Apprenticeship off-the-job training guidance
Updated 4 August 2026
Applies to England
Introduction
1. This publication provides further information about off-the-job training. It includes the responses to frequently asked questions and has been updated to align with the 2026 to 2027 apprenticeship funding rules. If you require a previous version of this guide, please contact us.
2. This guide is for:
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providers: who manage and deliver off-the-job training and want to check they are doing so in accordance with the apprenticeship funding rules
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employers: who wish to understand the off-the-job training requirements of an apprenticeship programme in order to support their apprentice
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apprentices: who wish to have a clear understanding of the off-the-job training that they are entitled to as part of their apprenticeship
3. We hope this document is useful. If it does not answer your question, please contact the Apprenticeship Support Desk (Monday to Friday, 8am to 8pm):
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by telephone: 08000 150 600
The essentials of off-the-job training
The what
4. What is the legal definition of off-the-job training?
The Apprenticeships Regulations defines off-the-job training as ‘training, which is not on-the-job training, that is received by the apprentice, during the apprentice’s normal working hours, for the purpose of achieving the approved apprenticeship standard to which the agreement or arrangement relates’.
5. What is the definition of normal working hours?
These are hours for which the apprentice would normally be paid, excluding overtime. Overtime is excluded as it typically relates to pressures within a business and is often unplanned, therefore making it difficult to include when developing a training plan.
6. Why must off-the-job training be completed during normal working hours?
An apprenticeship is a work-based programme, the purpose of which is to support the apprentice to become occupationally competent in the workplace. It is therefore reasonable that it takes place during the apprentice’s normal working hours, away from their productive job role. It would be unfair to expect an apprentice to undertake an apprenticeship in their own time, in addition to a, potentially full-time, job role.
7. What if off-the-job training cannot be completed during normal working hours?
If off-the-job training must, by exception, take place outside of the apprentice’s normal working hours, the apprentice must agree to this and be compensated, either by time off in lieu or an additional payment. The majority of the programme must not be delivered in this way. Compensation can be confirmed as part of the progress review.
Example:
Sarah’s provider informs her and her employer of a lecture taking place on Monday evening. This will cover some content essential to Sarah’s apprenticeship. This is taking place outside of Sarah’s core hours (Monday to Friday 9 to 5). Sarah’s employer agrees that if she attends the 2 hour lecture on Monday evening, she can leave 2 hours early on Friday to make up the time.
8. If an apprentice chooses to undertake training in their own time, can this be included?
No. While some apprentices may want to study outside of their normal working hours, for their own personal reasons, this additional training must not be included as off-the-job training. Legally, off-the-job training must take place within the apprentice’s normal working hours. There must be no expectation that the apprentice will undertake any training in their own time in order to complete the apprenticeship.
9. Why is it called ‘off-the-job’ training, can it be called something else?
Off-the-job training is the term used in legislation. It is important that everyone is consistent in the terminology as calling it by another name may be confusing. For example, if employers and apprentices are asked about their experiences of off-the-job training as part of a survey, they might not understand what they are being asked about if they don’t recognise the name.
10. What is on-the-job training and how does this differ to off-the-job training?
The Apprenticeships Regulations defines on-the-job training as ‘training which is received by the apprentice for the sole purpose of enabling the apprentice to perform their work’. In other words, this is training that may be required by the employer / job role but is not required by the apprenticeship standard.
Example:
A new apprentice baker, working for a small enterprise, might need to know:
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how to use the baking equipment and machinery; and
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how to maintain and repair the baking equipment and machinery.
Training for how to use the equipment is included in the Baker apprenticeship standard so this is off-the-job training. Training for maintenance and repair is not referenced in the standard, but is a skill that the apprentice’s employer would like the individual to have. As this is needed solely for the job role, rather than the apprenticeship, this is on-the-job training and is the responsibility of the employer to provide.
11. If an apprentice learns new skills through off-the-job training and then practices these in the workplace, is this on- or off-the-job training?
It would not be on-the-job training, because the specific skill must have been required by the apprenticeship standard for it to have been included in the apprentice’s training plan to begin with. However, once the skill has been taught, and is no longer new to the apprentice, it would not be considered to be off-the-job training either. Application or practising of new skills is often regarded as supplementary activity. While the activity itself may not deliver further new skills, it seeks to apply new learning so that it becomes embedded and more intuitive to the apprentice.
Example:
A customer service apprentice is being tutored in presentations. Once the provider has delivered the training, the apprentice may practice this in the workplace. If the apprentice is on a 2 year programme and gives presentations as part of their job role, they might continue to improve each time they present. However, it’s not off-the-job training every time they give a presentation. Once the skill has been taught, it is no longer new.
What can be included?
12. What determines whether an activity is off-the-job training?
To be considered as off-the-job training, there are 4 tests. The activity must:
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teach new knowledge, skills, and behaviours
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be directly relevant to the apprenticeship standard
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take place in the apprentice’s normal working hours, and
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exclude ineligible activities (such as initial assessment and English and maths)
This checklist has been represented in a useful infographic. All training should be planned in advance and documented on the training plan.
13. What is meant by new knowledge, skills, and behaviours?
Training would be ‘new’ if there is a clear gap between the apprentice’s existing skill level, as identified in their initial assessment, and the requirements of the apprenticeship standard, which must be filled to enable the programme to be achieved. If the apprentice already has some of the knowledge, skills and behaviours required by the apprenticeship standard, this must be recognised as prior learning and discounted from the apprentice’s training plan, so that unnecessary training is not delivered again.
14. What specific activities can be included as off-the-job training?
Eligible activities include:
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the teaching of theory (for example, lectures)
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practical training (for example, shadowing, mentoring, industry visits)
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learning support
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time spent writing assignments, and
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revision
15. Why is shadowing and mentoring included?
An employer may want to deliver some of the required training and they may do this by allowing the apprentice to shadow them or by mentoring (or coaching) the apprentice on a specific topic. Provided this delivers new skills, relevant to the apprenticeship, in normal working hours, shadowing and mentoring can be considered as off-the-job training.
