This chapter serves as the overarching framework for this edited volume. It begins with brief working definitions of learning, literacies, opportunities, and dialogic encounters, which serve as foundational concepts for the opportunities for learning (OfL) model presented in this chapter. Then, the OfL model is presented drawing on concrete examples from City Park State Elementary School in Brisbane, Australia, and the Children’s Voices Project in South Australia. Finally, after presenting the OfL model as a provocation for the other chapters in this edited volume, the authors pose key questions for the writers in subsequent chapters to consider as they critique and extend OfL ideas in their own respective chapters.