Functional Skills in Apprenticeships: What Employers Need to Know

Of the approved apprenticeship standards in the Find a Training Provider directory, 253 sit at level 3 and 152 at level 2. The English and maths requirement sits on top of all of them. It isn't written into the standard, your provider doesn't set it, and it is the most common reason a capable apprentice reaches the end of a programme and still doesn't pass. The rules for adult apprentices changed in February 2025, and most employer screening hasn't caught up with them. The apprenticeship funding rules for 2026 to 2027 set out where things now stand.

Which apprentices still have to achieve English and maths?

The requirement attaches to the person, not to the occupation. Two apprentices on the same standard, starting the same week with the same employer, can have completely different obligations depending on their age and what they already hold.

For apprentices aged 16 to 18 at the start of training, an English and maths qualification remains a condition of completing the apprenticeship. From February 2025 the Department for Education removed that condition for apprentices aged 19 and over at the start, leaving the decision with the employer and the provider rather than mandating it, as set out in the 2026 to 2027 apprenticeship funding rules.

Age is taken at the start of the apprenticeship. If you are recruiting someone close to their nineteenth birthday, the start date decides which rules apply to them for the whole programme.

Approved apprenticeship standards by level. Source: Find a Training Provider directory, November 2026.

Level	Approved standards
Level 2	152
Level 3	253
Level 4	121
Level 5	43
Level 6	108
Level 7	52

Level 3 is the largest group at 253 standards, with level 2 next at 152. Those two levels are where most school-leaver recruitment concentrates, so that is where the 16 to 18 requirement bites hardest. At level 6 and level 7, with 108 and 52 standards, apprentices more often arrive with prior attainment already evidenced, though you still can't assume it.

What counts as an exemption, and what evidence do you need?

An apprentice is exempt if they already hold an approved qualification. A GCSE in English language or maths at grade 4 or above, or grade C or above on the old grading scale, is the usual route, and a functional skills qualification at level 2 does the same job. GOV.UK sets out what each qualification level means, which is worth checking if a candidate presents something unfamiliar. The full list of accepted equivalents is in the 2026 to 2027 funding rules.

Three situations catch employers out repeatedly.

• Qualifications gained overseas. These need a formal statement of comparability before a provider can accept them. That takes time and usually costs money, so start it at application stage.
• Learning difficulties and disabilities. An apprentice with an education, health and care plan or a formally assessed learning difficulty can have the minimum requirement reduced, provided the evidence is held before the start, as described in the apprenticeship funding rules.
• Lost certificates. "I'm fairly sure I passed it" is not evidence. Replacement certificates from exam boards take weeks and have to be requested by the individual, not by you.

The provider has to hold the evidence on file. If it isn't there, the apprentice is treated as not holding the qualification, whatever they remember about year 11.

Why does English and maths surface at the end of the programme?

Because of the order things happen in. The provider runs an initial assessment in the first few weeks and identifies a gap. Functional skills teaching then gets scheduled around the occupational content, which is what the apprentice and their manager actually care about. Exam sittings are fixed dates. A near miss means waiting for the next sitting, and a second near miss means waiting again.

Meanwhile the apprentice can't move through gateway into their apprenticeship assessment until the requirement is met. So the problem lands on your desk well over a year into a programme you've been paying wages against, at the exact point you expected a qualified person.

Providers delivering at volume will tell you the same thing: the apprentices who don't complete are rarely the ones who couldn't do the job.

How do you screen for it before enrolment?

Move every one of these to the application stage.

1. Ask for certificates with the application, not at sign-up. Make it a standard document request alongside right to work.
2. Check the candidate's age at the planned start date, not at interview.
3. Ask the provider to run its initial assessment before you commit to the apprentice. A provider that will only do this after enrolment is managing its own risk, not yours.
4. Agree in writing who delivers the English and maths teaching, when it happens, and whether it is on site or remote.
5. Ask for the exam entry dates and the resit windows for the next twelve months. If the answer is vague, the plan is vague.
6. For apprentices aged 19 and over, make a deliberate decision about whether you want the qualification anyway, and record it.

How a provider handles this is a legitimate selection criterion. When you compare training providers, ask the question early and listen for a specific answer rather than a reassuring one. It tells you more about delivery quality than most of what is on a capability statement.

Does English and maths count towards off-the-job training?

No. English and maths study up to and including level 2 is excluded from the off-the-job training hours, as set out in the Department for Education's off-the-job training guidance. If an apprentice needs both, you are releasing them for the occupational training and for the English and maths on top.

That is a rota question as much as a funding question. Plan for the combined release time from day one rather than discovering it in month four.

On cost, English and maths up to level 2 is funded separately from the apprenticeship funding band under the 2026 to 2027 funding rules, so it doesn't eat into the band for the standard itself or draw down the balance in your apprenticeship service account, also known as DAS after its original name, the Digital Apprenticeship Service.

What the February 2025 change doesn't do

It doesn't apply to 16 to 18 year olds, who remain subject to the requirement under the current funding rules. For a level 2 or level 3 intake built around school leavers, very little has changed.

It also doesn't remove your ability to require English and maths. Plenty of employers still do, because the qualification matters for professional registration, for progression onto a higher-level programme, or simply because the role needs it. The difference is that the choice is now yours and the provider's, made jointly, rather than imposed. Make it consciously and put it in the training plan.

Before you commit to a programme, check what the occupational standard actually asks for. You can browse apprenticeship standards and their funding bands to confirm the level, the typical duration and what the assessment covers, then line that up against what your candidate already holds.

Frequently asked questions

Do apprentices aged 19 and over still need level 2 English and maths?

Not as a condition of completing. From February 2025 the Department for Education removed the exit requirement for apprentices aged 19 and over at the start of training, as reflected in the 2026 to 2027 apprenticeship funding rules. Employers and providers can still agree to include it, and many do where the role or professional body expects it.

Does a GCSE from twenty years ago still count?

Yes. A GCSE at grade C or above on the old scale, or grade 4 or above on the current scale, is accepted under the apprenticeship funding rules, regardless of when it was awarded. The practical obstacle is evidence rather than age. The provider needs sight of the certificate or an acceptable alternative record before the apprenticeship starts.

Who pays for the functional skills training?

Government funds English and maths up to level 2 separately from the apprenticeship funding band, under the 2026 to 2027 funding rules. You don't pay for it from your levy account and it doesn't reduce the budget available for the occupational training. Your real cost is the paid release time while the apprentice studies and sits exams.

Can an apprentice with a learning difficulty be exempt?

The minimum requirement can be reduced where an apprentice has an education, health and care plan or a formally assessed learning difficulty, subject to the evidence rules in the apprenticeship funding rules. The evidence has to be in place before the apprenticeship starts, so raise it during recruitment rather than after a failed first assessment.

What happens if the apprentice never passes?

For an apprentice aged 16 to 18, they can't complete the apprenticeship, so you carry the wage cost without the outcome. That is why screening at application stage matters more than any intervention you can run later. For apprentices aged 19 and over, completion is no longer blocked by English and maths under the current rules.

Should we rule out candidates without GCSEs?

No. You'd lose good people for a reason that has nothing to do with the job. Screen so you know what you're taking on, build the study time into the rota from week one, and choose a provider with a credible teaching and exam plan. The cost is planning, not capability.

If you're scoping a programme now, start with the occupational requirement and work back. Check the standard, its level and its funding band, then test providers on how they assess and deliver English and maths before you sign anything.