However, where shadowing is being used generally, to get a new member of staff up to speed, or where mentoring is being used in a pastoral sense, this is not off-the-job training, as there is no link to the content of the apprenticeship standard.
16. Why is learning support included?
To be successful, some learners may need a range of approaches and support. As well as physical adjustments or access to accessibility software, some apprentices may benefit from additional time or personal one-to-one support from their provider to help them to stay on track. This extra time can be recognised as off-the-job training, provided the activity meets the 4 tests (see question 12).
17. Why is time spent writing assignments included? Does this include compiling a portfolio of work?
New knowledge, skills, and behaviours can be developed through individual or group assignments. For example, an apprentice may learn theoretical material and be asked to produce an assignment to apply this theory to their employer or job role. They continue to learn new skills through this process. However, compiling a portfolio is not new learning as it doesn’t deliver new skills.
18. Why is revision included?
Revision is fine provided it meets the 4 tests (see question 12). However, revision must not be used to ‘pad out’ a programme to meet the minimum policy requirement. It should be planned and support the development of new knowledge and skills.
19. If the planned training (for example, first aid) is also a company requirement for all employees, can this be included?
Yes, this can be included if it meets the 4 tests (see question 12). If the activity is solely related to the job, it must not be included. The fact that the activity is a company requirement or that non-apprentices are also completing the training is irrelevant.
20. If an employer has specifically requested the inclusion of a non-mandatory qualification, can the associated training count as off-the-job training?
Yes, but only the training that overlaps with the knowledge, skills, and behaviour requirements of the apprenticeship standard.
21. Can an employer induction program, which includes a corporate induction and manual handling training, be included?
It would not be appropriate to include a generic company induction. However, some company inductions may include an educational aspect that might be relevant. For example, manual handling training might be relevant to some standards.
22. Does all off-the-job training have to be delivered in the presence of the provider?
No but all off-the-job training must be guided by the apprenticeship standard and the resulting training plan that has been agreed by all parties. If the apprentice has been set some work to do by themselves, such as an assignment, this is fine as it is still effectively being guided by the provider, even though the provider is not physically present when the activity is carried out.
23. Can an advanced level of knowledge be included, or is it only brand-new subject areas?
Some standards may require specific levels of knowledge. For example, an individual could have a basic understanding of spreadsheets, but the apprenticeship they are following may require a more advanced level. This means the individual can build on their existing skills base, to develop new skills in an area where they already have some limited knowledge.
Ultimately, whether a task is ‘new’ to an individual will come down to the initial assessment and the requirements of the apprenticeship standard. Is the training filling the gap? Note, training that goes beyond the level or requirements of the apprenticeship standard is not off-the-job training.
24. If an apprentice has recently changed job role and is now managing staff, can units from a team leading qualification be added to their training plan to support them?
No, all off-the-job training must be directly relevant to the named apprenticeship standard listed on the apprentice’s apprenticeship agreement. Some individuals might require other training, in addition to their apprenticeship, to enable them to perform aspects of their job role. This is not off-the-job training although providers may be able to support employers to address these additional needs on a commercial basis.
25. Can business meetings be included?
These are unlikely to meet the 4 tests for off-the-job training (see question 12) or be included on the training plan.
What cannot be included?
26. What specific activities cannot be included as off-the-job training?
The following must not be included as off-the job training:
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initial assessment and onboarding activities
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English and maths standalone qualifications
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progress reviews
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examinations and other on-programme testing
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training which takes place outside the apprentice’s normal working hours, and
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training that is not required by the apprenticeship
27. Why are these activities excluded?
Typically, these activities are excluded as they do not meet the 4 tests (see question 12). For example:
- initial assessment allows the provider to form an opinion of the individual’s existing skills and assess what training is needed. Onboarding is the subsequent process of agreeing the relevant paperwork. Neither meet the definition of new skills
- a progress review is a discussion rather than training. Examinations and other testing allow the apprentice to show what they have already learned at a point in time. Neither meet the definition of new skills
- training that does not take place in normal working hours does not meet the legislative definition of off-the-job training
- training that is not required by the apprenticeship is additional – this includes the delivery of skills at a higher level than that needed for the programme
28. Why are English and maths standalone qualifications excluded?
An apprenticeship is designed on the basis that an apprentice already has the required levels of English and maths. Therefore, where required, the time to undertake this training is additional to the time spent on occupational training. It would be unfair if two learners received the same time away from their productive job role and one of these learners used a high proportion of this time studying English and maths, to the detriment of any occupational upskilling they needed.
Example:
Zoe and Imran have the same employer and are working towards the same apprenticeship. Imran already has GCSEs in English and maths, but Zoe’s employer has agreed Zoe should also complete Level 2 qualifications in both, as part of her apprenticeship. Both apprentices spend the same time on off-the-job training, getting an equal opportunity to learn the occupational elements of their apprenticeship. So she is not disadvantaged, Zoe studies for Level 2 English and maths on top of this.
29. Can travel time to and from off-the-job training be included?
Generally, no. However, there may be occasions where it could be acceptable, for example if the apprentice was on a train during their normal working hours and was able to watch on-line material or work on an assignment whilst travelling.
30. If the apprentice fails their final assessment, and has to undertake further training, does this count towards off-the-job training?
No, by this point the apprentice should already have met the minimum requirements of the policy. Further training can be delivered prior to a re-sit, but this must not be included in the off-the-job training evidence.
The why
31. Why is there an off-the-job training policy?
Off-the-job training is a statutory requirement of an English apprenticeship programme and it is the vehicle that ensures the apprentice is upskilled and knows more after the programme than that they did before it. Without off-the-job training, the programme cannot be considered as a valid apprenticeship.
32. Off-the-job training is a financial burden for employers, by either losing the apprentice from the workplace or by having to backfill the role. Has this been considered?
