The DfE have dropped Version 2 of the 2025/26 Apprenticeship Funding Rules, and as ever, there’s a lot for providers and operational leads to get their heads around. Here’s my honest take on what’s actually changed, what’s just been clarified, and what you need to do differently if you’re running apprenticeship programmes from August 2025.
From August to December 2025:
If you deliver any of the 73 standards on the DfE’s “transition list”, you’ll need to use the newly-published minimum OTJT hours for new starters. These are set out in Annex C (definitely worth a read if you haven’t already). Remember: these are the minimum – most providers will, and should, plan above this.
If your standard isn’t on the list, you stick with the minimum hours published back in May.
From January 2026:
For those 73 standards, new starts will either go back to the original minimum hours (set in May), or switch to further reduced (moderated) hours. It all depends on the outcome of Skills England’s ongoing reviews. The DfE have flagged a handful of standards where delivery and minimums are miles apart – expect more changes for those.
Minimum OTJT for the first 7 Foundation Apprenticeships is now 187 hours. That’s the baseline – no leeway, no rounding down.
If you plan more OTJT hours than the minimum, but end up delivering less (as long as it’s still above the minimum), you now need a signed employer statement explaining the gap. This was dropped in v1, but it’s back – so make sure your compliance process is up to date.
RPL reductions must now be taken from your planned delivery model, not from the minimum published hours. Example: If you usually deliver 500 hours, but minimum is 400 and you deduct 50 for RPL, you should deliver 450 (not 350).
The spirit: don’t cut RPL from the bare minimum – start with your real model.
DfE/ESFA language: Everything now refers to DfE, not ESFA – a sign of the times.
Care leavers: Extra clarity on eligibility, evidence and bursary payments.
English/maths: Employers now have to actively opt in 19+ apprentices to do standalone English/maths, and you must record this. If they don’t opt in, you don’t need to evidence prior attainment.
Minimum apprenticeship duration: Now 8 months for new starts (down from 12), as long as all other rules are met.
No automatic duration extension for part-time/zero hours apprentices – you set a “realistic duration” instead.
Subcontracting rules: Tightened, especially for providers deemed “high risk.”
Some tweaks to payments, evidence and end-point assessment rules – mostly clarifications, but check your processes.
Check and update your OTJT planning for every relevant standard before August.
Update compliance: bring back employer statements if you ever under-deliver (vs planned).
RPL = reductions from your planned model, not the minimum.
Foundation Apprenticeships: 187 hours, end of story.
More changes may come for a few standards, so stay alert.
If you want a one-page checklist, or you’re not sure how these apply to your delivery model, get in touch.