In many countries today schools have been subjected to a testing and accountability agenda tied to a return to 'basic skills' in reading, maths and science and a demand that all children, regardless of race and class, learn these skills. In this paper I argue that current work in sociolinguistics, cognitive science, and literacy studies, work not directly involved with assessment, suggests a more complicated view of assessment and its ties with learning and equity. This view challenges the current testing and accountability agenda, but can also redefine more broadly how we have to think about learning, assessment, and equity in schools. I develop this view around one key notion, namely opportunity to learn . In each section of the paper I discuss some area of current research relevant to learning and assessment and then state a principle about opportunity to learn. While I centre my discussion around assessing reading, in the end I make clear that my argument applies to assessment of all content areas in school (e.g. maths and science).