Yes, however the training provided as part of an apprenticeship adds skills and value to the apprentice’s employer; 78% of employers state that the programme helps them to improve business productivity longer term. Before enrolling on the programme, the employer must agree with the provider that the individual requires significant training in order to be occupationally competent. They must also have agreed to release the apprentice for the training. The provider should make sure that the employer understands their role in the programme and what is required of them.
33. If the employer can no longer release the apprentice for off-the-job training, despite initially agreeing to this, does an apprentice have any rights around this?
An apprentice has the same employment rights as any other member of staff. If they are unhappy with anything related to their employment, including their apprenticeship, they should speak to their employer in the first instance. If the employer is struggling to release the apprentice due to work pressure, the provider may be able to deliver the programme in a different way or use a break in learning to temporarily pause the apprenticeship. Failing that, the apprentice must be withdrawn from the programme.
The when
34. When does off-the-job training takes place?
Off-the-job training takes place in the practical period of the apprenticeship. This is the part of the programme where training is delivered and is the period between the learning start date and the learning end date (on the Individualised Learner Record (ILR)). There must be evidenced learning on both dates. The practical period excludes any final assessment that may follow the delivery of all training. The duration of the practical period will depend on the delivery model used (see ‘what is a delivery model’) and must not be less than 8 months.
35. Why are there 2 potential apprenticeship start dates in the diagram?
The apprenticeship start date may be the same as the practical period start date, or it may be slightly earlier. The dates are usually the same when an existing member of staff, already in the job role, decides to start an apprenticeship. However, if a new person has been specifically recruited as an apprentice, this person may benefit from a few weeks in the workplace before they start their training. Their apprenticeship (job role) begins first and then their training.
This explains why there are 2 dates, an apprenticeship start date and a practical period start date, on the apprenticeship agreement and the training plan. There should not be a large gap between these 2 dates as the individual is legally an apprentice from the apprenticeship start date and could be receiving the apprenticeship rate of pay. Funding for the programme only begins when training begins.
36. What is a delivery model and what are the options?
A delivery model is a way of delivering training. Providers have a lot of expertise in designing quality programmes and can advise on the benefits of each delivery model. These models include:
- Day release:
This is where the apprentice attends off-the-job training on a regular basis, usually one day per week. This provides regular training that can be well-planned in advance. The apprentice can bring back new learning, on a piecemeal basis, to apply within the business and can balance their training with their job role.
- Block release/concentrated delivery:
This is where the apprentice may attend off-the-job training on a concentrated basis, for example one week every calendar month. This allows concentrated bursts of learning mixed with concentrated periods in the workplace.
- Front loaded model:
This is where a higher proportion of off-the-job training is concentrated in the first few months of the apprenticeship, then tapered off towards the end. This model allows apprentices to ‘hit the ground running’ and lessens the time they are out of the workplace later in the programme when they are arguably more productive.
- Mixed model:
This is where the apprentice’s off-the-job training varies throughout their apprenticeship. In some weeks or months there may be more training and in other weeks or months there may be less. This model may suit businesses with peak holiday periods where productive work may need to take priority over off-the-job training, for example retail.
37. What should be considered when discussing and agreeing a delivery model?
Providers and employers may wish to consider the following:
- the experience of apprentice: for example, will a front-loaded model help an inexperienced apprentice build confidence before entering the workplace, or will it be overwhelming, with too much information delivered in one go?
- apprentice choice: how does the apprentice prefer to learn? For example, if they were interested in full-time training, would they have chosen an apprenticeship?
- logistics: can the preferred model be resourced and delivered effectively by a provider? Does the employer have considerations such as seasonal patterns?
38. What is the active learning requirement?
The apprenticeship funding rules require that some learning be delivered at least every month (or quarter), depending on the delivery model. This is known as active learning. The purpose of this is to keep the apprentice engaged and working towards the achievement of their apprenticeship, which hopefully means they are less likely to fall behind or withdraw.
The government makes monthly payments to providers for the delivery of training, and it is right that there is a return on that investment. There is no minimum volume of active learning to take place each month (or quarter).
39. What if learning is planned but does not happen?
The funding rules give more detail on the active learning policy, including where activities are planned but don’t take place, perhaps due to sickness or holiday leave. The provider must ensure that all missed activity is re-planned, so that the full content of the training plan can still be delivered.
40. Are there any exceptions to the active learning requirement?
Yes, there is one exception. This is for apprentices with a term-time only contract. If there is no planned activity over the calendar month of August, we do not require a break in learning to be put in place for this period.
41. What happens with off-the-job training if the provider is closed for holidays?
A provider closure should not mean that training must stop. Off-the-job training can include the time spent with a provider, but it can also include any of the other activities listed in the funding rules, such as on-line learning and assignments. The apprentice must be engaged in active learning, as required, throughout their programme.
42. Does off-the-job training need to be delivered in line with the ‘typical duration’ (on the front of the apprenticeship standard)?
No, the typical duration is only a guide. Provided the statutory minimum duration of 8 months is met (for starts after 1 August 2025), the programme can be any length and use any delivery model. However, it’s important to understand that if a duration is compressed, more training per week may need to be delivered.
43. Does the training content need to be delivered in a particular order?
No, the provider has the flexibility to sequence the curriculum in any way they choose. However, sequencing rationale may be of interest to Ofsted.
The where
44. Where should off-the-job training take place?
Off-the-job training must be away from the productive job role, but this doesn’t mean it must be away from the workplace; training can take place at the employer’s premises and even at the apprentice’s normal workstation. Training can also take place off-site, (for example, in a provider classroom), or from home (using online/distance learning). Ultimately, it is the activity, rather than the location, which determines whether it meets the definition of off-the-job training.
45. Can a live environment be used for off-the-job training?
Off-the-job training must be separate from the productive job role. However, a live environment is sometimes required to check transferability of knowledge. For example, it would be difficult for an apprentice bus driver to be considered competent without considering their interaction with passengers. For specific scenarios we would suggest that the provider or employer sends an outline to the Apprenticeship Support Desk, to include how, and how often, a live environment would be used. A live environment must not be used for all off-the-job training, as this would mean the apprentice is essentially still performing their productive job role for their employer and is not being released for training.
