Skills England published new guidance on 6 July 2026 placing sole responsibility on employers to verify apprentice workplace behaviours at the point of programme completion. This article sets out what the guidance means, the key risks employers should be aware of, and the practical steps organisations should take now.

What does the new guidance mean?

Under the apprenticeship standards framework, behaviours form one of the three core components - alongside knowledge and skills - that apprentices must demonstrate to complete their programme. Previously, the assessment of behaviours formed part of the end-point assessment process conducted by an independent end-point assessment organisation. The new guidance removes independent assessment from the behavioural component entirely, replacing it with a single employer confirmation based on evidence gathered throughout the apprenticeship that the required behaviours have been demonstrated consistently across a range of tasks and contexts.

This will hopefully lead to a positive change which strengthens employer engagement whilst continuing to maintain the quality of apprenticeship standards, ensuring employers continue to be invested in developing individuals who will positively contribute to their workforce and the wider industry, whatever sector that might be.

What are key considerations for employers?

• Consistency of logging across teams: If apprentices move between directorates with different supervisors, it is vital to have a standardised logging approach. There is a risk if a single manager has not observed the apprentice's full behavioural development and if logging standards vary between supervisors, that there may be inconsistent approaches across teams or directorates.
• Sign-off responsibility: Apprentices may work across multiple locations or teams, so it is essential to establish who holds sign-off responsibility. Employers should use supervision, appraisal and performance management structures from day one. Supervising managers should contribute to a cumulative record, so that the sign-off reflects the full programme.
• Risk of indirect discrimination: As the guidance relies on employer-assessed behavioural standards applied without independent oversight, there is a risk of indirect discrimination, particularly for disabled apprentices. If the duty to make reasonable adjustments applies, adjustments might include extending the observation period or adapting how observations are recorded. 

What practical steps should employers take?

The guidance represents a significant shift in accountability, placing employers firmly at the centre of behavioural assessment for apprenticeships. Employers who act proactively to embed robust governance structures, consistent logging practices and reasonable adjustment frameworks from the outset will be best placed to meet their obligations and to ensure their apprentices are supported to succeed. In practical terms, employers may need to consider the following steps:

• Designate a responsible manager within the organisation who holds accountability for behavioural sign-off at the point of apprenticeship completion, ensuring clear lines of responsibility where apprentices work across multiple teams or locations.
• Implement a standardised framework for logging and recording behavioural observations, so that evidence is captured consistently across directorates, supervisors and sites throughout the duration of the apprenticeship.
• Integrate behavioural assessment into existing supervision, appraisal and performance management processes from day one, rather than treating it as a standalone exercise at the point of completion.
• Review reasonable adjustment policies and procedures to ensure they adequately address the assessment process, including consideration of extended observation periods or adapted recording methods where necessary, to mitigate the risk of indirect discrimination.
• Provide training and guidance to all supervising managers on the employer's obligations under the new guidance, including how to assess and record workplace behaviours objectively and consistently.
• Establish internal quality assurance mechanisms to periodically audit behavioural records and sign-off decisions, ensuring standards are applied uniformly and that the organisation can demonstrate compliance in the absence of independent external oversight.

Our employment team has extensive experience advising employers on apprenticeship frameworks, workforce governance and discrimination risk. If you would like advice on how to structure your organisation's approach to apprenticeship behaviour verification in light of the new guidance, please do not hesitate to contact us.