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If you're a College, it's an ILR requirement;
FE colleges must also send details of all learners who are not in receipt of public funding from the ESFA (apart from learners subcontracted in from a school or Higher Education Institution).
If you're not a College, I'm not sure why they are insisting on it being in the ILR, though I'd argue it's a good idea to do so anyway. You can still code as unfunded.
I guess you mean this bit Martin;
Non-funded apprenticeships
Training organisations are asked to send details of apprenticeships that are not funded by the ESFA in the following circumstances:
where the apprenticeship programme is delivered within the terms of an ESFA contract, and
on a voluntary basis in other cases
These non-funded apprenticeships need to meet the collection requirements for frameworks or standards, but don’t need the Financial dataset to be recorded.
I don't know what "within the terms of an ESFA contract" means, but if it's not that, it is technically voluntary. That could be something to quote to a EPAO.
Andrew Dickens
End Point Assessment for commercial Apprentice
Created
We have a learner who has completed an apprenticeship training programme on a commercial basis, due to not meeting some eligibility criteria. As a result, we have not included the learner in our ILR. However, our EPAO are now telling us that unless the learner is registered in the ILR (even if it is unfunded) then they will be unable to issue us with a Certificate saying he has passed his End point assessment, even though he has sat the EPA and passed it.
Is this correct? Surely the EPAO can issue the certificate if they have managed to charge us, register the learner for the assessment and conduct the EPA?
Thanks