App service employer details differ from those on ILR

It won't cause a DLOCK, because the only thing in our ILR that indicates employer, is the ERN/EDRS, which we now don't have to include, and I don't think they use at all even if we do include it. The employer details are now entirely determined by which employer they're linked to in the Apprenticeship Service. 

The Apprenticeship Service employer the apprentice is linked to, should be the one they're paid by. We have Employer DAS accounts under the person's name, but their business name is totally different (hairdressers and car garages usually). We have groups of organisations, particularly schools, where it's complicated. We ourselves have one DAS account which actually covers two organisations/PAYE schemes. As the employer, we have to make sure we pick the right one when setting up the apprentices. I don't know functionally how we did that.

I don't fully understand how it all works, and neither do the employers. Connected organisations are a real mess. We've had several employers accidentally list us as a connected organisation when they meant to just grant us permissions, you can do it to anyone!

How you record it internally is up to you. We record the registered company name and the trading name separately. EDRS were always site specific so we had one organisation per site, but since EDRS are not a thing anymore, it doesn't really matter.

Ruth Canham-James Thanks for your response. It's much appreciated, as every day seems to be a school day with some of these new scenarios we have had. 

We do have some employers that have different entries on DAS, to what is recorded in the ILR, but these tend to be small companies, who are perhaps not registered on Companies House, and yes, they haven't caused a DLock admittedly, but we also had a couple of companies that changed their trading name and as the PAYE had also changed, we had to change both sets of records to prevent any mismatch.

In this case, the holding company looks like a standalone business on Companies House, which appears to just deal with 'Activities of Head Offices', so looks like management of the payroll and PAYE etc. for the main employer, who themselves are down as a company in their own right, for their line of work, on Companies House, but look like they come under the umbrella of the first company, which is why I contacted Helpdesk to see how to record these correctly on the ILR, but their response was to say the two sets of data have to match.

On our ILR system, it will allow us to record single organisations, the Registered offices and the associated branch offices, so are you saying that we should just record as normal as 'single organisation' and let the ULN match the records up for the funding in effect, Or record the main PAYE company down as the 'Registered Office, then add the employers trading name down as being a 'branch' office (not sure if it would allow that to happen with there being two company registration numbers?)

The employer you record in your own systems only impacts on your ILR if you still happen to have an EDRS for that employer, you don't record employer name in the ILR. We have loads of apprentices where we record the EDRS as 999999999, and there is nothing else in our ILR that says which employer it is. Even when the EDRS numbers were used, there was no way to match those to the Apprenticeship Service employer data, because EDRS was per branch, but the AS employers are not. If you search PAYE in the Apps funding guide, it explains the PAYE thing. Each Apprenticeship Service account holder just has to set up the right PAYE scheme(s) in their account, and make sure each apprentice is linked to the correct one that they get paid from. Paragraph 313:

Employers must also make sure that the PAYE scheme used in the apprenticeship service account for the apprentice is linked to the National Insurance number for the apprentice declared by the provider in the ILR. Where provider data does not support the funding they have claimed, we will take action to get this corrected and could recover funds. 

I've never heard of that ever actually being checked or challenged, though one of our evidence requirements is that we checked this with the employer.

Nothing in your ILR will make any difference to employer, so you can record it however suits you. You're right that it just matches on ULN and Standard (and I guess UKPRN), to determine who the employer is for each apprentice. If you check column AL in the Apps Monthly Payment report, you'll see that it reflects the Employer/Organisation name from the Apprenticeship Service, rather than the name from the EDRS (if you even returned it) or anything you recorded internally.

It can be really confusing when we're working with an employer with one name (Playschool Name), and then the Apprenticeship Service permissions come through for a completely different name (Mrs A Smith). We just have to ask sometimes, though we do try and record the Apprenticeship Service employer name in our system somewhere, alongside the trading name/branch name.

Ruth Canham-James, thanks yet again, you're a star.

We will put the employer name down on our ILR, as we have to send electronic forms out for them to sign for enrolment etc., but we will then add a note alongside their details to state the parent company, so if we have any issues on the ILR returns, with their name on, we have a record to say which employer it relates to, but I think the fact that we have had to approach so many people for help on this, I think this one will stick in our minds!! 

Should have just come onto the forum in the first place!!