Brazil has developed an encompassing system for quality assessment of higher education, the National System of Higher Education Evaluation (SINAES), which includes a test for assessing learning outcomes at the undergraduate level, the National Exam of Student Performance (ENADE). The present system has been running since 2004, and also serves as criteria for accreditation of programmes and institutions, and has been used to regulate the growing private (for-profit) sector of Brazilian HE. We will present an analysis of SINAES and the many challenges it faces to be recognised as a valid tool for quality assurance and regulation for the Brazilian HE system, using data developed within the system for the engineering and medicine programmes in Brazil. The learning outcomes test is similar to the one that the AHELO project has proposed, including both general education and subject area components, thus providing some preview of issues that may arise as that project moves forward.