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I don't think it's clear, and so I'd do the same as you and err on the side of caution. I'd quote this to the employer:
185. Where there is a change of employer, and the apprenticeship originally started prior to 1 April 2024, then the co-investment waiver will no longer apply meaning the new employer will be liable to pay co-investment (regardless of the apprentice’s age at the time (this also covers where an apprenticeship re-starts with a new employer)).
But I'd also say that we'll refund if we discover that DfE have fully funded it. It definitely isn't fair to the new employer if they can't get the waiver. I'd code it as if we were expecting the small employer waiver, and see what happens in the month end reports! The number of things I've only learnt by putting the data in and seeing what happened, because the guidance just didn't say, it a bit of a concern. That's why this forum is great as we can share what we've found out 😊
Hey ya,
I really cannot get my head around this one, I've also gone to the help desk, had several replies and one where they copied a reply from the specialist funding team which said exactly that. Given current policy it makes NO sense at all.
This is the reply i got..
"Thank you for contacting the Apprenticeship Service Support Team, my name is Michael. I understand from your email you would like some clarification on a change within the funding rules.
A similar query was raised to our Specialist Support Team who responded with the below.
The policy on who is eligible for the employer co-investment waiver changed on 1 April 2024; meaning the previous waiver which was determined by apprentice age and size of employer (i.e. number of employees) no longer exists. Therefore, only starts that occurred prior to this date who remain with their current employer are eligible for this waiver.
The new criteria, for the co-investment waiver, is only applicable for new starts from 1 April 2024.
Where an apprentice changes employer & remains on the same apprenticeship, this is classed as a continuous learner (even if there is a break between leaving their original employer and starting with their new employer) – it is not classed as a 'new' start.
When determining eligibility for the co-investment waiver we will look at the original start date of the apprenticeship training. Therefore, if the apprenticeship training started prior to 1 April 2024, then no co-investment waiver will be applied & the new employer will be liable to pay co-investment."
Thoughts?
Thanks Ruth, i still think they making it confusing, they are getting co-investment waiver mixed up with Extra support for small employers (for those continuous starts pre april 2024. I'm going back to them and will see if i manage to get somewhere. The 2025_2026 funding rules have made it really confusing with this, this came into force in February 2025 from what i can see.
Wayne Hosking The guidance does specifically say:
187. Where there is a change of employer, and the apprenticeship originally started prior to 1 April 2024, then the co-investment waiver will no longer apply meaning the new employer will be liable to pay co-investment (regardless of the apprentice’s age at the time (this also covers where an apprenticeship re-starts with a new employer)).
The reply you got does match that. It's not the additional payments (which I think you can still get). This was included in the 24/25 rules (paragraph 161) but it wasn't clear in the 23/24 guidance.
Hello,
Just to add to the confusion—and possibly a sign that I’m struggling to keep up with the pace of change—I’ve come across the following scenario.
I have two apprentices who started prior to 1 April 2024. At the start of their programmes there was no co‑investment waiver, as they were aged 18 and employed by a 50+ employer. They have since changed employer to a non‑levy employer and are now aged 20, and it appears that co‑investment is no longer required - they are not showing up on my co-investment report.
This seems to be in line with the guidance below:
183.1. Employers who do not pay the levy, where at the start of the apprenticeship training the apprentice is aged between 16 and 21 years old (or 15 if the apprentice’s 16th birthday is between the last Friday of June and 31 August).
Unfortunately, contracts have already been issued including co‑investment charges, which will now need to be amended.
White flag being flown
Hi Christina,
I have been on my soapbox on this one as I don't like what the DfE have done with the rules but after several conversations and help desk queries. The conclusion is there is a co funded fee due, if you look at the small employer ILR tick box in conjunction with the funding rules and Apprenticeship technical funding and apprenticeship funding rules P187 guidance it does confirm this.
ILR Specification 2025 to 2026: Attribute: Small Employer
"You only need to record this field for starts up to and including 31 March 2024. You must not record this field for new starts from 1 April 2024, or where there is a change of employer and the apprenticeship originally started prior to 1 April 2024". Those coming under this were only ever 16 to 18 small employers.
Apprenticeship technical funding guide from August 2025 - GOV.UK
"a) where there is a change of employer, and the apprenticeship originally started prior to 1 April 2024, then the co-investment waiver will no longer apply meaning the new employer will be liable to pay co-investment (regardless of the apprentice’s age at the time (this also covers where an apprenticeship re-starts with a new employer))."
So, in your case, they are classed as 18 as that was the age when they started, they worked for an over 50 company which meant there was a co funded fee. Now they are changing employer and working for a small company, they are still classed as 18 but given the rules now stipulate you must not put the small employer tick box down then they will be due a fee. I'm assuming if you don't tick small employer then they should come up onto the co investment report if the learner has been set to the co funding indicator.
I don't like the policy, I still feel their technical funding guidance should be clearer under the section 6.1 to also clarify if a learner changes employer in the future then there would be a fee due if they originally came under small employer exemption as that section still talks about new starts.
That's my take on the current policy
Kind regards
Wayne
Cassie Adams-Wood
16-18 Co-investment Waiver - Change of Employer
Created
Hi all
Has anyone been able to get their heads around the the co-investment waiver when learner who was 16-18 from start and started before 1st April 2024 has now changed employer? Or got a decent answer from the DfE.
There's few different threads I've seen questioning it and upon reading the updated Technical funding guide it's still confusing.
The way I read it, it would suggest we'd still apply the old fewer than 50 employers rule for starts up to 31 March 2024 for those 16-18 at the start. But if they end up being more this would be where the waiver would no longer apply. The only thing is the updated guide does not mention Change of employer in that section.
6.1 Extra support for small employers for starts up to 31 March 2024
For starts up to and including 31 March 2024, we will waive the co-investment requirement for employers with fewer than 50 employees if the apprentice, at the start of their apprenticeship training, is a 16- to 18-year-old or an eligible 19- to 24-year-old as described in the apprenticeship funding rules. Where the employer is eligible for the co-investment waiver and pays the levy, we will not use their employer account funds.
We will pay 100% of the total price for these individuals, up to the maximum value of the funding band. You must identify the employers with fewer than 50 employees as a ‘Small employer’ (SEM) using the ‘Employment status monitoring’ fields in the ILR. You only need to record this field for starts up to and including 31 March 2024. You must not record this field for new starts from 1 April 2024.
We determine whether we waive co-investment from the size of the employer at the start of the apprentice’s programme; this determines whether we waive co-investment for the rest of the apprenticeship with that employer.
We will continue to waive the co-investment if the employer grows to 50+ employees after the start of the apprenticeship as we base the eligibility for the waiver on the status at the start of the apprenticeship with that employer.
We will not apply this waiver to new starts after 31 March 2024.
I have a scenario where a learner is moving employers (unsure if Levy or non-levy yet) and they are currently 19 but were 17 at the start of their apprenticeship. To me it makes sense to apply the old rule for this but the wording for the updated waiver for new 1st April 2024 suggests otherwise. Would seem unfair that the co-investment waiver would apply originally but not now.
For now I am cautioning on the safe side and quoting that any employer change in this situation has a co-investment to pay. Better to say they have something to pay, then find they later don't rather than the other way around.
Would like to know others thoughts on this.
Thanks