In the pursuit of educational outcomes relevant to world best practice, competency-based curriculum is widely seen as the most appropriate tool. Thus in Australia all areas of vocational education and training are now drawn together through the Australian National Training Authority (ANTA) into an exclusively competency- based system. This paper focuses on the area of adult migrant English, which is a part of that system. The resultant improvements in articulation, the development of a culture of accountability, the usefulness of competency-based curriculum in focusing a course, and the hard work and commitment which have gone into shaping this evolving system, are all deserving of due recognition. However this paper questions whether all elements of curriculum can be effectively stated and measured in 'can do' or 'does' form. It is argued that the abstract forms of knowledge identified as underpinning competence, cannot be meaningfully defined or objectively measured in competency terms; attempts to do so require the stripping away of complexities, ambiguities, contradictions, interpretations and interconnections which are the essence of such forms of knowledge. It is further argued that the notion that abstract/subjective areas of knowledge can be effectively translated into objective competencies is based on pedagogical assumptions which need wider debate, and that that debate needs to encompass the view of reality in which such assumptions are rooted.