Apprenticeship training can be planned over as little as 8 months, but the hours an employer releases do not shrink with it, and each one must sit in a dated, timed record an auditor can check.
Off-the-Job Training for Employers: Hours Set Standard by Standard
By James Cotton · Last updated · Sources checked · 13 min read
Part of our topic guide on Data & AI Apprenticeships.
By James Cotton, Founder, iO-Sphere
The figure on each standard's page
For starts from 1 August 2026, the apprenticeship funding rules for August 2026 to July 2027 (version 3, published 29 July 2026) from the Department for Work and Pensions (DWP) drop their reference to Annex C, last year's list of minimums; paragraph 85 points to each standard's own page on Skills England's website.
Regulation 3 of the Apprenticeships (Miscellaneous Provisions) Regulations 2017 makes off-the-job training (training in the apprentice's normal working hours to achieve the standard) a condition of every approved English apprenticeship and requires the apprenticeship agreement to state the amount. It sets no number; the hours on each standard are a funding condition.
Skills England shows the figure on each standard's page as "Minimum hours for compliance", and these are the five standards under our programmes. For any other standard, the figure is published on the front of that standard's own page.
| Standard (title, code, level) | Programme iO-Sphere delivers | Minimum hours for compliance (as displayed) |
|---|---|---|
| Data technician, ST0795, Level 3 | Data & AI Essentials (Level 3) | 348 |
| Data analyst, ST0118, Level 4 | Advanced Data & AI (Level 4) | 370 |
| Business analyst, ST0117, Level 4 | AI Transformation (Level 4) | 348 |
| Data protection and information governance practitioner, ST0967, Level 4 | Data & AI Governance (Level 4) | 370 |
| Data engineer, ST1386, Level 5 | Data Engineering (Level 5) | 418 |
The figure covers all the knowledge, skills and behaviours (KSBs) the standard sets out, and funding requires at least that figure for an apprentice with no relevant prior learning (any of that content already held). A provider may plan more, and fewer only with prior learning evidenced at the initial assessment; however much comes off, no programme falls below 187 hours.
For the five data standards, the floor for a person with no prior learning is therefore the published figure, 348 to 418 hours. Prior learning comes off the plan as hours, and the price falls with it.
Our initial assessment, for each learner at the start, is a skills radar mapped to the standard's KSBs plus a professional discussion with the learner, and it sets the starting point for the training plan.
DWP's Apprenticeship off-the-job training guidance says the minimums sit slightly below the median hours providers recorded for completers with no prior learning, where such data existed, and come from a formula on the typical duration where it did not. It names no method for any of the five and calls the approach cautious: minimums may need to rise.
Any change to a standard's hours will carry a new version number, after consultation and notice. Data technician, business analyst and data engineer already show a revised version awaiting implementation with the same hours.
How the 20% rule became a number of hours
The 20% dates from 2017, chosen, DWP's guidance says, because it broadly equalled a day a week when most apprenticeships ran on day release; the 2018 to 2019 rules began deducting statutory leave.
From 1 August 2022 a week capped at 30 hours set the minimum at 6 hours a week for anyone working 30 or more, across the practical period (the part of the apprenticeship in which training is delivered, before the final assessment): 278 hours for 12 months, 418 for 18.
The Department for Education's Apprenticeship evaluation 2023: employer survey, by telephone with 3,926 employers in England from 27 July to 27 October 2023, found that in 2023 about a third (35%) knew of that change.
From 1 August 2025 the minimum became a number of hours per standard, not a share of the working week, with no delivery link to programme length and no automatic extension for part-time programmes. From the same date, SI 2025/599 cut the minimum practical period in law from 12 months to 8.
Apprentices who started earlier, including those back from a break in learning (a pause of at least a clear calendar month), stay on the old rule. DWP's reasons: an eight-year-old policy, a floor that would otherwise have fallen from 278 hours to 187, and "one of the biggest areas of non-compliance in a funding audit".
The guidance also records a transition for 73 standards, with lower minimums for August to December 2025 starts, which ended on 1 January 2026. Data technician and business analyst went from 300 hours to 348, and any start planned now uses the full figure.
The old figures still appear on official pages: GOV.UK's Become an apprentice (last public update 14 October 2024) gives "at least 20% of your normal working hours", and the ST0118 assessment plan of June 2021 "a minimum of 20% off-the-job training" and 12 months on programme.
DWP's Provider guide to delivering high-quality apprenticeships, updated 21 October 2026, says "a minimum of 20% (or 6 hours a week on average)" in its induction and monitoring sections, beside the 2025 rule in its off-the-job section. For a start today the funding rules supersede all three, in paragraph 77 (8 months) and paragraphs 85 to 86 (the hours).
What counts towards the hours
In 2023, the same survey found 70% of employers said they understood what counted (59% of those with fewer than ten staff) and 29% did not, under the rules then.
The funding rules define off-the-job training as training within the practical period, in normally paid hours excluding overtime, towards the apprenticeship's KSBs; training solely to do the job is on-the-job training. DWP's infographic asks whether an activity is new, directly relevant, in normal working hours and not excluded; a "no" at any step rules it out.
