain due to decentralization and the presence of Autonomous Communities play a significant role (Bolívar, 2009; Brandão, 2018). In Brazil, the risk of fragmented learning pathways that are poorly coordinated or unequal is highlighted by the vulnerability of the public school systems and a lack of supportive policies, which undermines the effectiveness of innovative educational proposals (Frigotto, 2018; Saviani, 2011).

Finally, aligning educational systems with the world of work, addressing the challenge of competency-based assessment, and ensuring effective access to higher education require even more robust pacts among the State, the school community, and civil society. This could avoid the mere replication of external models while respecting the specificities of each national trajectory (Parente & Villar, 2020; Torres-Gómez & Pozo-Andrés, 2019; Freire, 1970).

VULNERABILITIES AND POTENTIAL OF EDUCATIONAL SYSTEMS

Analyzing the vulnerabilities and potential of Ensino Médio in Brazil and Bachillerato in Spain requires a critical theoretical approach that problematizes the social function of the school and considers trends in comparative policies for upper secondary education. As highlighted by Lingard & Sellar (2013) in their discussion of Stephen J. Ball’s work, the evaluation of reforms must consider both official discourse and practical impacts regarding equity, access, and retention for historically marginalized groups.

In Brazil, the democratizing potential of a flexible curriculum and professionalization, highlighted by the National Common Curricular Base for High School (BNCCEM) (Brazil, 2018), is supported by theories of curricular justice (Apple, 2024), which advocate for expanded opportunities for for diverse individuals. However, Frigotto (2018) and Dourado & Siqueira (2019) warn that this flexibilization, if not accompanied by the necessary conditions, adequate materials, and the valuing of the teaching profession, could exacerbate historical inequalities.

Persistent underinvestment in the public sector, alongside infrastructure deficits, ineffective inclusion policies, and unequal access to digital technologies (Saviani, 2011; INEP, 2019) has created a context in which the curricular autonomy and student agency remain largely rhetorical. As a result, developments that may seem progressive, such as the introduction of flexible learning pathways, integration with the labor market, and increased curricular diversity, are undermined by institutional fragility, a meritocratic mindset, and the declining status of the teaching profession. These factors have been identified as structural issues by critical Latin American scholars (Freire, 1970; Arroyo, 2013). Furthermore, the implementation of the “New High School” model in Brazil has marked a significant trend towards the corporatization of public education. As Silva & Oliveira (2023) demonstrate, the regulations and programs driving this reform have transferred the central role in curriculum and material development to private foundations and institutions, diminishing the decision-making authority of education professionals.

In Spain, the Bachillerato shows different characteristics, such as a longer duration and progressive specialization. Nóvoa (2022) and Imbernón (2011) identified them as essential for students' critical and academic development. Nevertheless, the system faces challenges similar to those in Brazil, including issues related to insufficient funding (OECD, 2022), deep regional inequalities, and a history of school dropout rates that, despite a recent decline noted by Eurostat (2021), remain a cause for concern.

The emphasis on integrating technical-vocational training into educational curricula (Navarro et al., 2021) aligns with the international employability agenda but carries the risk of fragmented educational pathways and the emergence of curricular hierarchies that privilege academic knowledge over practical skills, as warned by Yung (2014).

Spanish mobility and exchange policies demonstrate a certain openness to internationalization and diversity, yet they reveal limitations regarding inclusion, particularly for students with specific needs (Canário, 2004), and the implementation of national agreements aimed at more equitable education. Issues surrounding the hidden curriculum (Apple, 2024) and the system's decentralized organization in Spain, as detailed by Bolívar (2009), produce both positive (adaptation to autonomous communities) and negative impacts (difficulties in standardization and the universalization of rights).

Table 3 shows the strengths and vulnerabilities of both systems. Legal advancements and policies that promote flexibility frequently encounter structural, financial, and historical limitations. It is crucial to emphasize that, without the material and institutional conditions to ensure effectiveness, even the most significant strengths can be neutralized by persistent vulnerabilities.

