One CEFR Level, Four Different TOEFL Numbers

The General Osteopathic Council asks for one thing: level C1. Then it lists four different TOEFL numbers to get there.

Listening 22. Reading 24. Speaking 25. Writing 24. Those four figures are exactly the floors of a single band on ETS's own conversion table.

SpeakShark is free for the section carrying the highest of those four numbers, three AI conversation sessions a day with no card.

In this guide: the four numbers · the match · why unequal · IELTS is flat · what it proves · what to do · limits · method · FAQ

Key takeaways

The GOsC asks for CEFR level C1 and lists four unequal TOEFL scores.
Speaking 25 is the highest; listening 22 is the lowest.
Those four are the exact floors of band 5 on ETS's conversion table.
The IELTS row is flat, 7.0 with nothing below 7.0, because IELTS uses one scale.
ETS does not publish which CEFR level each band is, so that part stays open.

One level, four numbers

The General Osteopathic Council states that the ability to communicate effectively with patients is critical to working as an osteopath in the UK, that the national language of the UK is English, and that applicants must be able to demonstrate level C1 of the Common European Framework of Reference for Languages.

It then gives examples of tests and the minimum level considered acceptable.

Test	Requirement
IELTS Academic	7.0 with no element below 7.0
TOEFL iBT	Listening 22, Reading 24, Speaking 25, Writing 24
Cambridge English	C1 Advanced, Business Higher, or ESOL Skills for Life

Look at the TOEFL row. Four sections, all scored out of 30, and four different numbers for what is presented as one level.

The obvious reading is that osteopathy demands more speaking than listening. That is not what is happening.

They line up with one band

ETS publishes a conversion table showing how raw section scores from tests taken before 21 January 2026 map onto its new 1 to 6 band scale. Here is the row for band 5.

Section	Band 5 range	GOsC minimum
Reading	24 to 26	24
Listening	22 to 25	22
Speaking	25 to 26	25
Writing	24 to 26	24

Four for four. Every GOsC minimum is the lowest raw score in its section that ETS maps to band 5.

The regulator has not chosen four numbers. It has chosen one level and then read across four different scales to find where that level starts in each.

Why the numbers are unequal

This is the part worth understanding, because it explains a pattern that shows up across the whole TOEFL scale rather than at one regulator.

All four TOEFL sections are reported out of 30, and that similarity is misleading. A raw 24 does not mean the same thing in speaking as it does in listening, because the sections are built differently and their usable ranges are not the same shape.

The consequence runs through the whole conversion table, not just band 5. Speaking demands the highest raw score of the four sections at every band from 2 up to 5, and at band 3 the gap is ten raw points, with reading starting at 6 and speaking starting at 16. We set out the full table in TOEFL's new 1 to 6 scale.

So the GOsC's uneven numbers are not a judgement about osteopathy. They are what a single standard looks like after it has been translated into four scales that do not line up with each other.

That is a useful thing to know in the other direction too. A candidate comparing their raw section scores against each other and concluding that their speaking is their weakest skill may simply be reading the arithmetic of the scale.

The IELTS row is a single number

The contrast in the same table makes the point better than any explanation.

The GOsC's IELTS requirement is 7.0 with no element below 7.0. One number, repeated.

IELTS reports all four skills on the same nine point band scale, so a single level translates into a single figure. TOEFL reports four raw scores on four separate scales, so the same level translates into four.

Same regulator, same standard, same day. The number of numbers is a property of the test, not of the requirement.

That flat 7.0 floor puts the GOsC alongside the pharmacy regulator, which asks for 7.0 overall with 7.0 in every area, covered in pharmacists and straight sevens, and above the dental and most HCPC requirements, which put the floor at 6.5, covered in the dental score table and speech therapists against doctors.

What this actually demonstrates

Three things, in descending order of confidence.

Certain. The GOsC's four TOEFL minimums are the exact lower bounds of band 5 in each section on ETS's published conversion table. That is arithmetic and anybody can check it.

Strongly implied. The regulator worked from a level and derived the numbers, rather than choosing four figures independently. Four exact matches out of four is not a coincidence anybody should have to argue about.

Not established. Whether band 5 corresponds to C1 on the CEFR. ETS describes its new scale as more intuitively aligned to CEFR and does not print a band to level mapping on the page we read. The GOsC says its numbers demonstrate C1. Those two statements are consistent with each other, and we have not seen the document that joins them.

We are separating those deliberately, because the temptation here is to write band 5 equals C1 as though it were established. It follows neatly and we have not read it anywhere.

What to do with this

Do not read the four numbers as a ranking of skills. They are one level on four scales.
Check whether your regulator states a level or a score. The GOsC states both.
If a test rescales, expect the numbers to be restated. They already have been elsewhere.
Take the preferred test if one is named. The GOsC prefers IELTS.
Book IELTS Academic, not General. The GOsC says so explicitly.

If speaking is the section with the highest floor in raw terms, it is also the one that does not improve by reading quietly. Role play scenarios and a daily speaking partner are the practical routes, testing your speaking level free shows the gap, and CEFR levels for speaking explains what C1 actually describes. IELTS for UKVI by CEFR level maps bands to levels, what C2 actually means covers the level above, and the TOEFL speaking section covers the tasks. For how examiners mark spoken English, Cambridge speaking criteria by level works from real scored candidates.

What we could not verify

We did not confirm that band 5 is C1. ETS does not publish a band to level mapping on the page we read, and we have not treated the correspondence as established.