New means filling a gap between the assessed starting point and the standard, so nothing beyond the standard counts, and nor does practice once a skill has been taught.
The training happens away from the productive job, though not necessarily away from the workplace: a desk, home or classroom can host it, and a live working environment cannot carry all of it. Applying new skills in the job is the employer's half of the apprenticeship (paragraph 67).
Paragraph 83 lists what can count: teaching theory, through lectures, role play, simulation exercises or online learning; practical training such as shadowing, mentoring and industry visits; learning support; assignments; and revision. For the parts of a standard a workplace cannot supply, we use realistic case studies and simulations, which we call Prism.
Paragraph 84 rules out, among others, initial assessment and onboarding, exams and on-programme testing, and KSBs the standard does not require. Standalone English and maths qualifications sit on top of the minimum, and the plan shows them outside it.
Mentoring and shadowing count only on the rules' terms: new, relevant learning in working hours, documented in the plan, from a more senior or experienced colleague, off productive work, never general line management. Training the employer delivers itself counts when planned and evidenced. If the employer takes a fee for that delivery, it works at actual cost and makes no profit from training its own staff.
A portfolio does not count, since compiling one teaches nothing new; nor does training for a duty outside the standard, which a provider may offer commercially. DWP's training plan template shows an employer-requested presentation skills course at 0 off-the-job hours, for the employer to fund.
From hours to weeks of release
The hours come out of normal paid hours, excluding overtime, which DWP leaves out as often unplanned; the apprentice's own time never counts, and none may be expected. By exception, training can fall outside those hours, agreed by the apprentice and compensated with time off in lieu or pay, and never for most of it.
The apprentice is paid for training time as well as work (paragraph 75). Funding covers tutors, delivery locations and learning materials (107.1 to 107.3); wages, including backfill, and travel and accommodation for training are the employer's (112.1 and 112.2). DWP's guidance calls the time "a financial burden for employers".
Provider and employer agree the volume, timeframe and delivery model, because the hours carry no fixed length; the typical duration is only a guide, and a compressed programme means more training a week. All of it falls inside the practical period, which ends before the end-point assessment, the final assessment that closes the apprenticeship.
DWP's look-up table takes 370 hours as its example: approximately 16 months at an average of 6 hours a week, 8 months at 12, and under 8 months is non-compliant. It is an illustration, its months allowing for statutory leave and assuming the same delivery every week.
Both floors apply together, at least 8 months and the minimum hours, and within them the employer agrees the spread: day release, usually a day a week; block release, a week or more at a time, each week counted as 30 hours; front-loading, half the planned hours in the first quarter of the duration; or a mix.
Active learning is due in every calendar month, or every three months under an agreed block or front-loaded model, with no monthly volume set. One empty month needs no break if learning resumes the next; two in a row force a retrospective break in learning and a re-plan. Keeping that release clear falls to the apprentice's line manager.
Our programmes run 15 months of training, then a 3-month end-point assessment (Data Engineering: a 4-month end-point assessment). We start from the standard's hours and spread them across the training months, so the week follows: for a 370-hour standard such as data analyst, about 5.7 hours a week on a calendar-week basis, counting every week of the 15 months, holiday weeks included.
When the working week changes
One minimum covers full-time, part-time and term-time apprentices. Below 30 hours a week the programme is no longer extended automatically; the provider sets a duration at which the training is realistic and agrees it with the employer (paragraph 87.3), and regulation 4 requires the employer to weigh part-time working when agreeing the practical period.
Fewer than 30 hours, or a zero-hours contract, must not be a barrier, though zero-hours contracts work only where every other funding rule can be met.
If hours change mid-programme the minimum stays put, and the plan may have to move to keep training inside normal working hours; the agreement is revised for a changed contract or working pattern. Annual leave, public holidays and short absences are not breaks in learning; during a break no off-the-job training takes place, and the hours can stay the same on return.
Where the hours sit in what you sign
The apprenticeship agreement, a legal agreement between employer and apprentice and part of the employment, carries the employer's commitment to release the apprentice for the hours it specifies. Regulation 3(2) and paragraph 72.6 require it to state them, in DWP's agreement template as "Planned amount of off-the-job training (hours)". Employer and apprentice sign and keep a copy, and the employer gives the provider one.
The training plan, a three-way agreement between provider, employer and apprentice, records the apprentice's normal paid hours, the total planned off-the-job hours, the delivery model, whether occupational training sits inside those hours, and the employer's written confirmation of release for training in normal working hours. Activity is agreed before delivery.
Paragraph 66 commits the employer to release the apprentice "as documented in the training plan" and to give them the chance to embed what they learn. DWP's training plan template, which is optional, writes the employer's side as delivering training where agreed, allowing it in normal hours and helping collect evidence the employer holds.
The planned hours also go on the individualised learner record (ILR), the data a provider submits for each apprentice, fixed there from day one while the agreement and plan are updated. All three parties sign the plan and keep a current signed version, and the employer re-signs when re-planned training changes the release.