Table 3
Comparison between the High School in Brazil and Spain in terms of strengths and vulnerabilities

COUNTRIES	POTENTIALS	VULNERABILITIES
Brazil	Diverse National Curriculum	Low public investment
	Free and inclusive access to education	Social inequality and high school dropout rates
	Social and racial inclusion programs	Low institutional quality and preparedness
	Recognition of knowledge and competencies	Lack of monitoring and psychosocial support
Spain	Investment in technology and continuous assessment	Persistent regional inequalities
	Mobility and internationalization programs	Insufficient resources in some schools
	Policies for vulnerable groups	School abandonment and challenges to full inclusion
	Diversity of educational formats	Difficulty adapting to special needs

• Source: Prepared by the authors based on Law 13.415/2017 (Brazil, 2017); BNCC (Brazil, 2018); LOMLOE (España, 2020); INEP (2019); Eurostat (2021); Apple (2024); Frigotto (2018); Navarro et al. (2021)

Frigotto (2018) and Apple (2024) state that Brazil's vulnerabilities stem from structural and historical deficiencies. Bolívar (2009) and Navarro et al. (2021) highlight the impact of decentralization and a lack of investment in Spain. Brazil still shows high school dropout rates at 11.8% of students leaving before completing secondary education (Anuário, 2021), although a recent reduction was observed, from 10.8% in 2018 to 8.3% in 2019, among students aged 15 to 17. Despite this progress, significant challenges remain regarding socioeconomic factors such as poverty, a lack of incentives, and mental health issues, directly impacting student retention and academic performance (Anuário, 2021; Eurostat, 2021).

School dropout is not limited to the educational Context. It generates negative impacts on the lives of young people and on society as a whole. Young people who leave school early face fewer employment opportunities, lower wages, and greater exposure to social risks, including violence and substance abuse. A lack of education contributes to socioeconomic inequalities and limits the country's productive and innovative potential (Anuário, 2021).

The high school reform in Brazil, formalized by Law 13.415/2017, introduced curricular flexibility as one of its key innovations. It proposes that students can choose specific areas of knowledge for in-depth study, a move with the potential to foster a more autonomous and critical educational experience (Brazil, 2018). The integration of vocational and technological education aims to align school with labor market demands, strengthening young people's employability (Torres-Gomez & Pozo-Andrés, 2019; Navarro et al., 2021). However, the promise of autonomy and student agency through the choice of educational pathways has been illusory in practice. Silva & Oliveira (2023) argue that the responsibility for offering diverse pathways fell to state education networks, whose limited structural conditions often prevent students from having genuine choices. Many municipalities have few schools, which restricts the range of options and steers young people toward precarious curricular arrangements, deepening the exclusionary and utilitarian nature of the reform driven by Law 13.415/2017 (Silva & Araújo, 2021). Despite these promising prospects, the effectiveness of these measures is severely constrained by a persistent lack of public investment, particularly regarding school infrastructure, the provision of up-to-date teaching materials, and digital connectivity.

Data from the National Institute for Educational Studies and Research (INEP, 2019-Instituto Nacional de Estudos e Pesquisas Educacionais) indicate that only 36% of public high schools in Brazil have internet access in every classroom. This situation hinders the use of educational technologies and limits students' access to information and digital resources. Another system vulnerability shared by Brazil and Spain concerns the provision and quality of foreign language instruction, particularly English, which is a mandatory subject in Brazil. A lack of qualified teachers creates a curricular gap that limits students' mastery of essential linguistic skills needed for entering the global labor market (Law 13.415/2017). This situation also impedes young people's academic and professional mobility.

High levels of overcrowding, a lack of teacher training, and the insufficient valuing of the teaching profession exacerbate the situation in Brazil (Saviani, 2011; Frigotto, 2018). Additionally, psycho-emotional issues, such as the absence of psychological support and difficulties with vocational guidance, have compromised student motivation and educational trajectories.