The who
46. Who is responsible for the delivery of off-the-job training?
The organisation being funded (usually a provider) is responsible for the delivery and evidencing of all required off-the-job training, to enable the apprentice to reach full occupational competence against the standard, even if another party (for example the employer or another provider) delivers some of the training as a subcontractor. When the initial training plan is prepared, the provider and employer must agree who will deliver the content.
47. Is all employer delivery regarded as subcontracting?
This will depend on whether apprenticeship funding is being accessed. If the employer is accessing apprenticeship funding, they are a subcontractor of the main provider and the subcontracting rules apply, including the requirement to be on the Apprenticeship Provider and Assessment Register (APAR), unless an exemption applies. If the employer is not accessing apprenticeship funding, they are not considered to be a subcontractor and there is no APAR requirement.
Employers who are delivering off-the-job training for a fee must work to actual costs; employers must not make a profit from apprenticeship delivery to their own staff. If the employer is not charging a fee for their delivery, the provider and employer must agree if it is appropriate for the cost of this delivery to be included in the funding that the provider receives.
The how
48. How can off-the-job training be delivered?
It is up to the provider and the employer to decide how off-the-job training is delivered and they should take note of the type of activities listed in the funding rules that can and cannot be included as off-the-job training. As individuals have different learning preferences, good off-the-job training should have more than one delivery method, for example a combination of face-to-face delivery with some on-line learning and assignments.
49. Can all off-the-job training be delivered via online learning?
There are two types of online learning: self-directed and interactive. Self-directed online learning is where the apprentice is working on their own with no real-time support. Interactive online learning (often called a virtual classroom) is where the learner can receive real-time support from a provider. An apprenticeship must not be delivered solely by self-directed online learning. This would make for a poor learning experience for the apprentice, as the learning is not supported in real-time by the provider and there is no opportunity to ask questions or to receive feedback.
Example:
Ayo is employed as an apprentice software development technician. Most of his job is desk-based. He has a suite of on-demand learning available to him, including high-quality videos, quizzes, case studies, and external resources.
He learns at his own pace and has the flexibility to use quieter work periods to access this distance learning. His self-directed online learning is supported by face-to-face learning at his provider, so he can get feedback and support on how he is progressing. His online learning is automatically logged, so his provider can monitor progress and evidence his training. Registers are used when he attends in person.
Recognition of prior learning
50. What is recognition of prior learning and why is it important?
Recognition of prior learning is part of the initial assessment of the apprentice, carried out at the start of the programme. The provider must identify and document any knowledge, skills, and behaviours, relevant to the apprenticeship standard, gained from the following:
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prior education, training, or qualifications in a related subject sector area, including any previous apprenticeship undertaken; or
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learning or competence gained from prior work experience, particularly where the apprentice is an existing employee, or is beginning their apprenticeship after completing another programme with a relevant work placement
By recognising prior learning, providers can reduce the content and the price of the apprenticeship. This helps them to deliver appropriately tailored content rather than repeating learning. Tailored content is more likely to be engaging for apprentices, and lead to higher retention and achievement rates, and onward progression.
The resulting apprenticeship, once prior learning has been recognised, must meet the funding rules in relation to the minimum duration and off-the-job training. No programme must require less than 187 hours of off-the-job training.
51. Why does the content and price need to reduce?
The content is reduced so that the apprentice does not repeat training that they do not need. If the employer still wants their apprentice to attend sessions identified for removal, this is fine provided that apprenticeship funding is not being used for this delivery and the time does not count towards the off-the-job training hours.
The price is reduced so that apprenticeship funding is not used to pay for training that the apprentice already has or does not need. The funding rules outline in more detail how the price must be reduced. The full funding band must not be used where prior learning has been recognised.
There is additional guidance on the recognition of prior learning, which may be helpful.
The minimum policy requirement
Starts to 31 July 2025 (previous off-the-job training policy)
52. What was the minimum policy entitlement for an apprentice who originally started their training up to and including 31 July 2025?
To be eligible for government funding, the minimum requirement was that an apprentice had to spend at least 20% of their normal working hours (capped at 30 hours per week for funding purposes only), over the planned duration of the apprenticeship practical period, on off-the-job training.
This percentage was chosen because, when the policy was originally designed, 20% broadly equated to one day per week and, at the time, the majority of apprenticeships were delivered on a day release basis. The minimum policy requirement of 20% applied to all levels of apprenticeship.
53. Why were the normal working hours capped at 30 hours (for funding purposes)?
A 30-hour working week (introduced in August 2022) was used for all apprentices, even if the apprentice worked more hours per week for their employer. This was so all apprentices were treated equally. Prior to this, the policy used the apprentice’s own working hours to calculate the off-the-job training requirement. However, this disadvantaged apprentices who worked in sectors with above average working hours.
54. What did the minimum policy requirement mean in terms of training hours?
This varied, depending on the duration of the programme. For a 12-month apprenticeship the minimum was 278 hours. The table below shows some different durations. Note that as the duration increased, the off-the-job (OTJ) training requirement increased.
| Example calculations (minimum OTJ requirement) | |||
|---|---|---|---|
| Weeks duration (use rounded number) | 52 weeks (12 months) | 78 weeks (18 months) | 121 weeks (28 months) |
| Less statutory leave (5.6 weeks per 52 weeks) | 5.6 | 8.4 | 13 |
| Training weeks for OTJT | 46.4 | 69.6 | 108 |
| Multiplied by 6 hours | 278.4 | 417.6 | 648 |
| OTJ minimum (rounded) | 278 | 418 | 648 |
A calculator is available on the off-the-job training page to help providers test if their programme is compliant against the previous policy. Note, the table and the calculator only show the minimum requirement. A higher delivery volume may have been necessary to enable some apprentices to reach full occupational competency.
