Specifying learning outcomes (LOs) in higher education as part of the European Qualification Framework (EQF) has resulted in a variety of experiences in the national contexts of England and Norway, as well as in different institutional and disciplinary settings. This article contributes to a contextualised understanding of the kind of management tools that higher education learning outcomes (HELOs) are, based on a conceptually‐informed comparative empirical analysis. The comparison is based on two types of disciplines (the humanities and STEM) in two national contexts (Norway and England) at two research‐intensive universities in each country. These settings offer an opportunity to look for evidence – inspired by public administration literature – as to whether HELOs have some specific characteristics as management tools. HELOs share the characteristics that afflict most reform policies – that of ambiguity and the potential of being shaped by a number of circumstantial factors. Higher education institutions are highly dependent on, and embedded in, multiple relationships to the environment. Hence, as decision making structures, they are ‘penetrated’ and influenced in ways that are likely to vary across countries, types of institutions and academic disciplines. Because institutions and disciplinary groups are embedded in different policy (varying degrees and forms of state steering and policy implementation) and organisational environments (different degrees and forms of hierarchical leadership, managerial control, and autonomy) and different disciplines (different perceptions of scientific‐, professional‐, educational mission, and relationships to external stakeholders) they also constitute different organisational spaces for participation and engagement in shaping and using HELOs.