Curricular diversification and educational pathways, even still in their early stages, represent pedagogical advancements that, given the right conditions, have the potential to transform the educational experience, making it more meaningful and relevant for students (Brandão, 2018). The incorporation of practical components and collaboration with the productive sector shows potential for bridging the gap between school and the workplace, expanding opportunities for the social and professional inclusion of young people (Navarro et al., 2021). To fully realize this potential, it is imperative to simultaneously implement public policies that ensure adequate funding, prioritize the value and continuous training of teachers, and provide the necessary infrastructure.

In educational scenario of Spain, the Bachillerato stands out for offering a segmented educational pathway and an extension of secondary education, following the LOMLOE (2020). This structure, complemented by specialized tracks, prepares students for higher education and the labor market (Brandão, 2018; Torres-Gómez & Pozo-Andrés, 2019).

Recent reports from Spain’s Economic and Social Council and the Observatory for Education and Vocational Training (Navarro et al., 2021) indicate a growing appreciation for technical and vocational training, a sector previously stigmatized and underfunded. This change offers young students from Spain multiple pathways into the labor market, facilitating job entry and placement. However, challenges remain regarding the overcoming of prejudices associated with technical training and the assurance of its quality and alignment with the productive sector's demands. According to Navarro et al. (2021), the strengthening of technical and vocational education has been the focus of specific policies aimed at overcoming the historical devaluation of this sector and addressing lingering stigmas. However, budgetary limitations and regional inequalities persist, alongside a concerning school dropout rate estimated at 17% (Eurostat, 2021), raising concerns for social cohesion and the equitable provision of opportunities.

Educational inclusion remains a challenge for both countries, including the need for policies and practices that effectively address the needs of students with special requirements (Apple, 2024; Alonso et al., 2020). These issues impact the quality of education and the promotion of an inclusive and democratic school culture.

In examining the trends within the education systems of OECD member countries, the 2022 OECD report presents data on access, participation, completion, funding, equity, and the social and economic returns of education, alongside the impacts of the COVID-19 pandemic. The report highlights ongoing challenges related to equitable access, teacher qualifications, regional disparities, and the necessity to modernize in response to the demands of the 21st century. A comparison between Brazil and Spain addresses key factors such as public spending, the proportion of GDP allocated to education, school completion rates, results from international assessments, and the percentage of the population with a high school education. This underscores the crucial role of sustainable funding in promoting educational progress and social inclusion.

When comparing these systems, despite contextual and structural differences, both countries share the effects of neoliberal influence on education, which has led to an increasing focus on technical and vocational training at the expense of holistic and critical education (Saviani, 2011; Frigotto, 2018). These trends correlate with increased curricular fragmentation, the erosion of teaching job security, and the widening of inherent inequalities, undermining the implementation of educational policies that effectively meet social needs and promote equity.

Therefore, the formulation and implementation of educational policies must be grounded in transparent, democratic processes that involve school and community. Robust, inclusive educational agreements are essential to ensure the quality of educational systems (Frigotto, 2018; Brandão, 2018). Future research and intervention efforts must address these issues and seek to overcome the identified vulnerabilities, enabling both Ensino Médio in Brazil and the Bachillerato in Spain to fulfill their roles in fostering education and democratization.

The distinctions between Brazil and Spain should be analyzed within the framework of their unique historical, political, economic, and cultural contexts. This lens of comparison reveals that educational reforms, although influenced by similar global trends, manifest differently based on each country's institutional conditions, social agreements, and educational frameworks. This observation emphasizes the importance of critically understanding both the constraints and opportunities associated with the dissemination of educational policies across different national contexts.

In Brazil, the military dictatorship (1964-1985) was marked by strong U.S. influence and the consolidation of a technical model focused on transmitting content for the labor market, at the expense of critical, emancipatory education, as noted by Saviani (2011). More recently, the prevailing neoliberal agenda, particularly evident in the reforms promoted by the Temer administration (2016-2018), introduced curricular flexibility and aligned education with market demands. This approach has brought criticism from various sectors and social movements for being technocratic and undemocratic (Frigotto, 2018).

