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Guidance for employers in the UK on how to manage apprentices during the coronavirus outbreak

United Kingdom
Written by
Lewis Silkin, widely recognised as the UK’s leading specialist employment law practice.
Most businesses in the UK will be affected in some way by coronavirus, but apprentices may be particularly disadvantaged if they are unable to continue or complete their apprenticeship and gain their qualifications. What issues should employers of apprentices be considering?

Last month, the UK Government issued guidance for apprentices, employers, training providers, assessors and quality assurance providers in response to the impact of COVID-19. In recognition of the potential disruption caused to apprentices, the government has also implemented new measures to make it easier for apprenticeships to continue.

The government updated its guidance on 6 April 2020, although nothing substantially new for employers was added. An important clarification, however, was that there are no current plans to pause the collection of the apprenticeship levy because of COVID-19.

Training arrangements

Whether it be because of illness, caring responsibilities, inability to attend training or operational disruption, it is likely that apprenticeships will not be able to continue as planned for the time being. The government is encouraging employers and training providers to make use of distance learning tools where this is possible. In some instances, however – particularly where the qualification relates to manual work – this may not be possible.

Employers should speak to training providers to understand whether training can continue during this time. If this is possible, the apprentice’s individual learning record should be kept up to date in the usual way.

Breaks in learning

If there is a break in the apprentice’s learning due to sickness, lack of training or any other reason, the following rules apply:

  • If the break is for less than four weeks, the employer does not need to report it and the end-date of the apprenticeship remains the same.
  • If the break is for more than four weeks, the employer or training provider must report a formal break in learning in the apprentice’s individual learning record.
  • While breaks can normally only be initiated by the apprentice, employers and training providers can now initiate a break. During the break, the apprenticeship is ‘paused’ by the employer through the apprenticeship service, which means it can resume at a later date.


During a break in learning, the apprentice does not need to comply with the minimum 20% off-the-job training requirement.


Where possible, end-point assessments (EPAs) may be carried out virtually. If this is not possible but an apprentice is ready for their EPA, it will be rescheduled. If there was a specific time limit for the EPA to take place, a further 12-week break is allowed.

As apprentices need to be employed at the point of their EPA, employers with apprentices on fixed-term contracts may need to extend their contracts to allow for the assessment to take place

Continuing employment

Despite being on a break in learning, apprentices will remain employed. If due to the nature of the apprenticeship or the need for physical supervision, the apprentice can no longer fulfill their role, the following options should be considered:

If other work is available and the apprentice is able to perform it, the employer may seek to temporarily reassign them to an alternative role. This is subject to the apprentice’s contract allowing this, or upon obtaining consent.

Apprentices can be furloughed under the Coronavirus Job Retention Scheme in the same way as other employees, and they can continue their apprenticeship training while furloughed as long as this does not result in revenue generation for the employer. It is possible, therefore, for an apprentice to be furloughed without the apprenticeship being paused. Where this happens, the scheme guidance makes clear that the employer must pay them at least the Apprenticeship Minimum Wage, National Living Wage or National Minimum Wage (as appropriate) for all the time they spend training. That means the employer must cover any shortfall between the amount it can claim for the apprentice’s wages through the furlough scheme and the relevant minimum wage.

It is possible for apprentices to be made redundant, but certainly the government’s intention is that their measures will prevent this from taking place. If an apprentice is made redundant, the training provider should assist the apprentice is to find another role so they can complete their apprenticeship.

Saffron O'Gorman
Associate - United Kingdom
Lewis Silkin

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