New for 2026 to 2027, paragraph 101 has all three agree at the end that the plan's content was delivered.
The evidence behind every hour
The funded provider answers for all the evidence, including training the employer delivered. Each hour must be quantifiable and eligible, with a broad description, such as a module, lesson or KSB, that cross-checks against the plan; any format works, electronic signatures included, and some apprentices keep learning logs.
DWP's guidance gives "20 hours off-the-job training in August 2026" as evidence that fails: without dates and times, no auditor can tell whether the hours fell in working time.
Its evidence collection template logs date, start and end times, activity, duration and eligibility under a declaration that the training was new, relevant and in working hours, with signature rows for apprentice, employer and provider, and asks: "Please do not simply put 'off-the-job training'."
The provider enters the hours delivered on the ILR at the end of the practical period, before the final assessment, and they may inform future minimums. Before then, any slippage against the plan is documented at the progress review, the regular check of progress against the plan, held on a set cycle with the employer taking part.
DWP calls a review a discussion, so it never evidences learning. An audit counts the quantity of training against the definition and leaves quality to bodies such as Ofsted, whose inspection toolkit expects employers and staff to co-plan on- and off-the-job training.
What an audit finds, and what follows
DWP's guidance says failing the minimum "will result in a 100% clawback of funding", and that off-the-job training, the programme's biggest cost, is monitored closely: audits review all the evidence behind a random sample of records, and desk checks test ILR data. The money is recovered from the provider: funded and audited, it is the one that "will have action taken against them".
DWP also expects that "most errors that relate to off-the-job training will relate to paperwork".
The Department for Education's common findings for the 2024 to 2025 assurance year, published 30 September 2026, call off-the-job training "the main cause of apprenticeships funding errors" in starts under the earlier percentage rule, citing "no OTJT records", "dates and times missing", "bulk hours" declared "with insufficient context of eligibility" and "hours prior to start not being eligible".
In training plans they record "inconsistencies in off-the-job hours (OTJH) between sources" and "ineligible activity" planned within the hours; on agreements, signatures "typed, cut and pasted, or being editable or removable". A missing or incomplete agreement makes the apprenticeship ineligible, and all funds for that learner may be at risk.
Where delivery lands between the minimum and the plan, the provider writes a statement of hours planned and delivered, with the reason, for employer and apprentice to sign within 12 weeks of completion (DWP's example: 550 delivered, 500 minimum, 700 planned). An employer's refusal to sign puts funds at risk.
When work pressure stops the release, the provider may deliver differently or pause the programme with a break in learning; failing that, the apprentice must be withdrawn.
Our view, from those findings: each month the employer should ask the provider for the record of its apprentice's training that month, every entry with a date, start and end times and an activity, and check it against the plan. With active learning due monthly and one empty month allowed before a break, a monthly look leaves time to re-plan.
The paperwork, item by item
Each line gives the record, who signs it and its paragraph.
- The apprenticeship agreement with its planned hours: signed by employer and apprentice, who keep a copy, in signatures neither typed, pasted nor editable (paragraph 72.6; regulation 3(2)).
- The current training plan with the written release: signed by provider, employer and apprentice, who each retain a current signed and dated version (paragraph 100; glossary).
- Where working locations are unknown at the start, the employer's written statement to the provider that at least half the working hours will be in England (an eligibility condition: paragraph 30.5 and its evidence box).
- Dated, timed records of training the employer delivers, each with a broad description, signed by apprentice, employer and provider on DWP's template where used (paragraph 100.11.1; evidence box).
- For training outside normal hours, the apprentice's agreement and the compensation given (paragraph 84.6.1).
- After re-planned hours or a changed working pattern, the re-signed plan or revised agreement (paragraphs 103.4.1 and 298.5).
- At the end, the three-way agreement that the plan was delivered (paragraph 101), and any statement of hours below the plan, signed by employer and apprentice within 12 weeks (paragraphs 96 to 98).
Frequently asked questions
Does training during parental leave count?
Training on keeping-in-touch (KIT) days, the days an apprentice on leave works by agreement, or shared parental leave in touch (SPLIT) days is the only training that counts, under a KIT agreement all three parties sign. Otherwise the apprentice on leave is not working, and a break in learning covers the whole leave.
What if the apprentice moves to another employer?
The hours across both employers must together meet the standard's minimum. Training continues if the move completes within 4 weeks; otherwise the apprentice can take a break in learning of up to 8 weeks before being withdrawn.
What if the apprentice is made redundant?
Funding continues for up to 12 weeks of off-the-job training while the apprentice looks for another job, where the training can still be delivered, and may run to completion once at least 75% of the training is done or within 6 months of the final day of training.
Does our own compulsory training, such as first aid, count?
Compulsory training counts when it passes the same tests as any other activity; DWP calls it irrelevant that it is a company requirement or that other staff take it too. A generic company induction should not be included.
Will it fit your cohort?
Tell us your cohort size and what your people need to be doing by next year, and we will say whether we are the right shape, including when we are not.