A/68/294 Millennium Development Goals. Thus, in a development agenda, such strategy should be formulated for the benefit of Governments. The recognition of the right to education and the fulfilment of connected State obligations should be crucial to the implementation of such an agenda, bearing in mind the concepts of “rights-holders” and “duty-bearers”. People have the equal right to receive an education, and can hold their Government to account to address discriminatory practices or the failure to provide for their education. Governments in turn have the duty to provide education, and their obligations are based in national and international law. 41. The Special Rapporteur thus considers it necessary that each universal goal should be accompanied by implementation strategies which can be taken into consideration by Governments. The implementation strategy reflected in the explanations in the report of the High-level Panel should be further developed: the post-2015 development agenda should first state the goal and then propose implementation strategies, followed by the monitoring mechanisms, accountability and enforcement. 42. A rights-based approach is grounded in legal rather than political obligations. Governments should be encouraged to develop a national legal framework, including constitutional provisions on the right to education as well as education laws and related regulations and decrees. Any implementation strategies must underline the need to modernize national legislation to meet the objectives contained in the education goals and targets. Key areas that should be addressed include defining quality education, the financing of education, the inclusion of skill development and technical education and vocational training, regulating the private providers of education and providing for adult literacy and lifelong learning programmes. 43. The Special Rapporteur welcomes the importance attached to equitable approaches to education in favour of the marginalized and the vulnerable in the report of the High-level Panel. That requires emphasis on the adoption of positive measures such as affirmative action and social protection schemes that target disadvantaged and vulnerable groups to ensure that they have equitable access to education. B. A universal goal on education 44. The right to education is among the most widely recognized international rights. Education-related goals should apply universally, with nationally relevant targets. The report of the High-level Panel recognizes the importance of pre-primary, primary and secondary education, as well as technical and vocational skills development. Adult literacy is mentioned in the report, though not included as a suggested goal. The illustrative goals also seek to address access, non-discrimination and minimum learning standards. 45. Education is a continuum that begins before formal primary education starts and continues after secondary school. The importance of early childhood care and education along with the role of family is crucial in preparing children for education and is a welcome inclusion to the agenda. The post-2015 development agenda must also address the needs of millions of adults in terms of basic levels of literacy and numeracy, linking that to skill development. 13-42277 11/26