In Spain, educational policies are highly decentralized and structured following the political configuration of the [State of Autonomies, granting each community the autonomy to define aspects of the curriculum and educational management. This decentralization reflects the country's cultural, linguistic, and political diversity. Some regions emphasize the valuing of their identities and languages, as Catalonia, the Basque Country, and Galicia, while other communities follow guidelines more closely aligned with national policy. This shows the challenges of ensuring equity and coherence within the national education system, complicating both the planning and evaluation of public education policies (Brandão, 2018).

These policy orientations, positioned across various ideological spectrums, significantly influence public education policies and the ways in which educational systems address social, economic, and cultural challenges. The formulation and implementation of these policies necessitate transparency and broader participation from both the school community and civil society organizations. This involvement is essential to foster an education system that promotes equity, critical citizenship, and inclusivity. These findings underscore the importance of strengthening democratic processes that can solidify stable educational agreements that ensure continuity, adequate public investment, recognition of the teaching profession, and respect for cultural and social diversity.

Future research proposals could explore more thoroughly the impact of political ideologies on educational reforms, the role of social participation in policy formulation, and the role of school systems in mitigating inequalities from these orientations. Furthermore, expanding comparative studies beyond Brazil and Spain could reveal successful practices fostering equitable and holistic education across Latin America and Europe.

Another option for research involves examining assessment systems based on the impacts of educational reforms. Studies could also evaluate recent reforms, such as the High School reform in Brazil and the implementation of the BNCCEM, regarding student performance, inclusion, and educational quality (encompassing both humanistic and scientific dimensions). Such research could assess the promotion of economic, cultural, and social equity, and the rights of minority populations and groups not effectively integrated into government and State initiatives.

These are examples of potential studies related to the topic analyzed in this paper. The field of education is vast, offering opportunities and a need for research, inquiry, and proposals to address the major, urgent transformations society must confront, particularly in Brazil, given the large number of young people out of school, queuing for jobs with devalued wages, and exposed to the voracious exploitation imposed by the hegemonic labor market system.

CONTEMPORARY EDUCATIONAL REFORMS: RECENT DEVELOPMENTS (2022-2025)

Educational transformations within the Brazilian and Spanish systems continued to evolve after the initial implementation of the analyzed reforms, requiring significant structural adjustments based on practical experiences and challenges encountered during the early years of implementation.

Brazil's New High School Model: From Implementation to Restructuring

Starting in 2022, Brazil effectively began implementing the New High School model established by Law 13.415/2017, a process that revealed structural and pedagogical gaps necessitating legislative revisions. Practical experience highlighted issues regarding school infrastructure, a lack of material resources, insufficient teacher training, and limitations in the provision of “learning pathways” (itinerários formativos) (Agência de Notícias da Indústria, 2024; Brasil, 2024a; Movimento pela Base, 2023). In this context, Law 14.945/2024 introduced significant changes to the Brazilian high school curriculum structure, seeking to redefine aspects of the reform implemented in 2017 (Brasil, 2024b).

According to a study conducted by Movimento pela Base (2023) involving teachers from all five Brazilian regions, several challenges were identified regarding the implementation of the New High School model (Novo Ensino Médio). Key challenges include student resistance to the implementation of a sixth class period, rising dropout rates linked to the expanded instructional hours, and the difficulties teachers face when instructing subjects outside their area of expertise. Furthermore, the lack of standardization across various education systems has hindered the effective realization of the curricular flexibility proposed by the reform (Movimento pela Base, 2023; Agência de Notícias da Indústria, 2024). According to Agência de Notícias da Indústria (2024), the main changes resulting from the revision of the New High School model involve adjustments to instructional hours, criteria for selecting educational pathways (itinerários formativos), and the range of educational tracks available. In this context, the Ministry of Education highlights that increasing the instructional hours for the Basic General Education component (Formação Geral Básica) to 2,400 hours addressed a recurring demand from teachers and students, who had highlighted the need to strengthen the core curriculum established for this level of basic education (Brasil, 2024a; Brasil, 2024b).

