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darren.oneill

Application of Funding Rules 26/27 Para 96 for Early Completions

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We are looking for clarification regarding the application of Paragraph 96 in the Apprenticeship Funding Rules 2026/27, specifically concerning early completers whose delivered off-the-job training falls below their agreed baseline plan.
Context & Scenario
  • Standard Minimum: Published statutory minimum for the standard is 400 hours (or reduced to 350 hours due to 50 hours of RPL evidenced at initial assessment under Paragraph 86.1).
  • Agreed Plan: The provider plans delivery at exactly this baseline requirement (400 hours, or 350 hours post-RPL). No additional buffer hours are planned.
  • Early Completion: The apprentice accelerates their learning, demonstrates full occupational competence, and completes before the planned end date.
  • Actual Delivery Shortfall: Because the apprentice finished early, the provider delivers and evidences only 360 hours (or 310 hours in the RPL scenario)—falling short of the statutory baseline floor.
Under Paragraph 87.1, the rules state that there is no direct link between required hours and planned duration, and under Paragraph 96.4, any statement explaining a shortfall must include:
"Confirmation that the volume of hours delivered met the off-the-job training minimum requirement for the apprenticeship standard."
 
Does anyone have confirmation on how Paragraph 96 applies in this scenario:
  • Option A (Statutory Floor Protected): Paragraph 96 can only be used when planned hours were set above the statutory/RPL-adjusted minimum (as illustrated in the Paragraph 86.1 example of 550 planned vs 500 actual against a 466 minimum). If an apprentice finishes early, actual delivered hours cannot drop below the published statutory minimum (or RPL-adjusted baseline), and doing so would breach Paragraph 86 and place funds at risk of recovery.
  • Option B (Employer Discretion Overrides Statutory Floor): A signed statement under Paragraph 96 can validate and make compliant an early completer programme where actual hours delivered fall below the published statutory minimum (or RPL-adjusted baseline), provided the employer and apprentice sign off that they are satisfied.

We would like to confirm whether Option A or Option B reflects the correct interpretation of the rules?

 

Thank you

Replies

No one has replied to this post.

Chloe

Its option A - If their new minimum with RPL is 350 then they must complete at least 350 hours, even if they complete early

Steve Hewitt

It is CATEGORICALLY Option A. There is NO SUCH THING as a quick learner any more, any start after 1 Sept 2025 MUST meet the Skills England minimum OTJ (minus RPL) for the Standard, regardless of how quickly they do it. From the Service Desk, 21 April (after quite a bit of back and forth about it):

Thank you for contacting the Apprenticeship Service Support Team. My name is Honorine.
 
Your ticket number: 1573484.
 
I understand your concerns about the change regarding the previous understanding that some learners, without Recognition of Prior Learning (RPL), could complete their apprenticeship more quickly and therefore require fewer OTJ hours, as mentioned in paragraphs 97 and 98 of the 2024/25 Rules. I appreciate you reaching out to ask why the rules now require that early completers still complete the same minimum number of OTJ hours, and I'm here to help clarify this for you.
 
To clarify, the principle behind OTJ has changed. It is no longer framed as "what is needed to reach competence" but rather as a minimum condition for funding eligibility. This means that to be eligible for government funding, an apprentice without relevant prior learning must complete at least the published volume of OTJ hours for their standard.
 
OTJ is now treated as an input specification rather than an outcome dependent on learner speed. A minimum publicly funded training entitlement attached to the standard, not a variable expression of individual learning speed. These changes aim to reduce bureaucracy around OTJ calculations and provide greater flexibility in delivering off-the-job training.

Steve Hewitt

(we've checked and these are real humans sending these replies from the Service Desk, by the way, even if they do sound like they are very much spat out of an LLM...)

darren.oneill

Thank you both! We thought as much but wanted it confirming. I look forward to my robotic response from the service desk!

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