55. Why was statutory leave used, rather than the apprentice’s own annual leave?
This was so a consistent calculation could be applied to all apprentices, to establish if the minimum off-the-job training requirement was being met. The requirement to deduct statutory leave was introduced in the 2018 to 2019 apprenticeship funding rules.
56. Where did the 6 hours per week come from?
A 30-hour working week was used in the calculation for all apprentices. The minimum policy requirement was 20%, and 20% of 30 hours equated to 6 hours per week.
57. What if the apprentice did not need the minimum policy requirement?
If an individual did not need the minimum policy requirement (for example 278 hours for a 12-month programme), or their evidenced delivery was less than the required amount, they were not eligible for apprenticeship funding.
58. What was the minimum requirement for a part time apprentice?
If an individual worked less than 30 hours per week, they were considered to be a part-time apprentice. Overall, the volume of off-the-job training delivered to a part-time apprentice was no less that that delivered to a full-time apprentice; however less training was delivered on average per week, over an extended period. The apprenticeship funding rules outlined how to adjust the duration for this cohort.
59. What was the minimum requirement for a term-time only apprentice (for example, a teacher delivering for 39 contact weeks)?
If the term-time only contract was full-time, and the apprentice got paid every month, off-the-job training was calculated as though the apprentice was working 52 weeks per year. The training was then typically delivered across the 39 contact weeks, although this usually meant delivering more than an average of 6 hours of training per week.
60. Could an apprentice finish their programme early if all training had been delivered?
Yes, any apprentice (full- or part-time) could finish earlier than their learning planned end date, provided they had met the relevant minimum duration (12 months for the previous policy) and the off-the-job training requirement. The off-the-job training requirement applied to the shorter (actual) duration.
61. What happened if the learner went past their learning planned end date? Was off-the-job training increased to cover the new actual duration?
No. When the training plan was originally prepared, if all parties agreed that, for example 400 hours of off-the-job training was needed over a particular duration, for the apprentice to achieve occupational competence, then assuming the learner’s circumstances had not changed, 400 hours of training would still be needed.
The provider was responsible for updating the dates on the training plan and apprenticeship agreement. They did not amend the learning planned end date or the planned hours field on the ILR; this information stayed the same to reflect the day one circumstances of the individual.
62. What happened where the planned off-the-job training hours were complete, but the final assessment was delayed; did the provider have to continue to deliver training?
No, once all the training was complete, the practical period was also complete. The apprentice stayed on programme; they were not withdrawn or put on a break in learning as this would have stopped them from restarting at a later date, just to undertake the assessment (this was because the ILR requires there to be learning).
Starts from 1 August 2025 (current off-the-job training policy)
63. How has the off-the-job policy changed for new starts from 1 August 2025?
There are 3 key changes:
- a minimum volume of off-the-job training hours has been published for each apprenticeship standard, which replaces the need for the provider to calculate the minimum requirement based on a percentage of the apprentice’s duration. To be eligible for government funding an apprentice, with no relevant prior learning, must receive at least the published volume of off-the-job training hours for the standard, or a reduced figure for evidenced prior learning
- the delivery link between off-the-job training and duration has been removed, giving providers the flexibility to deliver the required training hours over any duration, subject to meeting the minimum duration requirement of 8 months. The volume of training is no longer impacted by an increase or decrease in duration
- providers no longer need to automatically extend the duration for part-time apprentices, although they should consider the working hours so that training expectations are realistic
Carry-in learners, and those returning from a break in learning, are not impacted by this new policy if they originally started before 1 August 2025. These learners will continue to follow the previous version of the policy.
64. Why did the policy change?
The previous policy was 8 years old and developed at a time when the programme looked quite different. Delivery was mostly at level 2 and 3, and the programme was largely delivered on a day release basis by independent training providers and colleges. There is now a wider range of programme levels, a different mix of providers and a variety of delivery models (such as block release and front loading).
The statutory minimum duration of the programme also changed, from 12 months to 8 months, for new starts from 1 August 2025. If the existing policy wording, based on a percentage of the duration, had been carried forward this would have lowered the minimum threshold from 278 hours to 187 hours (187 hours is 20% of 8 months). Accepting 91 hours less, for example where a 12-month programme was compressed into an 8-month programme, was not considered to be appropriate when the content and funding of the standard were not changing.
Off-the-job training was also one of the biggest areas of non-compliance in a funding audit and often this was linked to calculating the minimum requirement needed to meet the policy threshold or evidencing that training had taken place. In simplifying the policy, by providing an actual volume of hours needed to be compliant, and removing the link to the duration, the aim was to significantly reduce provider administration, increase delivery flexibility and lead to fewer audit errors.
65. How was the new minimum requirement set for each apprenticeship standard?
Actual delivery data submitted by providers was used (2023/24 R14 individual learner record). The data only considered completers who had no prior learning. Where there was an average (median) actual off-the-job training hours value for the standard, the new minimum requirement was set slightly below this, so that the standard could continue to be deliverable by all providers. The median was used because there were outliers in the data.
For example, for ST0006 Level 3 Lead Adult Care Worker, the data showed that on average 432 hours of training were delivered to apprentices, with no prior learning, who completed this standard. Therefore, the new minimum requirement was set at 370 hours, in recognition that some providers would have delivered below average.
66. Why was the minimum requirement set below average?
Changing from the previous 20% of duration policy was a significant change, so a cautious approach to the initial setting of the new minimum requirement was adopted. Over time the minimum requirement may need to be increased, for example, as new delivery data is considered (see question 70).
67. What if there was no completer information for a standard?
In the absence of any completer information, the minimum requirement was set using a percentage (75%) of the typical duration for the standard and the historical off-the-job training equivalent. For example, ST1398 Level 6 Machine Learning Engineer has a typical duration of 24 months. 75% of this is 18 months and 20% of 18 months is 418 hours. So, this was the initial minimum requirement for this standard.