We did not check when the GOsC set these numbers. The page does not carry a visible date, and the TOEFL scale changed on 21 January 2026.

We do not know how the GOsC treats a post-rescale TOEFL report. Its published numbers are on the old raw scale. What it accepts from a candidate whose report shows bands is not addressed on the page.

We did not verify the Cambridge equivalences. The GOsC names C1 Advanced, Business Higher and ESOL Skills for Life without giving grades.

We did not read the Osteopathic Practice Standards. The page cites Theme A as the source of the communication requirement and we have taken that citation as given.

This is not registration advice. It is a reading of a published requirements page and a published conversion table, both linked below.

How we researched this guide

We were reading the osteopathy page for its score table and stopped at the TOEFL row because the four numbers were unequal. A regulator setting a different bar for each skill is a real design choice, and we had already seen the HCPC do exactly that between professions.

The check was to look for where the numbers came from rather than to explain them. We had the ETS conversion table from earlier work in this series, so the fastest test was to see whether the four figures were the floor of a single band. They were, in all four sections.

That reframed the whole thing. What looked like a regulator weighting speaking more heavily turned out to be a regulator applying one standard across four scales that do not agree with each other.

The IELTS row in the same table is what confirms it. If the regulator wanted speaking held higher, the IELTS row would show it, and it does not. It is one number repeated, because IELTS already reports every skill on the same scale.

We then drew a hard line at the CEFR question. Band 5 corresponding to C1 would tie the whole thing up, and neither document says it, so it sits in the limits with the two things we can support above it.

Practise speaking, from SpeakShark

SpeakShark is an AI English speaking practice app, and this guide contains one genuinely reassuring finding for anybody staring at an uneven score report.

Your speaking number being lower than your reading number does not necessarily mean your speaking is worse. Those two numbers were never on the same scale.

What is true is that speaking needs a higher raw score for the same level, so it is where raw points are most expensive and where they buy the most.

You talk, the AI answers what you actually said, and you get speaking feedback while the conversation is still running. The free tier gives basic feedback; the detailed pronunciation and grammar breakdown is on Premium.

Being straight about the limits: a free session runs five minutes with four turns, and we issue no certificates. We are not affiliated with the GOsC, ETS or IELTS, and we do not teach osteopathic terminology.

Start free with three sessions a day and no card. Paid sessions run ten minutes with unlimited turns. Limits are on the pricing page, and how it works walks through a session. Sign up here if speaking is the number you need to move.

We are a speaking improvement tool. We are not an exam preparation provider, and we are not affiliated with Cambridge English, the IELTS partners, Pearson or any exam board. For test format, booking and official practice material, go to the exam body directly. Use SpeakShark to make your spoken English stronger, and use official material to learn the test.

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Sources

General Osteopathic Council, English language requirements: the requirement to demonstrate level C1 of the Common European Framework, the TOEFL iBT minimums of listening 22, reading 24, speaking 25 and writing 24, the IELTS Academic requirement of 7.0 with no element below 7.0, the Cambridge examples, the statement that any test demonstrating C1 will be sufficient, the stated preference for IELTS, and the requirement to take the Academic rather than the General test
ETS, understand your TOEFL iBT scores: the conversion table for tests taken before 21 January 2026 giving band 5 as reading 24 to 26, listening 22 to 25, speaking 25 to 26 and writing 24 to 26, and the description of the new 1 to 6 scale as more intuitively aligned to CEFR
Council of Europe, CEFR Table 1, common reference levels global scale: the definition of level C1 that the GOsC requirement refers to
GPhC, guidance on evidence of English language skills, June 2025: the pharmacy requirement of 7.0 overall with 7.0 in every area, used for comparison

FAQ

What TOEFL scores does the General Osteopathic Council require?

Listening 22, Reading 24, Speaking 25 and Writing 24 on the TOEFL iBT. The regulator presents those four figures as the scores that demonstrate level C1 of the Common European Framework of Reference for Languages, and speaking is the highest of the four while listening is the lowest. It also accepts IELTS Academic at 7.0 with no element below 7.0, and names IELTS as its preferred testing system.

Why are the four TOEFL numbers different from each other?

Because the raw section scales are not equivalent to one another. All four are out of 30, but the same raw number does not represent the same level in each section, so translating one CEFR level into raw scores produces four different figures rather than one repeated four times.

Is speaking really the strictest section?

On these numbers, yes. Speaking asks 25 out of 30 where listening asks 22, a difference of three raw points for what the regulator presents as the same level. The pattern matches the ETS conversion table published for tests taken before 21 January 2026, where speaking demands the highest raw score at almost every band.

What IELTS score does the GOsC accept instead?

IELTS Academic at 7.0 with no element below 7.0. Unlike the TOEFL row, the IELTS row is a single number repeated, because IELTS bands are already reported on one nine point scale across all four skills rather than on four separate raw scales.

Does ETS say which CEFR level each band is?

Not on the scores page we read. ETS describes the new 1 to 6 scale as more intuitively aligned to CEFR and publishes a conversion table from the old raw scores, but it does not print a band to level mapping there, so the exact correspondence is not something we can confirm from that page.

Which test should I take?

The GOsC states that its preferred testing system is IELTS, while accepting any test that demonstrates C1. If your regulator expresses a preference, that is worth following, because a preferred route is the one their assessors read most often and are least likely to query.