In response to these limitations, Law 14.945/2024 was enacted in July 2024, establishing a new National High School Education Policy. Key changes include: increasing the instructional hours for the General Basic Curriculum from 1,800 to 2,400 hours; reducing the minimum hours for elective learning pathways from 1,200 to 600; mandating the return of all traditional subjects, including history, biology, sociology, and physical education; and implementing the changes gradually starting in 2025, beginning with the first year of high school (Brazil, 2024b). This restructuring represents an official acknowledgment that the previous excessive flexibility compromised students' basic education.

Educational System in Spain: LOMLOE and contemporary challenges

The Organic Law on the Modification of the Education Law (LOMLOE-Lei Orgânica de Modificação da Lei de Educação), approved in 2020, represents the eighth Spanish educational reform since the establishment of democracy. Known as the “Ley Celaá,” it seeks to address controversial aspects of the previous LOMCE (2013) by promoting greater inclusion, equity, and curricular modernization (España, 2023; Talentoteca, 2024). The LOMLOE establishes a competency-based approach as its central axis, organizing the curriculum around the exit profile, key competencies, and basic knowledge. Regarding the Bachillerato, it maintains four tracks (Arts; Science and Technology; General; and Humanities and Social Sciences), while offering greater flexibility in assessment and eliminating high-stakes exit exams (España, 2022; España, 2023).

However, the implementation of the law faces significant challenges. Recent studies reveal that most teachers view the lack of specific training on the law as the primary barrier to its effective application. Bureaucratic overload and insufficient resources are cited as obstacles to inclusively addressing student diversity. Educators have emphasized these issues alongside the need for specific training and a gradual approach to implementing this relevant legislation (Serrano, Vela, Martín, 2025).

While the decentralization of the system allows for adaptation to regional specificities, it creates complexities regarding national coordination and the assurance of equity among autonomous communities. Studies indicate that teachers at educational centers who expressed an interest in effectively implementing the changes feel better prepared and more competent in the face of the proposed modifications (Talentoteca, 2024; Serrano, Vela, Martín, 2025).

Comparative analysis of recent reforms

Both countries had similar efforts toward curricular modernization, prioritizing competencies and personalized learning. However, they reveal distinct trajectories: while Brazil is undergoing a course correction, acknowledging the limitations of excessive flexibility by expanding the General Basic Education component, Spain maintains a path of progressive flexibility, eliminating rigid assessment barriers (Talentoteca, 2024; Brazil, 2024a).

The Brazilian socioeconomic context demands greater attention to fundamental structural issues, such as infrastructure, resources, and teacher training. Spain focuses on pedagogical and inclusive refinements. This difference reflects the distinct realities of the two countries: Brazil as an emerging economy facing basic structural challenges, and Spain as a developed nation refining qualitative aspects of its education system (Movimento pela Base, 2023; Talentoteca, 2024).

However, recent reforms highlight the complexity of contemporary educational transformation. The success of both initiatives will depend on the ability to overcome identified structural challenges and on a commitment to continuous investment in education. In Brazil, the new law represents an attempt to balance curricular innovation with a solid educational foundation. In Spain, the LOMLOE seeks to consolidate a model that is more inclusive and adapted to technological advancements (Brasil, 2024a; España, 2023; Talentoteca, 2024). While Brazil structures secondary education around knowledge areas to foster interdisciplinarity, LOMLOE in Spain adopts a curricular architecture based on universal key competencies linked to subject-specific competencies, allowing for greater flexibility in adapting to regional contexts and individual student needs (Spain, 2023).

Comparative experience suggests that effective educational reforms require normative changes and adequate material conditions, continuous teacher training, school community participation, and sufficient time to consolidate the proposed transformations. International dialogue among education systems, while respecting local specificities, remains fundamental to the mutual improvement of educational policies (Serrano, Vela, Martín, 2025; Brazil, 2024a; Spain, 2023).

