Challenge four - Stakeholder roles and responsibilities

Is it clear what each stakeholder within the apprenticeship system is responsible for? Is the External Quality Assurance (EQA) system ensuring that EPAs are being delivered effectively and consistently? 6th November 2019

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1) The role of employers

Given the requirement for only 20% of an apprenticeship to be completed off-the-job, it was noted by several members of the group that the employer provides a crucial component of each apprentice’s learning experience. However, there was general agreement that the conceptualisation of the employer’s role may need addressing. For example, there are no formal qualifications required to be a trainer of apprentices within an employer (unlike in many other countries). In addition, there is no external quality assurance of the training that employers are providing. This can lead to inconsistent practice in terms of supporting apprentices, even between different departments of the same organisation.

Many employers are keen to provide an excellent training programme for their apprentices. Even so, some employers find it hard to check the quality of their own delivery. There are no agreed mechanisms for employers to measure and record their business activity related to apprenticeships. At the same time, some apprenticeship standards are not easy for employers to interpret in terms of what is required of them throughout the duration of the training. Subjective interpretations of ‘behaviours’ or ‘skills’ that apprentices are supposed to acquire can therefore create more variability in terms of an apprentice’s experience. This becomes even more of a barrier for occupational areas that do not have a long history of designing progression routes and training programmes.


  • How formalised should the role of employers be within the context of a full apprenticeship training programme?
  • Should we consider moving towards additional checks on employers to make sure they have the right people and the right skills in place to deliver high-quality apprenticeships?
  • Should the government consider introducing penalties for employers who fail to allow their apprentices to adhere to the 20% off-the-job requirement?
  • How could the trailblazer process be adapted to make it easier for employers to understand what they need to deliver in-house?
  • What additional support for employers would help improve the consistency of the workplace experience of apprentices?

2) Missing infrastructure and partnerships

Although there is plenty of goodwill and commitment from employers to improving apprenticeships, the group felt that the lack of an established ‘infrastructure’ for conversations about designing and delivering apprenticeships made it harder for all the stakeholders to share their views. Ever since the ‘Sector Skills Councils’ were dismantled several years ago, there has been no concerted attempt to fill this infrastructure gap – meaning that there is still uncertainty about who is speaking on behalf of employers. For example, the Institute for Apprenticeships and Technical Education (IFATE) has 15 ‘route panels’ to act as the voice of employers, but these were thought to be too variable in terms of their representativeness of each sector as well as their size. The ‘apprenticeship commitment statement’ was recognised as a possible vehicle for improving the clarity of roles and responsibilities, but the existence of the ‘apprenticeship agreement’ as a separate document alongside this might have the situation more complicated.

Other stakeholders are involved in determining the quality of apprenticeships, yet their role is sometimes just as uncertain. Professional bodies may be able to support employers and assist with creating occupational standards, but some bodies have a commercial interest in certain qualifications being incorporated into apprenticeships, which has not always been enacted in a transparent manner. Moreover, Ofsted is theoretically in charge of monitoring apprenticeship quality, although the ESFA can overrule them when it comes to deciding which providers can re-start hiring apprentices after a poor Ofsted inspection.


  • How much control do employers want over the apprenticeship system, given the government’s push for an ‘employer-led’ system?
  • Should the government seek to reintroduce a new form of ‘Sector Skills Councils’ to boost the collective voice of employers?
  • What reforms could be made to the IFATE route panels in future?
  • Does more need to be done to ensure that the trailblazer process involves providers and End Point Assessment Organisations (EPAOs)?
  • What role should professional bodies play in promoting apprenticeship quality?
  • Can the roles of Ofsted and the ESFA be clarified?

3) Lack of standardisation with EPAs 

The quality assurance of EPAs was felt by the group to be one of the most critical elements of a functioning apprenticeship system. It was widely acknowledged that the loss of trust in EPAs could damage the apprenticeship brand, yet this is a potential risk of the current model which sees thousands of apprentices training against the same standard but being tested by different EPAOs. The inconsistency generated by having different EPAOs for the same apprenticeship standard – over 20 EPAOs in some cases – was another issue raised by the group as an issue for monitoring the quality of assessments in terms of their design and delivery.

The consequences of a lack of standardisation in the quality assurance process was also highlighted as an area of concern. If employers lose trust in EPAs then they might be less willing to enter apprentices for their final assessments – something that is already causing problems with providers and might potentially be exacerbated. In addition, question marks over the rigour of EPAs may deter future apprentices from applying for technical courses instead of academic ones, which might further weaken the apprenticeship brand.


  • What role should Ofqual play in the EPA process?
  • How can a greater level of standardisation be introduced into the EPA process without creating large additional burdens for stakeholders?
  • Can the risks of involving unregulated organisations in the EPA process be managed in any meaningful way?
  • Would quality assurance be more straightforward if the EPA was a qualification itself?
  • Should employers face any penalties for not entering their apprentices for the EPA?