68. How were the new minimum requirements communicated to the sector?
The minimum requirement is now published on the front of each apprenticeship standard. However, all of the minimum requirements were initially published together, in May 2025, in an annex to the 2025 to 2026 the apprenticeship funding rules.
To give some providers time to adjust their curriculums to meet the new requirements, a transition period for 73 standards was introduced. This applied to starts between 1 August and 31 December 2025. During this transition period the minimum requirement was temporarily reduced. The transition period ended on 1 January 2026.
69. How does recognition of prior learning work with the new minimum requirement?
If there is evidence of relevant prior learning, then the minimum requirement can be reduced accordingly. For example, if the published figure is 300 hours and there is evidence of 50 hours of prior learning, the new minimum requirement for that learner and standard would be 250 hours. A non-compliant programme is one with less than 187 hours of training. Recognition of prior learning must not bring the required hours below that new baseline.
70. If a provider delivers far in excess of the minimum requirement for a particular standard, is that wrong; do they need to scale back delivery?
No, this is a new policy and a new way of approaching off-the-job training, and a level of caution was initially exercised in setting the minimum requirements. It’s no surprise that many providers are delivering more than the minimum.
It may be that the minimum requirements for some standards have initially been set too low and do need to increase, either in line with refreshed delivery information or with how the standard is being funded. However, affected providers and sector representatives will be consulted if hours do need to increase and adequate notice of any increase will be given. A change to the hours will be identified by changing the version number of the standard.
71. If a provider feels the minimum requirement is not deliverable, what can they do?
As the minimum requirements have been set below average delivery, they are considered to be fair. If a provider feels they are unable to deliver the minimum requirement it may be useful for them to look at their delivery model and talk to other providers who are delivering the same standard. Ultimately the provider will need to decide whether to continue to offer the standard.
72. Why do similar standards, either at the same level or the same funding band, have different minimum requirements?
While it might seem logical to align levels, funding bands, and minimum requirements (for example all Level 2 standards, or all standards in the £7,000 funding band, should require the same off-the-job training hours), in reality there are a number of variables to consider. First, the funding band is not just about the cost of delivery; some standards have expensive materials factored into their price. Second, differing amounts of off-the-job training have been factored into some standards at the design stage (for example, the teaching standard was designed to have 40% off-the-job training). Third, ILR information (actual hours) was used to set the minimum requirement, and different delivery models have resulted in a wide range of delivery hours being reported, for the same standard. That delivery variance has essentially carried forward into the revised policy.
73. Why has the delivery link between the OTJT hours and duration been removed?
This allows for maximum flexibility in the delivery of the programme. In the previous policy, if the duration of the programme increased, the off-the-job training requirement also increased. For example, a learner on a 12-month programme required at least 278 hours of evidenced training, whereas a learner on a 14-month programme required at least 326 hours of evidenced training.
By removing the link, providers can deliver the required training over whatever duration is appropriate, subject to meeting the minimum duration. The volume of training is no longer impacted by an increase or decrease in duration. For example, 278 hours can be delivered in 12 months at an average of 6 hours per week; it can also be delivered in 8 months at an average of 9 hours per week. A look up table has been developed to illustrate how the same volume of hours can be delivered over a variety of durations.
Documenting the off-the-job training
74. Why does off-the-job training need to be documented?
Documenting off-the-job training is important because there must be a shared understanding by the provider, employer, and apprentice, of the volume and content of training that is going to be delivered.
75. Where do the planned off-the-job training hours need to be documented?
After being adjusted for prior learning, the planned hours are documented on:
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the apprenticeship agreement
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the training plan
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the ILR
The figure used at the beginning of the programme should be the same across all 3 documents. If the volume of off-the-job training changes during the course of the programme, the apprenticeship agreement and the training plan must be updated to reflect the latest information. The planned hours figure on the ILR does not get updated as the ILR is designed to reflect the day 1 position of the apprentice.
76. Where do the actual off-the-job training hours need to be documented?
When the apprentice leaves the programme, either as a completer or early leaver, the provider must document the volume of actual hours delivered on the ILR. This figure should correspond with the evidence of training that is held for that apprentice.
77. What is the purpose of the apprenticeship agreement?
The Apprenticeships, Skills, Children and Learning Act 2009 requires an apprenticeship agreement. It is completed and signed by the apprentice and the employer and forms part of the individual employment arrangements between these 2 parties. The provider may need to support the employer to complete the apprenticeship agreement correctly and they need to keep a copy of it.
A valid apprenticeship agreement has the status of a contract of service, to which employment law applies. An apprenticeship programme cannot be funded unless there is a valid (complete) apprenticeship agreement in place (where one is required). The agreement must be extended if the apprenticeship programme is extended. With regards to off-the-job training, the apprenticeship agreement sets out the employer’s commitment to release the individual for the hours specified.
78. What is the purpose of the training plan?
The training plan sets out the training to be delivered and the commitment of all three parties (provider, employer, and apprentice) to the programme. It can also be used to record key details such as the employer’s agreement to release the apprentice for their off-the-job training. The apprenticeship funding rules detail what information is required, and all parties must keep a current signed and dated version. The training plan is a working document and must be amended if required. Anyone picking up the apprentice’s training plan should be able to understand what is going to be delivered to the apprentice and where the apprentice is in relation to their plan.
There is a training plan template which is non-mandatory but compliant with the funding rules. Providers are free to adapt this online version or use an alternative.
79. Can the training plan be combined with the apprenticeship agreement?
No, these documents serve different purposes. The apprenticeship agreement is a legal agreement between the employer and apprentice and forms part of the individual employment arrangements between these two parties. The training plan is a three-way agreement, between the provider, employer, and the apprentice.
80. What is the purpose of the ILR?
The purpose of the ILR is to act as an ongoing data collection system used to calculate funding and monitor provider performance.
81. How is the planned and actual off-the-job training hours data used?
The off-the-job training policy is the cornerstone of the programme, and it is important that each apprentice receives the right amount of off-the-job training that they need and are entitled to. Data is used to provide visibility of the training being delivered, to check compliance with the policy and also to provide intelligence for new products.