FINAL CONSIDERATIONS

A comparative analysis of the reforms to Ensino Médio in Brazil and Bachillerato in Spain indicates that the evolution of these educational systems is profoundly shaped by the distinct political, economic, and cultural contexts of each country. The varying ideological frameworks that inform their educational policies, spanning Brazil's authoritarian legacies and neoliberal transitions to Spain's intricate decentralization and political diversity, significantly impact curricular proposals, teaching practices, and strategies for inclusion.

In Brazil, recent reforms reveal a movement initially aimed at curricular flexibility and the expansion of educational pathways. However, the implementation of this design was complicated by structural inequalities, insufficient public funding, and political tensions that limited its democratic performance. In this context, the enactment of Law 14.945/2024 plays an essential role, signaling a course correction in response to problems identified in the reform's earlier formulation, particularly regarding excessive curricular fragmentation and the disconnect between the normative model and the actual conditions of public schools. This changes in the new law, also aligns with criticisms raised in recent Brazilian literature, which had already highlighted the limitations of curricular flexibility and the risks of exacerbating educational inequalities. In Spain, the influence of regional pluralism and initiatives designed to strengthen technical training and active citizenship must be constantly balanced against regional disparities and precarious investment levels.

The convergence between the two systems aims to meet contemporary demands for an education that combines competencies, interdisciplinarity, and a connection to the world of work, while still prioritizing the students' holistic, critical, and emancipatory development. This shift within the Brazilian context largely confirms the theoretical critiques raised throughout this research, particularly the formulations of Frigotto (2018) and Saviani (2011), by demonstrating that educational reforms based on excessive flexibility and uncritical alignment with market logics tend to yield limited results when confronted with historical inequalities and persistent material deficiencies. Ultimately, the successful implementation of these proposals depends on the capacity of states and societies to overcome the historical and structural challenges that hinder the universalization of the right to quality education.

A democratic and inclusive education requires the coordination of consistent public policies, grounded in broad social pacts, that ensure adequate funding, the valuing of the teaching profession, modern infrastructure, and the promotion of school environments that respect cultural, social, and individual diversity. The active participation of the school community and civil society in the formulation and implementation of these policies is essential to legitimize the process and ensure its sustainability.

Finally, this study recognizes that comparative education, when combined with dialectical methodology and the process of critical knowledge transfer, strengthens reflection on educational policies and fosters an understanding that reforms cannot be mechanically transplanted between distinct contexts. However, it is important to highlight that this study is subject to the limitations inherent in binational documentary and comparative research, as it relies on the analysis of legislation, curricular guidelines, and specialized literature, without encompassing observations of school practices or direct input from teachers, students, and administrators. By highlighting convergences, divergences, and historical shifts, this study contributes to a broader understanding of the challenges and potential associated with the organization of Ensino Médio in Brazil and Bachillerato in Spain. It also suggests potential avenues for future research, such as empirical school-based investigations, analyses of how teachers and students perceive these reforms, and comparisons with other Latin American countries.

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¹

Article published with funding from theCoordenação de Aperfeiçoamento de Pessoal de Nível Superior- CAPES/Brazil) for editing, layout, and XML conversion services.

²

The institutions have an internationalization agreement, signed in 2022.

³

The IET technique comprises a comparative document analysis of the systems under study, an epistemological analysis of the categories, and the transfer of results to educational contexts, in accordance with the teachings and guidance of Prof. Dr. Fernando González Alonso (UPSA/Spain) within the framework of internationalization activities between UPSA and URI.

⁴

Law of Guidelines and Bases of National Education (LDBEN-Lei de Diretrizes e Bases da Educação Nacional), Law 9,394 of December 20, 1996, establishes the guidelines and bases for national education in Brazil.

DATA AVAILABILITY STATEMENT

The content of the research text is within the manuscript.

Section editor:

Suzana dos Santos Gomes

CONFLICT OF INTEREST STATEMENT

The authors declare no conflict of interest regarding this article.

Publication Dates

• Publication in this collection
  02 Oct 2026
• Date of issue
  2026

History

• Received
  11 Nov 2025
• Preprint posted on
  10 Nov 2025
  10.1590/SciELOPreprints.13544
• Accepted
  17 May 2026