The emerging interdependent world order poses new challenges for States and citizens alike. For States, interdependence has meant a new concern with integration, whilst for citizens and authorities alike, greater mobility has raised new concerns about recognition of competences, qualifications, quality and transparency. The introduction of learning outcomes is one of the principal instruments to achieve this in higher education. This article analyses how the implementation of higher education learning outcomes (HELOs) can be seen as ambiguous governance and management tools, manifested as parts of international policy development and policy trends. These ambiguous tools intertwine with different disciplinary and stakeholder networks. The desire to implement HELOs in a more or less uniform way across as diverse contexts (countries, disciplines, institutions) as possible has led to a design strategy that favours generic definitions of learning outcomes. In the implementation process, these generic HELOs are experienced as ambiguous, meaning that they are characterised by an openness to different interpretations. This opens up a space of discretionary and interpretational latitude, either because HELOs are assimilated to traditional path dependencies, or because they allow institutional agents (such as institutional leaders and others) the space to introduce change. The ambiguity of HELOs simultaneously provides the flexibility for contextually-diverse implementation, ensures less comparability than initially envisaged, and opens up the possibility for change, although change is contingent on structures and processes that are external to the policy process itself. HELOs are thus a paradigm case of the centrality of context in policy implementation studies.