82. When entering the planned or actual hours on the ILR, is this for the full programme or just that academic year?
The planned hours and actual hours are for the full programme.
83. Should providers wait until the apprentice has completed their final assessment to input actual off-the-job training hours, in case more training is needed?
Providers must enter the actual hours at the end of the practical period once they are confident that all training delivery is complete. This is prior to any final assessment. If an apprentice fails their final assessment and additional learning is required, this does not get added to either the planned or actual hours information as the policy should already have been met by this point.
Evidencing off-the-job training
84. Whose role is it to evidence off-the-job training?
The provider being funded is ultimately responsible for the evidencing of off-the job training, even where another party has delivered the training. It is this provider that will have action taken against them if non-compliance is found, so it is in their interests that all evidence is collected in a timely manner. This provider may wish to use the progress review to collect evidence from other parties. For example, some learners keep learning logs for tasks the provider has set them, such as assignments, and they keep a record of their time in a learning log.
85. What should the evidence look like?
Off-the-job training is a quantitative, rather than a qualitative, policy. This is why the funding rules say that all delivery evidence must be quantifiable, in the form of a number of hours, and must meet the definition of off-the-job training. As well as the evidence of delivery it’s important that the volume of planned and actual hours is correct, that prior learning has been applied correctly and that any differences between planned and actual hours are explained in line with the funding rules.
86. How does evidencing actual off-the-job training hours prove that this time has been spent in good quality learning?
It doesn’t; a funding audit only assesses the use of public funding against the requirements of the funding rules. Auditors will check the quantity of training and that it meets the published definition, but they will not pass judgement on the quality or appropriateness of delivery. The quality of training delivery is important, but this for bodies such as Ofsted to make a judgement on.
87. Is it easy to check if an activity meets the evidence requirements of the funding rules?
Yes, the evidence should meet the 4 tests (see question 12). It must show that:
- it was directly relevant
- it was new knowledge, skills, and behaviours
- it took place in the apprentice’s normal working hours
- it was an eligible activity
If the evidence doesn’t support this, it needs to be revisited. There is a simple evidence collection template online which records the basic information required, such as the volume of hours and what those hours broadly relate to, alongside key statements to verify the training was new, relevant, and carried out during normal working hours.
Providers may wish to keep additional information about the learner’s journey and their work for other purposes (for example, Ofsted inspections). However, it’s important to recognise that this sits outside of the off-the-job training evidence requirements outlined in the apprenticeship funding rules.
88. Does off-the-job training evidence need to include a specific date and time?
A funding auditor will need to know if the training took place in normal working hours. If the evidence was more general, for example ‘20 hours off-the-job training in August 2026’, they would not know if this was outside of the apprentice’s normal working hours. Including times also enables the auditor to check hours have been calculated correctly. As a cross-check, the evidence form should include key statements to support the policy, for example that all learning was new.
89. Does the evidence need to be paper-based, or can it be online?
The format of the evidence is not stipulated in the apprenticeship funding rules. Electronic evidence, including electronic/digital signatures, is acceptable. Where evidence is electronic, providers must have wider systems in place to assure that apprentices exist and are eligible for funds. Where an electronic or digital signature is being held, providers must ensure it is irrefutable. Systems and processes must be in place to provide assurance that the original signature has not been altered.
90. Can the evidence for the actual hours field come from the hours logged by an apprentice on an MI or e-portfolio system?
The evidence for the actual hours field must correspond with the total volume of training undertaken by the apprentice. If this is being administered by a third-party MI or e-portfolio system, this is fine, provided all evidence is quantitative and shows it meets the definition of off-the-job training.
91. Where an apprentice is undertaking their daily responsibilities but are not yet fully competent, can their working hours be claimed as off-the-job training?
No, off-the-job training is separate from the apprentice’s productive day job. The only hours that can be recorded as off-the-job training are those which meet the 4 tests, are planned and included on the apprentice’s training plan. The apprentice’s time at work, including any on-the-job training delivered by the employer, must be excluded.
92. Once all training has been delivered, if the actual off-the-job training hours delivered is less than the original volume of planned hours, what must the provider do?
The provider must produce a statement for the employer and apprentice to sign. The funding rules outline the information to include. This includes a check to confirm that despite delivering less, what has been delivered still meets the off-the-job training minimum requirement for the apprenticeship standard.
For example, the published minimum requirement is 500 hours, but the provider plans to deliver 700 hours. This is agreed with the employer and apprentice and documented in the training plan. The provider delivers 550 hours. The programme is compliant but it’s still 150 hours less than what was agreed so a statement is required to confirm the employer and apprentice are happy that all training has been delivered. If the employer will not sign the statement, this may indicate they do not believe the quantity of training was sufficient. Funds may be at risk of recovery.
Compliance and audit activity
93. What is a funding audit?
A funding audit provides assurance that all funding paid to providers is based on accurate and complete ILR data and is in accordance with the funding policy and guidance provided. The audit seeks to provide reasonable assurance that there is no mis-statement in the provider’s earnings. It will select a random sample of apprenticeship records and will review all the evidence to support the ILR data submitted, including off-the-job training data. Where the review identifies that funding has been claimed in error it will be recovered where possible.
94. Why does off-the-job training play such a big part in a funding audit?
The Department for Work and Pensions is accountable to Parliament for the apprenticeship budget. They have a duty to safeguard and manage funding in line with the principles set out in managing public money. Off-the-job training is monitored very closely, through the program of funding audits and other compliance activity, because this is the biggest cost in the apprenticeship programme.
