Wayne Hosking commented, 13 May 2026 13:11

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        

1. 16-18 Co-investment Waiver - Change of Employer

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 f...

Wayne Hosking commented, 24 March 2026 11:38

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.

1. 16-18 Co-investment Waiver - Change of Employer

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 bac...

Wayne Hosking commented, 24 March 2026 08:48

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?

1. 16-18 Co-investment Waiver - Change of Employer

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 tha...

Wayne Hosking commented, 17 March 2026 13:56

Hi Steve,   After four emails i eventually got some information, see below. Thanks for responding. Wayne [image]

1. Loss of Employer at EPA, new Employer ref 120.2

Hi Steve,   After four emails i eventually got some information, see below. Thanks for responding. Wayne

Wayne Hosking commented, 05 February 2026 13:41

Hi there,   Was just looking at that one on the DSAT report,  "as there's no way in the ILR to indicate that RPL has been applied", that why they have added new hours fields into 2026/2027 spec. " Planned hours for off the job training due to a reduction in prior learning (HRS 4) should record the hours of off-the-job training that have been removed from the apprenticeship in recognition of prior learning." lots of new HRS types. Wayne

1. DSAT 26A-215 planned OTJ implications

Hi there,   Was just looking at that one on the DSAT report,  "as there's no way in the ILR to indicate that RPL has been applied", that why they have added new hours fields into 2026/2027 spec. " ...

Wayne Hosking commented, 23 September 2025 12:33

Thanks Karen,    We were thinking about the self declaration as an option but seems like you have already got the answer, sadly. Additional checks it is :( Kind regards Wayne  

1. ASF eligibility: dependents of skilled workers

Thanks Karen,    We were thinking about the self declaration as an option but seems like you have already got the answer, sadly. Additional checks it is :( Kind regards Wayne  

Wayne Hosking commented, 23 September 2025 11:23

Hi all,   I'd like to know whether providers are now doing double share code checks? One for the dependent and one for those they are dependent on? Really annoying as adding in that seasonal workers not being eligible, you don't know they are a seasonal worker without an additional check. Kind regards Wayne

1. ASF eligibility: dependents of skilled workers

Hi all,   I'd like to know whether providers are now doing double share code checks? One for the dependent and one for those they are dependent on? Really annoying as adding in that seasonal worker...

Wayne Hosking commented, 31 July 2025 15:15

Hi Jo,   As far as i'm aware its all apprenticeships, minimum duration of 8 months. Kind regards Wayne Apprenticeship Funding Rules 2025/2026 v2 71. The provider must confirm that, after all relevant prior learning and experience has  been taken into account, the apprenticeship practical period lasts for a minimum  duration of 8 months. For example, to satisfy this requirement, an apprentice who  starts their training on 1 August 2025 must still be receiving training on 31 March  2026. 71.1. The apprenticeship standard specification or assessment plan may require  this practical period of training to be longer, to support the delivery of the  full apprenticeship content.  71.2. The end-point assessment can only be taken after the minimum duration  has been met. 

1. Clarification on new 8 months min duration

Hi Jo,   As far as i'm aware its all apprenticeships, minimum duration of 8 months. Kind regards Wayne Apprenticeship Funding Rules 2025/2026 v2 71. The provider must confirm that, after all releva...

Wayne Hosking commented, 19 June 2025 07:35

Hi Tracy, Well if that is the case then that is ridiculous as its in the current 2025/2026 rules stating its from August, its very poor planning and typical of this sector over the last four years. Wayne  

1. New Funding rules Apprenticeships 25/26

Hi Tracy, Well if that is the case then that is ridiculous as its in the current 2025/2026 rules stating its from August, its very poor planning and typical of this sector over the last four years....

Wayne Hosking commented, 19 June 2025 07:25

Hi Ruth,   Yeah concerned by that statement above by Tracy, i have not seen that anywhere and are planning to align with the new minimum requirement from September 2025. Wayne

1. New Funding rules Apprenticeships 25/26

Hi Ruth,   Yeah concerned by that statement above by Tracy, i have not seen that anywhere and are planning to align with the new minimum requirement from September 2025. Wayne