Progress files, involving personal development planning (PDP), are becoming a feature of many higher education systems internationally. In the UK they will become mandatory for all undergraduate students from 2005. This presents a major implementation challenge, because while reflection has been a cornerstone of practice in some areas of higher education for a considerable time, its generalisation as national policy changes its discursive location. The paper presents findings from a case study of the implementation of PF in one UK Higher Education Institution (HEI). It reports on how staff in one institution understand PF in the context of national policy, and on how they interpret the challenges they face in facilitating reflection for all students. The paper argues that pedagogical innovations take on a different meaning when applied to the system as a whole.