To establish compliance with the funding rules, an auditor will expect to see:
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a planned off-the-job training hours value, which is at least equal to, but can be more than, the minimum requirement if the learner has no prior learning or an adjusted figure (and price) to account for relevant and evidenced prior learning as highlighted by the initial assessment
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an appropriate duration in which to deliver the required hours and relevant documentation of the planned hours – this includes a description of the delivery model in the training plan and a compliant plan for active learning
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evidence that delivery has taken place against the training plan and that appropriate records are available. All evidence must meet the definition, and the activities must be eligible activities. The volume of evidence must correspond with the actual hours documented on the ILR and where there is a difference between planned and actual a signed statement must be available to explain the difference
Failure to meet the minimum requirements of the off-the-job training policy will result in a 100% clawback of funding so it is important to ensure that an individual needs that level of training in the first place and a compliant amount is delivered, regardless of interruption, absence, or other reason.
95. How can providers check their own compliance with the policy?
A number of tools are provided to help providers check their own compliance. As well as this guide and the accompanying documents and templates on the off-the-job training page of GOV.UK, providers can also use the Provider Data Self-Assessment Toolkit reports to check their own data and identify any potential issues for checking and correction.
For apprentices working to the previous off-the-job training policy there is a calculator online, which can be used to check that an apprentice’s off-the-job training meets the minimum requirement, based on their planned duration and normal working hours.
96. What will happen if an error is identified at audit?
Following the completion of an audit, the auditor will collate and evaluate any identified errors, including those that relate to off-the-job training. They will provide feedback to the provider including ways to resolve the issues. This might include adjustments to the ILR. If a data adjustment to the ILR is required, the provider must make the necessary data adjustment in time for the next scheduled data return.
A funding error may be identified as a ring-fenced error. This is where other learners share the same characteristics and, for these type of errors, further testing of the sub-population is carried out, either by the auditor or by the provider.
Most errors that relate to off-the-job training will relate to paperwork and will not be remedied through the ILR. The provider will be given the opportunity to correct paperwork, where it is appropriate to do so. If the nature of the error is one of evidence, or rather a lack of evidence, again the provider will be given the opportunity, where it is practical to do so, to provide additional information to show that the apprentice is on track to receive the training as documented in the training plan. The provider is responsible for obtaining any missing evidence. Sanctions for non-compliance include the recovery of funds.
97. Are there any other compliance activities undertaken, beyond a funding audit?
Desk-based compliance activity using off-the-job data from the ILR may be undertaken. If a provider is selected as part of these compliance checks, they will be required to submit evidence to support the volume claims made in the ILR. Providers may be required to take further action if evidence of non-compliance is found.
Impact of a change of circumstance
98. What happens if there is a change of provider?
Ideally there would be a transfer of apprentice information from Provider A to Provider B. Provider A must record the actual hours of off-the-job training for anyone leaving their programme, including an early leaver, and must retain evidence of delivery, so this information should be available.
However, where this doesn’t happen, Provider B must assess how much training the apprentice has had to date and develop a training plan based on what is still needed. Provider B would not be held accountable for the actions (or inactions) of Provider A, but any unusual circumstances (for example, no or little training delivered by Provider A) should be reported so that this matter can be explored with the relevant party.
99. What happens if there is a change of employer?
If an apprentice changes from Employer A to Employer B, and the new employer agrees to support the apprenticeship, the provider must update the ILR and the training plan with Employer B’s details. Employer B must also sign, with the apprentice, a new apprenticeship agreement for the remainder of the apprenticeship. The provider must make sure that the off-the-job training hours, across the two employers, meets the minimum policy requirement and, as the provider hasn’t changed, this should be relatively straightforward.
The apprentice can continue their off-the-job training during the transition from Employer A to Employer B, provided the transition is complete within 4 weeks. If the transition is not complete by this point the apprentice can be put on a break in learning for up to 8 weeks before being withdrawn from the programme. They can restart at a future date. Off-the job training should not be delivered during the break in learning or after the apprentice has been withdrawn.
100. What happens if the apprentice wants to change their apprenticeship standard?
It is possible to change to another apprenticeship standard, for example if the apprentice has changed job role. However, the individual would effectively be withdrawing from the first apprenticeship without completing and starting a second one from the beginning. As such, they would need to re-establish eligibility. This includes whether they require enough training to meet the minimum duration and off-the-job training policies, after any prior learning has been considered.
101. What happens if there is an increase or decrease in the apprentice’s working hours?
Where this happens, the most common query is whether this impacts the volume of off-the-job training required. Against both the old and new policy, the answer to this is no. Against the old policy, what was originally agreed at the beginning would continue to be accepted. Against the new policy, the minimum requirement is not impacted by the learner’s hours or the duration of the programme.
However, as off-the-job training must be delivered in normal working hours, there is a practical element to consider, especially if the apprentice’s hours have been substantially reduced. Can the apprentice still attend the training as originally planned or does the plan need to be adjusted?
102. What happens if an apprentice goes on parental leave?
An apprentice can either go on a break in learning for the full length of their planned leave or, if they are close to completing the programme and don’t want to take an extended period of absence, they could use their statutory keep in touch (KIT) days to continue with the programme. Where KIT days are used, the apprentice, provider and employer must complete an agreement, and the funding rules outline what this must include. Note that if the apprentice is not going on a break in learning, they are still considered to be on programme and therefore the active learning policy applies. This may influence when KIT days are taken.
Only the training activity carried out on the KIT day can be recognised as off-the-job training. At all other times during a period of parental leave, the individual is not working, which means that off-the-job training cannot be recognised (as off-the-job training can only take place during normal working hours). The other thing to consider is that while the apprentice is on parental leave, they are not getting the opportunity to apply and embed the new skills they are learning into their productive job role, which could impact their overall chance of success.
103. What happens if an apprentice is made redundant?
If the apprentice is made redundant, and assuming it is still possible to deliver the training, funding support is provided for up to 12 weeks, to allow off-the-job training to continue while the apprentice looks for another job. The programme may be funded to completion in certain circumstances; namely if the apprentice has either completed at least 75% of the training or they are within 6 months of their final day of training.
104. What happens if an apprentice is put on a break in learning?
While the apprentice is on a break in learning, they must not undertake off-the-job training. When the apprentice returns from the break, the employer must re-plan the learning and revise the end-dates in the apprenticeship agreement and training plan.